PSM and RMP Citations/Analysis

EPA inspected a meat plant that has an ammonia refrigeration process that qualified as a Program 3.  This inspection should garner additional attention as this inspection took place VERY SOON after the facility was sold/bought.  The new owner took over on August 29, 2011 and the inspection took place on May 16th and 17th, 2012.  The…...

This is the first time, in a VERY LONG time that I have seen EPA take issue with and issue citations against actual errors in the RMP Submittal data and errors made in the Off-Site Consequences Analysis (OCA).  Unfortunately, EPA does not list the monetary fine with each violation and this inspection apprears to be…...

A paint plant was inspected in 2010 by EPA for compliance with the RMP rule.  The plant uses flammables such as Propane, Butane, Isobutene, and methyl ether in their covered process.  The inspection resulted in the following citations:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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?...

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…...

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...

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…...

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…...

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…...

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…...

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…...

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)…...