PSM and RMP Citations/Analysis

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…...

OSHA initiated an inspection on Nov. 21, 2014, as a follow-up to its May 30, 2013, inspection. Company received two failure-to-abate notices for hazards for which the employer had been cited previously: not maintaining process equipment and not adequately addressing the potential impact of a vapor cloud explosion on an occupied temporary trailer.  Additionally, OSHA…...

Four workers were killed by a lethal dose of methyl mercaptan gas in November 2014.  OSHA has cited the company for 11 safety violations and identified scores of safety upgrades the company must undertake to prevent future accidents at its manufacturing building. The company employs 313 workers who manufacture crop protection materials and chemicals there.  The…...

An explosion and fire in October 2011 injured 52 workers and this week a provincial court judge sentenced the business to a $200,000 fine and an $80,000 “victims of crime” surcharge.  On 1/22/15, the company pleaded guilty to a charge under the Saskatchewan Occupational Health and Safety Act that the refinery failed to ensure that…...

An ammonia refrigerated food processing facility will pay a civil penalty of $3,000,990 for violations of the Clean Air Act and EPCRA, and $8,865 for violations of CERCLA resulting from a 32,000 pound release of ammonia.  This after OSHA cited the facility for the same release in 2011 for $52,500 for 16 PSM violations.  ALL,…...

Respondent is the operator of an aerosol and non-aerosol product manufacturing and packaging facility. The Facility, including its chemical storage tanks, is located less than 0.1 mile from the nearest neighboring commercial/industrial facility. There are several commercial facilities within a 1,000 foot radius of the Facility. Respondent manufacturers and packages into personal-sized containers a number…...

This is not just another RMP General Duty Clause case.  This case centers around a “critical utility” and how its FAILURE led to the release of a flammable gas and explosion.  And the critical utility was the plant air system and the critical component was air dryer.  The facility had recognized these systems as critical…...

On May 24,2012, EPA conducted a compliance inspection of Respondent’s facility to determine compliance with the Risk Management Program (“RMP”) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. EPA found that the Respondent had violated regulations implementing Section 112(r) of the Act by failing to comply with the regulations. The…...