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 @ Nitrogen plant (NH3, CL2, SO2, & $26K w/ SEP $98K)

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…...

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EPA RMP citations @ Nitrogen plant (NH3, CL2, SO2, & $26K w/ SEP $98K) Read More »

EPA RMP General Duty Clause citations @ chemical packaging facility (Sodium Chlorite chemical reaction & $37,5K)

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…...

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EPA RMP General Duty Clause citations @ chemical packaging facility (Sodium Chlorite chemical reaction & $37,5K) Read More »

EPA RMP, CERCLA, EPCRA citations @ fertilizer distributor after 600 pound NH3 release (NH3 & $34K, w/ $15K SEP)

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…...

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EPA RMP, CERCLA, EPCRA citations @ fertilizer distributor after 600 pound NH3 release (NH3 & $34K, w/ $15K SEP) Read More »

OSHA PSM citations @ frozen seafood distributor (NH3 & $155K w/ Repeats and SVEP)

OSHA began a programmed-targeted inspection on July 23, 2015, under the agency’s Process Safety Management Covered Chemical Facilities National Emphasis Program to reduce or eliminate the release of highly hazardous chemicals. Following the inspection of the plant’s anhydrous ammonia refrigeration system, OSHA issued citations for 11 serious and three repeat violations and also placed the…...

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OSHA PSM citations @ frozen seafood distributor (NH3 & $155K w/ Repeats and SVEP) Read More »

OSHA PSM citations @ frozen food plant (NH3 & $100K, w/ pre-citation settlement agreement)

OSHA returned to a food manufacturing facility and found previously cited hazards had reoccurred, the management of the business took an unusual step and told OSHA the company accepted responsibility for the safety and health hazards and signed a pre-citation settlement agreement with OSHA on Jan. 15.  OSHA cited the business, which manufactures frozen foods sold…...

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OSHA PSM citations @ frozen food plant (NH3 & $100K, w/ pre-citation settlement agreement) Read More »

EPA RMP citations @ food facility (NH3 & $7K)

On June 3-5, 2015, an authorized representative of the EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA…...

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EPA RMP citations @ milk and fruit juice facility (NH3 & $255K, with SEPs $316K)

Respondent owns and operates a controlled temperature production plant for milk and fruit juices. The Facility is located in a predominantly industrial and commercial area, across the street from the Lynn wastewater treatment plant, which also is an RMP facility. The Facility is within a quarter mile of a church, restaurants, other businesses, and freight…...

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EPA RMP citations @ milk and fruit juice facility (NH3 & $255K, with SEPs $316K) Read More »

EPA RMP Citations @ poultry processing facility (NH3 & $8K)

The Respondent is poultry processing business. On April 14-15, 2015, EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA…...

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EPA RMP Citations @ poultry processing facility (NH3 & $8K) Read More »

EPA RMP citations @ food facility (NH3 & $5K)

On July 25, 2014, EPA conducted a compliance inspection to determine its compliance with the Risk Management Plan (“RMP”) regulations promulgated pursuant to Section 112(r) of the Act, and set forth at 40 C.F.R. Part 68. Based on the July 25, 2014 inspection and documents submitted by Respondent, EPA has determined that Respondent violated the…...

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EPA RMP citations @ gas packaging plant (NFPA 4 Flammable Mixture & $55K)

I should point out that this facility was found to be OVER the threshold for 180 days over a three (3) year period.  EPA went through paper work to find times the facility had over 10,000 pounds of a NFPA “4” flammable mixture in their process.  The process involves dissolving acetylene in acetone in order…...

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OSHA PSM citations @ chicken processing facility (NH3 & $154K)

Inspections of the leading supplier of fast food and supermarket chicken processing facilities have resulted in $154,000 in penalties for deficiencies in ammonia refrigeration system. The leading supplier of fast food and supermarket chicken has racked up more than $1.87 million in fines from OSHA this year for exposing workers to multiple safety and health…...

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OSHA PSM citations @ chicken processing facility (NH3 & $308K)

Inspections of the leading supplier of fast food and supermarket chicken processing facilities have resulted in an additional $462,000 in penalties for deficiencies in ammonia refrigeration systems at two of the company’s facilities. The leading supplier of fast food and supermarket chicken has racked up more than $1.87 million in fines from OSHA this year…...

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