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 @ Ethanol Plant ($30K)

On May 17,2012, EPA conducted an inspection of an Ethanol plant located in Wyoming to determine compliance with CAA section 112(r)(7). During the EPA inspection, the EPA representatives observed alleged violations of the CAA section 112(r)(7). The alleged violations were:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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OSHA cites foods plant for PSM, LOTO, PRCS, ER (NH3 refrigeration)

OSHA has cited a facility that produces retail frozen pizzas, retail dressings and sauces, and food service dressings and sauces with 27 health and safety violations, including two repeat, for inadequate hazardous energy control procedures after an August 2012 inspection at the company’s facility was opened under OSHA’s Site Specific Targeting Program for industries with high injury…...

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Ethanol Plant receives RMP citations (NH3)

EPA cited an Ethanol plant in NE for RMP deficiencies for the total penalty amount of $3,780, with estimated cost of correcting the deficiencies at $60,000. The covered chemical was Anhydrous Ammonia.  The deficiencies included:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP Citations at food distribution business (NH3 Refrigeration)

A food distribution warehouse in Michigan was cited by EPA for RMP defeciencies.  On September 13, 2010, the facility submitted an RMP for the refrigeration process, which indicated the process is subject to the Program 3 eligibility requirements.  On March 23, 2011, an authorized representative of U.S. EPA conducted a compliance inspection at the facility…...

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OSHA cites manufacturer for 23 serious safety violations, proposes $123,000 in fines (PSM, ER, LOTO, PRCS)

OSHA has cited a manufacturer of roof insulation panels with 23 alleged serious safety violations following an inspection that began in July 2012.  OSHA found several deficiencies in the plant’s process safety management (PSM) program.  The chemical was n-pentane, an organic compound used in the manufacturing process. The cited deficiencies included missing PSI, failing to develop and implement…...

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OSHA cites manufacturer for 23 serious safety violations, proposes $123,000 in fines (PSM, ER, LOTO, PRCS) Read More »

EPA RMP General Duty Clause citations $75,000 (LOPC @ Refinery)

The facility includes a Crude/Vacuum Unit (“CVU”). The CVU stores, handles, treats or otherwise processes a mixture of flammable substances, including methane, ethane, isopentane, propane, butane, isobutene and pentane. The CVU had an 8 inch piping elbow that failed, leading to the release of hot Vacuum Tower bottoms. The piping elbow used in the CVU…...

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CAL-OSHA cites refinery $963,200 (PSM)

Cal-OSHA issued 25 citations against a refinery with proposed penalties totaling $963,200, for state safety standard violations related to the August 6, 2012 fire at the refinery. The citations include eleven “willful serious” and twelve “serious” violations, resulting in the highest penalties in Cal-OSHA’s history. The penalties against the refinery are the highest allowed under…...

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OSHA cites pasta manufacturing plant with 12 safety & PSM violations (NH3 Refrigeration)

OSHA has cited a pasta manufacturing plant with 12 safety and PSM violations following a complaint inspection alleging workers were exposed to ammonia hazards in July 2012 at the plant, which was being retrofitted for use as a pasta production facility. Proposed fines total $54,000. Eight serious violations of OSHA’s PSM standard were cited for…...

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EPA RMP General Duty Clause citations (Storage of acids and International Fire Code)

EPA has cited a “chemical distributor” $3,600 with RMP General Duty Clause citations using the International Fire Code as the RAGAGEP.  EPA took issue with the facility’s storage of nitric acid (Chemical Abstract Services (“CAS”) Number 7697-37-2), sulfuric acid (CAS No. 7664-93-9), and hydrochloric acid (CAS No. 7647-01-0), all of which are extremely hazardous substances (EHS)…...

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EPA RMP citations @ WWTP (Chlorine; $4,129)

On or about May 3, 2011, EPA conducted an inspection of a water treatment plant to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68.  Information collected during the inspection showed the facility exceeded the threshold quantity for chlorine, thus the facility is subject to the requirements of Section 112(r) of…...

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EPA’s RMP* Comp and Ammonia’s ERPG-2

If you are an RMP site and have updated your RMP Submittal in the past couple of years you may have noticed a slight discrepancy in some of the data.  In fact, the EPA guidance documents are also out-of-date with the ERPG-2 level for Ammonia still is being shown as 200 ppm.  I am not…...

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RMP citations @ WWTP

Although the agreement does NOT state the EHS involved, I am going to make a strong assumption that it is Chlorine.  This inspection netted a whopping $980 in fines.  Here are the elements allegedly violated:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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