PSM and RMP Citations/Analysis

A pharmaceutical manufacturing facility has been cited for 23 safety and health violations-including seven willful, one repeat and 15 serious. The company has been placed in OSHA’s Severe Violator Enforcement Program, and the citations carry proposed penalties of $449,680. OSHA initiated an inspection in December 2013 after the company failed to fix hazards following an…...

According to the RMP submitted to U.S. EPA, the Facility fell within NAICS Code 48699, as “all other pipeline transportation”, used ethyl mercaptan and other flammable mixtures as process chemicals during its operations and held at least 10,000 lbs. of ethyl mercaptan and other flammable mixtures. Respondent was required to meet Program 3 eligibility requirements at…...

A cheese manufacturing facility stores and uses anhydrous ammonia in its production process and the facility had present at the facility anhydrous ammonia in quantities exceeding 10,000 pounds during calendar years 1999 through 2011. On September 14, 2010, Respondent’s Risk Management Program, prepared pursuant to 40 C.F.R. § 68.12(d), failed to implement mandatory elements required…...

OSHA has cited a paper mill for failing to protect workers from hazards associated with exposure to sulfur dioxide. SO2 is used in treating wood pulp for paper manufacturing and can cause numerous adverse effects to the respiratory tract when vapors are inhaled. OSHA cited eight violations, carrying proposed penalties of $42,300. OSHA opened the…...

EPA alleged that each facility failed to comply with Section 112(r)(1) of the CAA (the “General Duty Clause”) in its handling of anhydrous ammonia at four (4) cold storage warehouses. Specifically, with respect to the General Duty Clause, the four Complaints alleged that each facility failed to: identify hazards which may result from accidental releases…...

On July 27, 2011, U.S. EPA conducted a compliance inspection at the facility to determine Respondent’s compliance with the Risk Management Program regulations. Based on the inspection, U.S. EPA alleges that Respondent has committed the following violations of the Risk Management Program regulations:… Membership Required You must be a member to access this content.View Membership...

Respondent is a producer of made-to-order frozen gourmet Italian entrees. The Facility uses anhydrous ammonia in its refrigeration process to cool the ingredients cooler and product freezers. Anhydrous ammonia is included on the List of Regulated Substances and Thresholds for Accidental Release Prevention requirements under Section 112(r) of the Clean Air Act. At approximately 1:40…...

Respondent owns and operates a refrigeration system which consists of buildings, equipment, structures, and other stationary items which are located on a single site or on contiguous or adjacent sites, and which are owned or operated by the same person. On June 21, 2004, under Section 112(r) of the Act and implementing regulations at 40…...

Respondent owns and operates a fungicides, herbicides, and insecticides production facility which consists of buildings, equipment, structures, and other stationary items which are located on a single site or on contiguous or adjacent sites, and which are owned or operated by the same person. On November 1, 2004, under Section 112(r) of the Act, and…...

The Wyoming Department of Workforce Services (DWS) (WY-OSHA) has cited a refinery for seven (7) violations stemming from a September 2013 incident. An OSHA inspection following the September 27, 2013 explosion and subsequent fire resulted in seven citations and proposed penalties totaling $201,000. No injuries occurred as a result of the incident. WY-OSHA monetary penalties…...

The Respondent, at its stationary source, has one RMProgram covered process which stores or otherwise uses ammonia in amounts 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 stationary source. Based on…...

EPA alleges that Respondent has violated EPCRA Section 312 and the federal regulations promulgated pursuant to EPCRA; and Section 112(r) of the CAA. On or about February 12-13, 2013, EPA conducted an inspection of Respondent’s facility to determine compliance with EPCRA and Section 112(r) of the CAA. Respondent stores approximately 924,000 pounds of natural gasoline…...