PSM and RMP Citations/Analysis

Respondent operates a facility located in Vermont, where it makes cheese (the “Facility”). The Facility is located in an industrial section of Swanton, Vermont, within approximately 700 feet (0.13 mile) of Route 78, which runs up to the Canadian border, 590 feet (0.11 mile) of the nearest residence, 1,000 feet (0.19 mile) of the Missisqoui…...

OSHA initiated the October 2015 inspection following a report of an ammonia release (apparently during a manual purge of NH3) at the warehousing and logistics company. The agency cited the company for nine serious violations, six for process safety management standards violations, two for not fit testing or providing a medical evaluation of employees before…...

This investigation began after a 9.6 pound vinyl chloride release from an improperly installed rupture disc (RD). The rupture disk had been improperly installed per original design, and its identification tag had been improperly inserted in the rupture disc holder.  Just last night I posted an incident where a “low pressure” vessel catastrophically failed because it did…...

This is an interesting CAFO!  The facility has a 30,000 gallon LPG tank which they use the fuel for heating water to produce steam to cook its product.  The LPG is exempted from Part 68 since it is “used as a fuel”; HOWEVER, EPA pulled out their “General Duty Clause” and cited the facility for the…...

An ice manufacturer using anhydrous ammonia in the plant’s refrigeration system under went an OSHA PSM inspection in September 2015. OSHA’s inspection found that the plant failed to: Document that equipment used in the refrigeration system complied with recognized and generally accepted engineering practices. Conduct a pre-startup safety review following modifications to the refrigeration system…....

Respondent is a company doing business as a cold storage facility. The Respondent has an RMProgram covered process, ammonia refrigeration, which stores or otherwise uses ammonia, in an amount exceeding its applicable threshold of 10,000 pounds. Based on an RMProgram compliance monitoring investigation initiated on October 29, 2013, the EPA alleges that the Respondent violated…...

A “temporary clamp” that was four (4) years old led to an HF Leak which initiated the OSHA inspection.  The leak was related to a temporary clamp that was installed on a three-inch nozzle flange following an earlier leak in 2011.  The nozzle was not replaced until January, 2016.   The three citations include one willful-serious, indicating the…...

Another OSHA PSM citation with some interesting citations. In this one, the company: was using Global FM Engineering Data Sheets as their RAGAGEP(s) for Rupture Disk sizing and Fire Protection, but failed to list these data sheets in their PSI as officially adopted RAGAGEPs. had multiple pieces of equipment on the system that were not…...

OSHA initiated an inspection on Aug. 4, 2015, under its national emphasis program focused on chemical manufacturers. Inspectors found deficiencies in the employer’s equipment process safety information, process hazard analysis, written operating procedures, contractor safety, equipment inspection and testing along with management of process changes, resulting in the citations. PLEASE NOTE: this OSHA inspection cited…...

Respondent has five RMProgram covered processes. The letdown area process, the urea process, and the high pressure solutions process store or otherwise use ammonia in an amount exceeding its applicable threshold of 10,000 pounds; the chlorine addition process stores or otherwise uses chlorine in an amount exceeding its applicable threshold of 2,500 pounds; and the…...

Respondent is a corporation authorized to do business in the State of Texas. Respondent owns and operates a chemical building, manufacturing, and packaging facility. Respondent receives bulk raw chemicals, including liquid sodium chlorite, delivered in tanker, railcar, and packaged containers. Respondent uses these raw ingredients to produce finished products. Liquid sodium chlorite is an extremely…...

Respondent is a fertilizer distributor engaged in the business of selling anhydrous ammonia to farmers as fertilizer. Anhydrous ammonia is classified as a physical or health hazard, and a simple asphyxiant and therefore is an “extremely hazardous substance” according to Section 302(a)(2) of EPCRA. The Respondent stores more than 10,000 lbs. of anhydrous ammonia at…...