PSM and RMP Citations/Analysis

On April 18, 2012, EPA conducted a compliance inspection of an Ammonia plant 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 the Act by failing to comply with…...

This is a very interesting case, as it involved an error by the manufacturer of a new vessel and not the facility; however, it was the facility that was cited the $35K!  On March 26, 2012, there was an incident at the facility involving the release of hydrogen gas to ambient air from a newly…...

OSHA has cited a chemical facility with 14 safety violations, including chemical hazards found at the company’s facility. OSHA’s September 2012 inspection was initiated as part of the agency’s National Emphasis Program on process safety management for covered chemical facilities. The inspection resulted in $64,665 in proposed penalties. The serious violations, with a $63,000 penalty,…...

Several times year we upset a client who has hired us to do a “wall-to-wall” compliance audit with their PSM/RMP programs. These audits are our most intense audits in which we leave no rock unturned. One of the items we audit in this level of auditing is the RMP submittal and all of the supporting…...

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…...