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 @ food facility (NH3 & $6K)

On March 24-25, 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 by […]

EPA RMP Program 2 Citations @ fertilizer facility (NH3 & $3K)

On March 19, 2015, EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA by failing to comply with the regulations as noted on the enclosed Risk Management Program Inspection Findings

EPA RMP Citations @ synthetic rubber facility (Anhydrous ammonia, 1, 3-butadiene, and acrylonitrile & $8K w/ $33K SEP)

Respondent owns and operates a facility that produces synthetic rubber, styrene butadiene rubber (SBR), using a hot emulsion polymerization process. Anhydrous ammonia, 1, 3-butadiene, and acrylonitrile are each a “regulated substance” as set forth in 40 C.F.R. § 68.130. Respondent has the following processes at the stationary source:

EPA RMP Citations @ controlled temperature laboratory (NH3 & $85K)

GENERAL ALLEGATIONS Respondent operates a controlled temperature laboratory, where it conducts research on the effect of cold temperatures on equipment, structures and technological systems, at its Cold Regions Research and Engineering Laboratory.  The Facility is located approximately two miles north of the center of Hanover, New Hampshire. The 30-acre site is bordered on the north

EPA RMP General Duty Citations @ disposal facility (Flammables, Hotwork & $37,500)

Respondent owns and operates a disposal facility associated process equipment.  At the facility the Respondent stored produced water, including residual hydrocarbons, in a 500-barrel fiberglass tank. Produced water stored in this tank was generated from multiple wells. Produced waters, and their associated vapors, are extremely hazardous substances due to their flammability and explosive nature. On

EPA RMP citations @ aluminum chloride manufacturing facility (Chlorine & $33,150)

Respondent is the owner and/or operator of a facility which operates as an aluminum chloride manufacturing Facility.  On December 3, 2013, EPA conducted an inspection at the Facility to determine, among other things, Respondent’s compliance with Section 112(r) of the CAA. The Inspection included discussions with Facility representatives concerning the Facility’s covered process and risk

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