PSM and RMP Citations/Analysis

If you ever wondered if the “inventory” in your railcars or tank trucks that are NOT attached to their mode of transportation (i.e. locomotive or tractor) is part of your threshold calculation, here’s your answer, eight railcars of Chlorine sitting on the property was tallied by EPA to establish the amount of the EHS on…...

On September 1, 2010, EPA conducted a compliance inspection at the facility to determine its compliance with the 40 C.F.R. Part 68. 34. Based on the inspection and a review of additional information received by U.S. EPA subsequent to that date, it has identified the following violations by Respondent of the Risk Management Program Regulations:…...

Plant was cited for six process safety management standard violations, including one willful, after an explosion in June killed two workers and injured 80 people. A willful violation was cited for failing to develop clear, written procedures for how to change and put idle pressure vessels into service. The five (5) serious and one (1)…...

OSHA has cited a manufacturer of polystyrene foam core board for willful, repeat and serious safety violations. The business faces a total of $105,490 in proposed penalties following two inspections by OSHA’s Hartford Area Office. The first inspection, begun on May 31, identified several deficiencies in the plant’s process safety management program involving the chemical…...

OSHA has cited an industrial gas manufacturer for 19 serious safety violations following an inspection at its repackaging facility. The inspection began in May under OSHA’s national emphasis program for process safety management for covered chemical facilities. Proposed fines total $49,200. Here is a breakdown of the actual citations:… Membership Required You must be a member...

On July 17, 2013, 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 failing to comply with…...

On January 15 and 16, 2013, 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 failing to…...

OSHA has cited a processor of chicken, beef and pork for repeat and serious violations of workplace safety standards following an inspection at a NY manufacturing plant. The proposed fines total of $121,720. The inspection, which began on May 15, was conducted under OSHA’s Site Specific Targeting Program, which directs enforcement resources to high-hazard workplaces…...

NOTE: this is a GAME CHANGER for the cold storage business!  Now EPA is pulling in the business that is merely leasing space AND the real estate broker who is managing the lease agreement!!  Imagine the shock when a business who is just storing their goods in a cold storage facility receives a NOV from…...

On or about March 30-April 1, 2010, EPA conducted an inspection at one facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. On or about September 27-29, 2010, EPA conducted another inspection of the business but at another facility in a different location to determine compliance with Section 112(r)…...

On October 15, 2012 EPA conducted a compliance inspection of a specialty steel treating business (“Facility”) to determine its compliance with the Risk Management Plan (“RMP”) regulations promulgated pursuant to Section 112(r) of the Act, and set forth at 40 C.F.R. Part 68. Based on the October 15, 2012 inspection and documents submitted by Respondent,…...

WY-OSHA (within the Wyoming Department of Workforce Services (DWS) will cite a refinery with $707,000 in fines for 22 violations found at the company’s Wyoming refinery operation. The violations are the result of a May 2013 OSHA inspection which stemmed from an employee complaint and several gas releases that the refinery voluntarily reported to DWS…...