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 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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EPA Settles with Fruit Company for RMP Violations (NH3 Refrigeration)

A fruit Company failed to meet risk management requirements under the Clean Air Act, according a settlement with the U.S. Environmental Protection Agency. The plant failed to submit their RMP in 2004 when they exceeded the 10,000-pound threshold for Anhydrous Ammonia, used as a refrigerant at the plant. As part of the settlement, the company will…...

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OSHA issues WILLFULS in PSM and Serious in LOTO, PPE, Electrical, PIT

OSHA has cited a chemical company for 47 violations following a chemical release and proposes $545,000 in fines AND the company was also placed in the Severe Violator Enforcement Program (SVEP). The 47 violations include four willful – violations after an unexpected release of hazardous materials led to the temporary shutdown of the plant and…...

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Unsafe line break into a NH3 line results in three workers hospitalized and more than $55K in fines

Unsafe line break into an Anhydrous Ammonia line results in three workers hospitalized and more than $55,000 in fines – and some valuable lessons for emergency responders. … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA cites 50 safety violations, proposes $917,000 in fines after flammable liquid explosion

My apologies for missing this one back earlier this year!!!  OSHA has cited an adhesives manufacturing facility with 50 alleged violations of workplace safety standards following a March 13 explosion in which four workers were injured. The  faces a total of $917,000 in proposed fines.  OSHA’s inspection identified several serious deficiencies in the company’s PSM program. In…...

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EPA’s RMP General Duty Clause and a challenge to the definition of an EHS

This is an interesting case, with EPA laying claim that although the chemical Toluene is NOT listed as an Extremely Hazardous Substance (EHS) in either the RMP or EPCRA rule it is still an EHS and the Clean Air Act’s RMP General Duty Clause applies to it.  EPA wins this case, but the argument the facility…...

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