PSM and RMP Citations/Analysis

The respondent produces, processes, stores, and/or handles extremely hazardous substances, including hydrochloric acid (36%), due to its toxic and corrosive characteristics and propensity to volatilize in ambient air.  On July 25, 2014, there was a release of hydrochloric acid (36%) at the Facility.  An operator while on his normal rounds gauging the Boiler I house…...

On Jan. 20, a pressure-relief device released flammable gas and liquid into the atmosphere; it burned for more than two hours. OSHA investigated the facility and cited the employer for one willful and six serious safety violations. The violations included failing to train operators, update operating procedures, conduct a management of change analysis when changing…...

Respondent owns and operates a Power Plant (“Facility”) which produces processes, handles, or stores, among other things, hydrogen peroxide, which is an extremely hazardous substance when stored in a carbon steel tank and produces hydrogen, a regulated substance, when reacting with carbon steel.  On July 25, 2014, there was an incident in which a tank…...

On July 22, OSHA issued eight serious safety citations from an inspection that was NOT initiated as a PSM inspection, but after determining that the company was using flammable liquids above the threshold quantities that could present a potential for a catastrophic event. Business was cited for not implementing five elements of the PSM standard,…...

UPDATED/CORRECTED on 9/14/15.  Many thanks to Chris Kim Kahn, Attorney at Law @ Frost Brown Todd LLC for her assistance in correct this posting. Respondent owns and operates a controlled-temperature storage warehouse for food products.  The Facility is located on the banks of the Connecticut River, within a quarter mile of residences and other businesses,…...

Respondent operates a silicon wafer manufacturing facility. Respondent has a HCL tube trailer and gas supply system process at the stationary source and has exceeded the threshold quantity for Hydrogen Chloride (anhydrous) [Hydrochloric Acid] at the HCL tube trailer and gas su11ply system. The covered process is subject to the Program 3 requirements of the…...

Facility a petroleum refinery where regulated Substances and other extremely hazardous substances are produced, processed, stored, and handled, and from which an accidental release could occur.  On July 23, 2014, a fire occurred at the control valve station on Pass #3 to Vacuum Tower Heater H-1-1601 while facility operators were isolating flow control valve 02FC23…...

A refrigeration warehousing company, which refrigerates various food products and citrus extract/oils and employs approximately 200 workers was cited for 13 safety violations, including one willful violation, for failing to follow the industry recognized and generally accepted good engineering practices for insulation removal and for failing to test the ammonia refrigeration system piping and pressure…...

In November 2014, a worker was overcome at the chemical manufacturing facility when a supply line unexpectedly released more than 20,000 lbs. of methyl mercaptan, a deadly chemical. Three co-workers came to the worker’s aid in an attempted rescue, but all four were asphyxiated fatally by the colorless, flammable, and highly toxic gas. After the…...

At the facility, the respondent primarily engages in the production of oil and gas from underground reservoirs. The operation at the Facility includes various piping, heater treaters, and a high-low pressure separator vessel used for separating well fluids into gaseous and liquid components.  Natural gas is a highly flammable gaseous hydrocarbon mixture containing methane, ethane,…...

OSHA initiated a PSM inspection under the agency’s Site Specific Targeting program for industries with high injury and illness rates and its Process Safety Managed Covered Chemical Facilities National Emphasis Program. Eight of the 15 serious violations are related to the Process Safety Management Program for the maintenance and operation of the Anhydrous Ammonia refrigerant…...

Did EPA just issue RMP citations because a facility did not have a Car Seal program?  Although they mention Lockout/Tagout in their citation, LOTO is NOT the proper control technique for the “sliding line blind” that was “mistakenly opened by an employee during operation of the unit“.  LOTO is purely for servicing and maintenance and…...