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 RMP citations @ Natural Gas Processing Plant (Flammables & $42K)

The process at the Facility involves the separation of propane, butane, ethane and isobutane from the incoming natural gas using compressors and a process skid. The separated gases are stored together in a 10,000-gallon storage tank, which when full weighs 67,000 pounds, for transportation off-site.  The National Fire Protection Administration’s Code 58, Liquefied Petroleum Gas Code,

EPA RMP citations @ Motor Vehicle Parts and Accessories Plant ($119K toluene 2,4 diisocyanate and toluene 2,6 diisocyanate)

This was a Program 2 Inspection and the facility had toluene 2,4 diisocyanate and toluene 2,6 diisocyanate in quantities exceeding 10,000 pounds during calendar years 1999 through 2010. Respondent thus maintained toxic substances in quantities exceeding the threshold quantities under the Chemical Accident Pollution Prevention rule. At and prior to the time of inspection the

EPA RMP citations @ Food Plant (NH3 & $4K)

On December 14,201 1, EPA conducted a compliance inspection of Respondent’s facility 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 the

EPA RMP citations @ Ethanol Plant (NH3 and $4K)

On June 27, 2012, an authorized representative of the EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.P.R. Part 68 under Section 112(r) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA

OSHA has cited a refinery with repeat, serious and o-t-s violations (PSM $281K)

OSHA has cited a refinery with repeat, serious and other-than-serious violations following the death of two workers at the crude oil refinery. OSHA began its investigation 9/12/2012 following the explosion of a boiler, which killed the employees. The inspection was expanded to include associated contractors and ongoing maintenance activities during a turnaround operation. We need

EPA RMP Program 2 Citations $5,400 (NH3 Plant)

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

EPA RMP General Duty Clause citations $35,000 (release of H2 from a improperly installed gasket by the manufacturer of vessel – NOT the facility)

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 (PSM NEP $63K)

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,

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