PSM and RMP Citations/Analysis

Respondent owns and operates a container molding facility where it manufactures and recycles high density polyethylene containers ranging in size from fifty-five to 330 gallons (“containers”). The larger containers are encased in a steel cage for extra support. As part of its recycling operations, the Facility accepts used containers which routinely contain small amounts of…...

Respondent operates a meat processing facility that uses 24,300 pounds of ammonia as its refrigerant. Respondent has one RMProgram level 3 covered process, an ammonia refrigeration process, which stores or otherwise uses a toxic chemical in an amount exceeding its applicable threshold of 10,000. During calendar year 2014, EPA opened an RMProgram compliance monitoring investigation…...

Respondent owns and operates a chemical manufacturing facility that has an Acrylonitrile Manufacturing process. On or about December 1-3, 2015, an EPA inspector conducted an inspection of Respondent’s facility.  A contractor was removing a six-inch blind and installing four-inch and three quarters inch blinds to prepare the Heads Column in the Acrylonitrile Unit for caustic cleaning. The…...

Respondent owned and operated a refinery. On March 31-April3, 2014, EPA Region 6 conducted an unannounced, onsite CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The refinery submitted a single RMP with covered processes that are subject to Program 3 requirements. The regulated flammable substances that are above the threshold…...

A food additive manufacturer’s failure to handle hazardous materials and respond properly to an emergency led to an explosion that injured four workers, including two contractors who scaled an 8-foot security fence topped with triple-strand barbed wire to escape the fireball.  An OSHA investigation found the business violated process safety management procedures for the handling…...

July 7, 2016 UPDATE – Company is Contesting all citations OSHA has issued nine serious safety violations to a food industry provider of cold storage warehousing and logistical services. A January 2016 complaint investigation found the company violated OSHA’s process safety management procedures for using ammonia in its refrigeration warehouse facility. An investigation by the…...

Respondent owned and operated the a chemical manufacturing facility. On September 8-11, 2014, EPA Region 6 conducted an unannounced, onsite CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The faility’s RMP lists three covered processes subject to Program 3 requirements. The regulated flammable substances that are held above the…...

Respondent owns a Utilities Plant that maintains the support of steam, refrigeration, compressed air, cooling and process water; wastewater treatment, electricity, and natural gas for a chemical manufacturing complex. The Utilities Plant includes methanol storage and ammonia storage tank operations and distribution systems. Respondent produces, processes, stores, or handles up to a maximum of 51,180,000 pounds…...

Respondent owns and operates a global technology and specialty materials company operating in the production of vinyl acetate. Respondent operates the Facility in part to produce vinyl acetate in a reactor process. Vinyl acetate is identified at 40 C.F.R. Part 68.130 as a toxic regulated substance with a threshold quantity of 15,000 pounds. Respondent produces, stores,…...

Respondent owned and operated a chemical plant where regulated substances and other extremely hazardous substances are produced, processed, stored, and handled, and from which an accidental release could occur. Within the Facility, at the time of the incidents described herein, Respondent used and produced butadiene, chlorine, pentane, sodium hydroxide, hydrochloric acid, toluene, 1 ,4-dichloro-2-butene, 3,4-dichloro-1…...

NOTE: This case is important as it is based on the simple fact that the facility did not follow it’s own internal procedures regarding changes and construction. This incident also occurred via a “TEMPORARY CHANGE” where the MOC called for a check-valve, the spec’s called for a check-valve; yet a check-valve was NOT installed. This…...

OSHA found an Idaho frozen food manufacturer failed to safeguard employees and was unprepared to respond to a release of 1,300 lbs. of anhydrous ammonia on Dec. 1, 2015. While no one suffered an injury in the December incident, other major ammonia releases at the facility have hospitalized employees in the past. In its review…...