PSM and RMP Citations/Analysis

NOTICE:  The OSHA cases found in these posts may be taken from OSHA citations BEFORE the “informal conference” takes places.  These cases are posted for AWARENESS and EDUCATIONAL purposes only.  I have scrubbed company names and locations from my postings, but not from the OSHA and EPA documents.  These posts are in NO WAY meant to shame any company, just providing information showing the things OSHA/EPA are finding in their PSM/RMP inspections.

EPA RMP Citations @ WTP after 180 pound Cl2 release (Cl2 & $ 25K)

Interesting case as the focus of the release was… “maintenance procedures failed to include clear instructions for detecting chlorine leaks after maintenance activities“ Respondent is the owner and operator of a facility. On August 30, 2024, there was an incident at the Facility that resulted in an accidental release of 180 pounds of chlorine (the…...

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EPA RMP citations @ Dairy (NH3 & $104K)

The Respondent owns a milk production facility. According to U.S. Census data, more than one thousand people live near the Facility. The Facility has been in use as a dairy since 1886, and at the time of EPA’s inspections, included a milk production site, office space, chemical storage, warehousing, and production areas. The last major…...

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OSHA issues PSM citations after Cl2 release (Cl2 & $130K)

On 8/9/21, the flex hose transferring chlorine to the furnace failed, and employees discovered the leak by observing a visible chlorine cloud. An exposed employee was hospitalized as a result of pulmonary edema…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP citations @ plastics manufacturer (37% Formaldehyde & $10K)

On November 6, 2024, authorized EPA representatives conducted a compliance inspection of Respondent’s facility to determine its compliance with the Risk Management Plan (“RMP”) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. EPA found that Respondent had violated regulations implementing Section 112(r) of the Act as noted on the attached…...

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EPA RMP GDC @ paint/coating plant (Temp-sensitive organic peroxide & $196K)

Respondent is the owner and operator of a paint facility. On August 7, 2023, an incident occurred at the Facility that EPA alleges resulted in an accidental release (the “Incident”) of byproducts from a temperature-sensitive organic peroxide, leading to an overpressure release event. EPA conducted an investigation of the Facility beginning September 12, 2023, to…...

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EPA RMP Citations @ Smelter & Refinery (SO2 & $211K)

Respondent is the “owner or operator” of the Facility that uses, handles, and/or stores as much as 7,810 pounds of sulfur dioxide (anhydrous). Respondent’s RMP describes a covered process, furnace off-gas handling, that is subject to Program 3 requirements. On July 25, 2022, and July 26, 2022, authorized representatives of the EPA conducted an inspection…...

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EPA RMP citations @ refrigerated facility (NH3 & $150K)

Respondent is the owner and operator of a facility that utilizes Anhydrous ammonia in a refrigeration process. On or about April 30, 2024, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that…...

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EPA RMP citations @ fruit packing facility (NH3 & $262K)

Respondent operated a facility (the “Facility”) that utilizes anhydrous ammonia to provide cooling capabilities to package, refrigerate, store, and ship cherries and grapes. On September 16, 2021, EPA performed and inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act Section 103, EPCRA Sections 304-312, and CAA Section 112(r)…...

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EPA RMP citations @ a chemical and allied product merchant wholesaler facility (NAOH, HCL, C6H13N & $298K)

Respondent has a chemical and allied product merchant wholesalers process at the Facility, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. 35. Respondent is a wholesale chemical distributor that primarily repackages, stores, and distributes industrial chemical raw materials and allied products. Hydrochloric acid (36%) is an extremely hazardous substance within the…...

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EPA RMP citations @ wet corn milling plant (SO2 & $99K)

Respondent owns and operates a stationary wet corn milling plant, which uses sulfur dioxide (anhydrous) (SO2) to control microbial growth during the corn steeping process and to weaken the starch-gluten bonds. Sulfur dioxide (anhydrous) is a regulated substance. See 40 C.F.R. § 68.130(a), Table 1. The Facility maintains a maximum inventory of the regulated toxic…...

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EPA RMP citations @ Food Facility (a release of 1,024 lbs of NH3 & $46K)

Respondent is the owner and operator of a facility where, on October 10, 2024, there was an incident at the Facility that resulted in an accidental release of NH3. A sanitation team member opened an ammonia valve instead of the valve to drain the marination tank, resulting in the release of 1,024 lbs of anhydrous…...

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EPA RMP Citations @ Power Plant (NH3 & $8K)

Respondent is a power gas-fed generation facility, utilizing Anhydrous Ammonia in its SCR. It shares its ammonia with a neighbor who uses the NH3 in its refrigeration process. (Don’t ask me how I know) ALLEGED VIOLATIONSFollowing its February 5th, 2025, inspection, EPA alleges Respondent’s failure to:… Membership Required You must be a member to access...

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