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.

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  In fact, the EPA guidance documents are also out-of-date with the ERPG-2 level for Ammonia still is being shown as 200 ppm.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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EPA issues RMP citations (NH3 Refrigeration)

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...

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EPA issues RMP citations to two (2) Program Level 2 WWTPs (Chlorine)

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…...

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EPA issues RMP citations to a Program Level 2 Ammonia Plant

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…...

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EPA cites for failing to submit a RMP (NH3 Refrigeration)

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…...

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EPA RMP General Duty Clause citations (NH3 Refrigeration)

Another detailed look into an EPA RMP General Duty Clause citations at an Ice Plant and Cold Storage facility.  The facility was cited $108,000 under the EPA’s RMP GDC that alleged…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Refinery to pay $115K penalty and improve Risk Management Plan (PHA, SOP, MI)

EPA has announced a settlement with a refinery, resolving alleged Clean Air Act violations. The company has agreed to pay civil penalties of $115,000 for violations of risk management program requirements associated with the storage and use of flammable substances and hazardous chemicals. On December 15 and 16, 2011, EPA conducted an inspection of the…...

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OSHA cites a chicken processing and wholesale distribution company with REPEAT and SERIOUS PSM violations (NH3 Refrigeration)

OSHA has cited the company with three repeat and four serious violations following a June inspection as part of the agency’s Process Safety Management Covered Chemical Facilities national emphasis program (NEP). Proposed penalties total $99,000. The repeat citations issued for the process safety management standard violations include failing to inspect and test process equipment consistent…...

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