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 Program 2 Citations @ fertilizer facility (NH3 & $15K)

EPA found that Respondent had violated regulations implementing Section 112(r) of the Act at 40 C.F.R. Part 68 by failing to comply with the regulations as noted on the enclosed Risk Management Plan Inspection Findings and Alleged Violations Summary, which is hereby incorporated by reference. In consideration of Respondent’s size of business, its full compliance…...

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EPA RMP citations @ beverage plant (NH3 & $81K)

Respondent operates a beverage production plant with the capacity to produce energy drinks, teas and beer. The production plant uses 160,300 pounds of anhydrous ammonia in its refrigeration system to provide cooling capabilities for its beverage products. On August 22, 2013, the EPA conducted an onsite inspection of Respondent’s RMProgram related records and equipment for…...

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EPA RMP citations @ food plant (NH3 & $133K)

Respondent owns and operates an ammonia refrigeration process, which is an RMProgram level 3 regulated process that stores or otherwise uses 95,000 pounds of anhydrous ammonia for cooling and freezing capabilities for its waffle products. On August 20, 2013, EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of…...

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EPA RMP citations @ fertilizer facility (NH3 & $92K)

Respondent operates a facility that transports and stores anhydrous ammonia and at its stationary source, the Respondent has one RMProgram level 3 covered process, which stores or otherwise uses ammonia in an amount exceeding its applicable threshold of 10,000 pounds. On August 13, 2014, the EPA conducted an onsite inspection of the RMProgram related records…...

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EPA RMP citations @ food oil products manufacturing and distribution facility (NH3 & $43K)

Respondent owns and operates a food oil products manufacturing and distribution facility which is engaged in packaging margarine, liquid oil and shortenings. Respondent operates a closed loop refrigeration system which utilizes or utilized anhydrous ammonia at the Facility. Respondent uses and stores 13,800 lbs. of anhydrous ammonia in the refrigeration system. The Facility is subject…...

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EPA RMP citations @ ice plant and cold storage (NH3 & $49K)

Respondent owns an ice production operation and two refrigerated warehousing storage operations which consist of two separate ammonia closed-loop refrigeration system processes. Both processes have refrigerated and frozen storage space using industry standard mechanical refrigeration designs including multiple cooling coils (evaporators), heat rejection towers (condensers), rotary screw compressors, and ammonia service pressure vessels. At the single…...

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EPA RMP citations @ refinery (HF & $ under negotiations)

On November 1, 2016 through November 4, 2016, representatives from the U.S. Environmental Protection Agency (EPA) Region IX conducted an inspection of a refinery to determine compliance with the Risk Management Program (RMP). The preliminary findings of the inspection and additional information request were sent to the refinery and several agencies on March 27, 2017…....

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OSHA issues PSM Citations @ meat processor (NH3 & $75K)

Violation Summary   Serious Willful Repeat Other Unclass Total Initial Violations 15         15 Current Violations 15         15 Initial Penalty $128,562         $128,562 Current Penalty $75,000         $75,000   Violation Items # ID Type Standard Curr$ Init$ LastEvent 1. 01001 Serious 1910.119(d)Process…...

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EPA RMP GDC citations @ ice plant (NH3 & $40K)

Respondent owns and operates a facility that produces, processes, handles, and/or stores a regulated extremely hazardous substance, anhydrous ammonia. The facility uses anhydrous ammonia in a closed-circuit refrigeration system to produce and store ice. Though the ice maker process runs continually, employees are not normally present at the facility outside of business hours. On March…...

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WA-OSHA Emergency Response Citations @ beverage plant (NH3 & $154K)

Lack of emergency planning for ammonia leaks put workers at a beverage plant in harm’s way three (3) times in the past year. As a result, the Department of Labor & Industries (L&I) has fined the business $154,000 for multiple willful, serious and general workplace safety violations.  In each of the incidents, when the leaks…...

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EPA RMP citations @ pesticide and specialty chemical manufacturing facility (CL2 & $124K)

Respondent owned and operated a pesticide and specialty chemical manufacturing facility located in Louisiana. On January 8, 2014, EPA Region 6 conducted an on-site CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The facility has 11 regulated substances that are held above the threshold quantities identified in 40 C.F.R.§…...

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EPA RMP General Duty citations @ Ethylene Oxide Pilot Plant (EO & $36K)

Respondent owns and operates a facility in Houston, Texas. The Facility processes, handles, and/or stores regulated substances and other extremely hazardous substances, including ethylene and ethylene oxide.  The Facility has a number of laboratory and pilot plant processes, including a Reversible Acid Pretreatment Pilot Plant (RAPT PP) and an Ethylene Oxide Pilot Plant (EOPP). On February…...

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