PSM and RMP Citations/Analysis

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)…...

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…...

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...

EPA conducted a compliance inspection of Respondent’s facility located in Orem, Utah, and found that the facility had violated regulations implementing section 112(r)(7) of the Act by failing to comply with the specific requirements outlined in the attached RMP Program Level 3 Process Checklist-Alleged Violations. Citations totaled $4,650 and include:… Membership Required You must be...

On May 1 and June 5, 2012, EPA conducted compliance inspections of two (2) Waste Water Treatment facilities located in South Dakota and North Dakota to determine compliance with the Risk Management Plan (RMP) regulations 40 C.F.R. part 68 under section 112(r)(7) of the Act. The EPA found that the facilities had violated regulations implementing…...

On April l8, 2012, an authorized representative of the EPA conducted a compliance inspection of Respondent’s facility in Holyoke, Colorado, 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…...

EPA’s has cited a refrigeration facility $117,000 alleging the facility failed to prepare and submit a risk management plan (“RMP”) for anhydrous ammonia before using it in a process at Respondent’s facility in East Providence, Rhode Island, in an amount that exceeded the regulatory threshold established at 40 C.F.R.  § 68.130, in violation of Section…...