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 @ Ammonia Manufacturing Facility (NH3 & $70K)

Respondent owned and operated a chemical manufacturing facility that produces anhydrous ammonia at a quantity of approximately 1,500 tons per day. The produced ammonia is used on site for the production of granulated fertilizers. Ammonia (anhydrous) is identified at 40 C.F.R. Part 68.130 as a toxic regulated substance with a threshold quantity of 10,000 pounds. […]

OSHA PSM citations @ Refinery (Line Break Fatality; Flammables; Contractor $62K, Refinery $37K)

OSHA found multiple safety violations at an ethanol refinery expansion project after a 38-year-old pipefitter suffered fatal burn injuries when ethanol spilled from a process pipe he was working on and was ignited by flames from nearby welding operations.  On Nov. 1, 2016, OSHA issued five serious safety violations to the worker’s employer, the project’s

EPA RMP Citations @ LPG Facility ( Propane, Butane, Ethyl Mercaptan & $154K w/ $154K SEP)

Respondent is the owner and operator of a facility which receives and stores liquefied petroleum gas (“LPG”) for wholesale customers. Respondent filed an RMP for the Facility with EPA, which was most recently updated on March 21, 2013 and identified a covered LPG storage process at the Facility subject to Program 3 requirements, with specified

EPA RMP Citations @ Pharmaceutical Facility (Aqueous NH3 & Methylamine Gas; $190K and lowering inventories)

Respondent is the owner and/or operator of a pharmaceutical manufacturing facility which uses ammonia (conc. 20% or greater) (“aqueous ammonia”) and methylamine gas in two (2) processes for the manufacture of pharmaceuticals. EPA conducted an inspection of the Facility on or about January 31 , 2014 to assess compliance with 40 C.F.R. Part 68. Respondent subsequently

EPA RMP Citations @ Fertilizer Facility (NH3 & $16K w/ a SEP of $4K)

Respondent owns and operates the bulk anhydrous ammonia storage facility located in Nebraska. On or about August 18, 2014, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of

OSHA PSM Citations @ chemical plant (Liquified flammable gas & $115K)

As part of the agency’s national emphasis program for chemical facilities, OSHA inspected the company on Feb. 6, 2016, and found multiple violations of federal process safety management regulations, including not developing set written procedures for maintaining process equipment, which resulted in repeat violations.  In addition, OSHA issued citations for serious violations for the following:

EPA RMP Citations @ polyhydric alcohol production process (Flammables & $66K)

Respondent has submitted and registered an RMPlan to the EPA for its stationary source and has developed an RMProgram accidental release prevention program for the stationary source. Respondent operates polyhydric alcohol production process that uses ethylene oxide, propylene oxide, and ethylenediamine in the polyhydric alcohol production process. Respondent has one RMProgram level 3 covered process, polyhydric

EPA RMP Citations @ food plant (NH3 & $121K)

Respondent owns and operates a 210,000 square foot fresh fruits and vegetables processing and cold storage facility. The facility includes one RMProgram regulated closed-looped ammonia refrigeration system. The refrigeration system represents an RMProgram level 3 covered process which currently stores or otherwise uses 27,300 pounds of anhydrous ammonia, in amounts exceeding the applicable threshold of

EPA RMP General Duty Clause citations @ tote recycler/manufacturer (Chemical Reaction & $37K)

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

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