PSM and RMP Citations/Analysis

After two years of litigation to correct dozens of hazards that might have had catastrophic effects on its workers and the surrounding community, the refrigerated food warehouse has agreed to make health and safety improvements. The company will also end its fight against $197,000 in penalties assessed in 2013 by OSHA.  A joint inspection by…...

Respondent operates a “stationary source” that has an RMProgram covered process, ammonia refrigeration, which stores or otherwise uses anhydrous ammonia, in an amount exceeding its applicable threshold of 10,000 pounds.  Respondent has submitted and registered an RMPlan to the EPA for the stationary source. Respondent has developed an RMProgram accidental release prevention program for the…...

OSHA issued 12 PSM citations at a manufacturer of foam, paper and plastic packaging materials. The inspection, which began Sept. 19, 2014, was conducted under OSHA’s National Emphasis Program on chemical facilities and focused on OSHA’s Process Safety Management. The facility had on hand 50,000 pounds of Isobutane, a flammable colorless gas used in the…...

OSHA issued eleven (11) PSM citation at a business that specializes in heat treating powder metal parts. The September 2014 inspection was initiated under the National Emphasis Program for Process Safety Management at chemical facilities.  The process used anhydrous ammonia as a fuel at the metal heat treating facility. Here is a breakdown of the…...

Respondent operates a natural gas processing and fractionation facility. Respondent had maintenance activities performed on the Inlet Filter Separator (“Vessel”) on March 10, 2014 and March 11, 2014.  The Respondent used a contractor to perform the routine maintenance on the vessel, specifically, to replace filters.  The Vessel was flooded with water overnight on March 10,…...

Respondent does business in the Commonwealth of Kentucky and operates a “stationary source”. Respondent has developed an RMProgram accidental release prevention program for the stationary source. The Respondent, at its stationary source has an RMProgram covered process, ammonia refrigeration, which stores or otherwise uses anhydrous ammonia, in an amount exceeding its applicable threshold of 10,000…...

On Sept. 2, 2014, OSHA initiated an inspection of a petroleum refinery after a fire occurred in a heater at the facility, used to process crude oil. The refinery sustained some minor damage but no injuries were reported.  OSHA initiated the investigation under its National Emphasis Program for Process Safety Management at refineries.  Here is…...

The Facility is a “stationary source” within the meaning of Section 112(r)(2)(C) of the CAA and 40 C.F.R. § 68.3.  The Facility has at least two “processes” within the meaning of 40 C.F.R. § 68.3, including a chlorine repackaging process and a chlorine and sulfur dioxide warehousing process.  Chlorine and sulfur dioxide are regulated substances…...

The targeted inspection, which began October 2014, is part of OSHA’s National Emphasis Program on chemicals, and focuses on OSHA’s PSM standard.  The pork-processing facility operates two anhydrous ammonia refrigeration systems. OSHA issued seven serious citations related to the process safety management of the ammonia refrigeration systems used in its production process. Three violations are…...

Respondent is a corporation organized under the laws of the State of Michigan, and is thus a “person” according to section 302(e) of the CAA. At all times relevant to this Complaint, Respondent owned, operated, controlled and supervised a facility which includes buildings, structures, equipment, and installations belonging to the same industrial group, located on…...

Scenario:  Manufacturing is shutdown for long holiday weekend.  Upon their return after the long holiday weekend, the refrigeration techs find the refrigeration process shutdown and they are unable to restart the system for some reason.  They call in their refrigeration contractor who determines that the system is EMPTY – NO NH3!  The facility assumes that…...

An OSHA PSM investigation at a nationwide chemical manufacturer and distributor produced 11 serious violations with penalties totaling $60,500. One of the hazards identified was formaldehyde, which is manufactured for use in various industrial applications and products. The July 16, 2014, inspection found that the facility’s standard operating procedures did not contain accurate information on…...