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 @ utilities plant (NH3 & $37,500)

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…...

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EPA RMP Citations @ global technology and specialty materials company (Vinyl Acetate & $18,750 w/ $70,312 SEP)

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,…...

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EPA RMP General Duty Clause citations @ chemical plant (Toluene & $37K)

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…...

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EPA RMP General Duty Clause @ refinery (Temporary Change leads to discharge & $50K)

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…...

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OSHA PSM citations @ potato processor (NH3 & $273K)

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…...

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EPA RMP Program 2 citations @ fertilizer and fuel distributor (NH3 & $48K)

Respondent is the owner and operator of an ammonia and fuel retail business. On or about June 12, 2014 EPA inspected the facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. At the time of the 2014 inspection, Respondent had greater than 10,000 pounds of anhydrous ammonia stored in…...

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EPA RMP General Duty Clause Citations @ chemical plant (Cyclohexane & $30K)

Respondent is a limited liability company which owns a chemical plant where regulated substances and other extremely hazardous substances are produced, processed, stored, and handled, and from which an accidental release occured. Within the facility, the Respondent produces nylon intermediates (adiponitrile (ADN), hexamethylene diamine (HMC), adipic acid, C12, and C12 co-products). On May 9, 2015,…...

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EPA RMP General Duty Clause Citations @ food facility (NH3 & $39K)

Respondent is a Dairy Company that was incorporated in the Commonwealth of Pennsylvania in 1921. Respondent has owned and operated the fluid milk manufacturing facility since 1973.  Respondent uses anhydrous ammonia for refrigeration of raw milk, juice concentrate, and product storage…. Membership Required You must be a member to access this content.View Membership LevelsAlready a...

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EPA RMP Citations @ Water Treatment Facility (CL2 & $20K, with $200K SEP)

Respondent is the owner and/or operator of a public water treatment facility that uses chlorine in its water treatment process. The amount of chlorine on hand at the facility is up to 9,000 pounds. At all times relevant to this Consent Agreement and Final Order (CAFO), Respondent produced, processed, handled or stored chlorine at its…...

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OSHA PSM citations @ cold storage warehouse (NH3 & $42K)

OSHA has issued nine serious and two other-than-serious violations to a refrigeration warehouse after a January 2016 complaint investigation found the employer violated OSHA’s process safety management standard in regards to the anhydrous ammonia used in the facility’s refrigeration process where more than 10,000 pounds of ammonia are in use. An investigation by the agency’s…...

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OSHA PSM citations @ Ethanol Plant (Flammables & $80K)

On May 6, OSHA issued 42 serious and four other-than serious safety and health violations following three separate inspections at the bio-refinery in November 2015.  Inspectors found the ethanol production facility violated OSHA’s process safety management regulations including failing to: Develop written procedures for safely conducting tasks in the process, and for maintaining the ongoing…...

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OSHA PSM citations @ foodservice distributor (NH3 & $72K)

Responding to a complaint from employees at a facility operated by the fourth largest foodservice distributor in the U.S., OSHA found that a check valve in the food plant’s pump room leaked about 9 pounds of anhydrous ammonia on Oct. 21, 2015. Inspectors also found the ammonia sensor in the pump room did not sound…...

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