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 @ water treatment plant(s) (Cl2 & $39K)

Respondent operates water filtration plants which store or otherwise use chlorine in an amount exceeding its applicable thresholds of 2,500 pounds. Respondent has submitted and registered an RMPlan to the EPA for these stationary sources and has developed an RMProgram (accident release prevention program) for these stationary sources. Based on an RMProgram compliance monitoring investigation…...

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EPA RMP Citations @ a WWTP (CL2; $51,700 and SEPs $77K)

Respondent is a Water Works Department (HWWD or Respondent), a municipal owned utility organized under the laws of the State of Indiana. Beginning prior to 1999 Respondent used, stored, handled, and moved, multiple one ton containers of the regulated substance chlorine at the Facility in amounts over the chlorine threshold quantity of 2,500 pounds per…...

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EPA RMP Citations @ a paper mill (CL2 and ClO2; $54K)

The Respondent has three RMProgram covered processes, one chlorine dioxide process, which stores or otherwise uses chlorine dioxide in an amount exceeding its applicable threshold of 1,000 pounds, and two chlorine processes, which store or otherwise uses chlorine in amounts exceeding its applicable threshold of 2,500 pounds. Based on an RMProgram compliance monitoring investigation initiated…...

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OSHA PSM citations @ aerosol paint and coatings manufacturer (Flammables & $132,800)

A May 1, 2014, inspection conducted after a complaint alleging three separate fires has resulted in the issuance of eight safety violations. Many of the violations were cited under the Process Safety Management Standard. OSHA cited one willful, two repeat and five serious safety violations and proposed penalties totaling $132,800. OSHA issued one willful violation…...

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OSHA PSM citations @ BPA Plant (BPA & $134,000)

Following the death of an employee, 61, OSHA has cited the chemical manufacturer for 21 serious and two other-than-serious safety violations. Many of the violations involve OSHA’s Process Safety Management Standards. The company has been placed in OSHA’s Severe Violator Enforcement Program. OSHA’s investigation found the employee suffered fatal injuries on April 4, 2014, while…...

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EPA RMP Citations @ a propane wholesale distributor (LPG; $21K)

Respondent is the owner and/or operator of a facility which stores liquid propane (“LP”) for wholesale distribution. Respondent filed an RMP for the Facility with EPA on or about October 18, 2013 that identified a covered propane process at the Facility as a Program 3 process, and that specified a quantity of 822,500 pounds of…...

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EPA RMP Citations @ a cheese plant (NH3; $88K)

Respondent has a Program 3 covered process, as defined in 40 C.F.R. § 68.1O(d), using Anhydrous ammonia. 40 C.F.R. § 68.12(a) and (d) require that, in addition to submitting a single RMP as provided in §§ 68.150 to 68.185, facilities with a Program 3 covered process shall among other things, develop a management system as…...

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EPA RMP Citations @ a chemical manufacturing, warehouse, and distribution facility (NH3, CL2, GDC; $114K)

This CAFO resolves the following CAA violations that Complainant alleges occurred in conjunction with Respondent’s storage and handling of hazardous substances at its facility: Failure to prepare and submit a Risk Management Plan that includes all covered processes, in violation of 40 C.F.R. §68.12(a) and 68.150(a); Failure to comply with process safety information requirements, including…...

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EPA RMP Citations @ a chemical manufacturing, warehouse, and distribution facility (NH3, CL2, GDC; $114K) Read More »

EPA RMP Citations @ a dairy processing plant (NH3; $7,500)

On December 3, 2013, EPA conducted a compliance inspection of 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)(7) of the Act. The EPA found that the Respondent had violated regulations implementing section 112(r)(7) of the Act by failing to comply with the…...

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EPA RMP Citations @ a pharmaceutical manufacturing and Research & Development facility (Chloroform; $172K)

EPA contacted the facility by letter in January 2014 to determine the facility’s compliance with RMP.  Based on communications with the facility, EPA determined that the facility exceeded the threshold for chloroform on 2/17/2010; however, the facility submitted their RMP with EPA on 4/14/2014.  The fine was $172,900 for a violation of 68.12 and 68.150…...

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EPA RMP Citations @ a dairy processing plant (NH3; $57K)

EPA contacted the facility by letter in January 2014 to determine the facility’s compliance with RMP.  Based on communications with the facility, EPA determined that the facility had more than 10,000 pounds of Anhydrous Ammonia in a process; however, the facility had not filed an RMP with EPA.  The fine was $57,000 for a violation…...

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OSHA PSM citations @ Ice Maker (NH3 refrigeration & $274,700)

Inadequate safeguards to protect workers against potential ammonia releases at an ice plant have resulted in $264,700 in fines at a nationwide ice manufacturer and distributor. This inspection was conducted under OSHA’s PSM Covered Chemical Facilities National Emphasis Program. OSHA cited the company for 19 violations of workplace safety standards following a comprehensive inspection that…...

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