EPA RMP citations @ chemical processing facility (Flammables & $65K - Car Seal issues)

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Details: Parent Category: Safety Info Posts; Category: PSM and RMP Citations/Analysis; Published: 24 June 2015

Did EPA just issue RMP citations because a facility did not have a Car Seal program? Although they mention Lockout/Tagout in their citation, LOTO is NOT the proper control technique for the "sliding line blind" that was "mistakenly opened by an employee during operation of the unit". LOTO is purely for servicing and maintenance and is not permitted to be used for other purposes (see 1910.147(c)(5)(ii), so a blind that was opened in error during operation of the unit had NOTHING to do with LOTO and everything to do with a car seal program. Here are the details of the incident and the RMP citations:

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