EPA Cracks Down on Chemical Safety Violations in California
Definitely a Wake-Up Call for Better RMP Compliance
On April 22, 2025, the U.S. Environmental Protection Agency (EPA) announced settlements with ten California facilities, including organicgirl, LLC, for violations of the Clean Air Act’s Risk Management Program (RMP). These enforcement actions, resulting in over $170,000 in penalties, underscore the EPA’s unwavering commitment to ensuring chemical safety and protecting communities from the risks of hazardous substances like anhydrous ammonia. While some violations might appear as minor administrative oversights, they reveal the EPA’s rigorous approach to RMP compliance and serve as a critical reminder for facilities to prioritize robust safety management.
A Closer Look at the EPA’s Enforcement Actions
The EPA’s Pacific Southwest Region targeted facilities across California for failing to meet RMP requirements, which are designed to prevent accidental releases of toxic chemicals and mitigate their impacts. The settlements addressed a range of deficiencies, with organicgirl, LLC facing the heftiest penalty of $151,979. The EPA cited organicgirl for issues including:
Failure to address safety recommendations promptly, increasing the risk of chemical accidents.
Inadequate operation and maintenance programs, with corrosion in refrigeration systems and deficient emergency ventilation posing significant safety hazards.
Insufficient documentation, lacking proof that systems were designed to prevent releases of anhydrous ammonia, a highly flammable and toxic substance.
Other facilities faced similar violations, though specifics vary. Each agreed to pay penalties and implement corrective actions to align with RMP regulations. These actions include updating safety protocols, improving equipment maintenance, and ensuring proper documentation…. steps that are non-negotiable under the Clean Air Act’s Section 112(r).
Note: What might seem like a paperwork error, such as inadequate documentation, can have far-reaching consequences. The EPA’s focus on these details highlights how seriously it takes RMP compliance. A single oversight could compromise a facility’s ability to prevent or respond to a chemical release, endangering workers and nearby communities.
Why the EPA’s RMP Program Matters
The RMP, established under the Clean Air Act, requires facilities handling more than a threshold quantity of regulated substances--like anhydrous ammonia--to develop and implement risk management plans. These plans must identify potential chemical accident risks, outline prevention strategies, and detail emergency response procedures. The EPA estimates that accidental releases from RMP-regulated facilities cost society over $540 million annually, with 131 million people living within three miles of such sites.
Anhydrous ammonia, commonly used in refrigeration systems, is a prime example of a regulated substance with severe risks. Exposure can cause irreversible health effects, including respiratory damage and skin burns, while its flammability heightens the potential for catastrophic accidents. The EPA’s enforcement actions aim to reduce these risks, particularly in vulnerable communities near industrial facilities.
Note: The EPA’s penalties, even for seemingly minor violations like missing documentation, reflect the high stakes of RMP compliance. Facilities must maintain meticulous records to demonstrate safe operations, as these records are critical for emergency responders and regulators to assess risks and protect public health.
The EPA’s Broader Commitment to Chemical Safety
These settlements are part of the EPA’s National Enforcement and Compliance Initiative to reduce accidental releases at industrial and chemical facilities. Historically, about 150 catastrophic accidents occur annually at ammonia refrigeration facilities, resulting in fatalities, injuries, evacuations, and environmental harm. The EPA’s Pacific Southwest Regional Administrator, Josh F.W. Cook, emphasized that “reducing risks from accidental releases of toxic substances is a core responsibility for EPA.”
The agency’s approach combines inspections, penalties, and corrective mandates to drive compliance. For instance, organicgirl and other facilities were required to address equipment deficiencies, enhance safety protocols, and pay fines that reflect the severity of their violations. These actions align with recent EPA rule changes, such as the 2024 “Safer Communities by Chemical Accident Prevention Rule,” which introduced stricter safety standards and transparency measures for high-risk facilities.
Note: The EPA’s proactive enforcement, even for administrative errors, sends a clear message: compliance is not optional. Facilities must invest in robust safety systems and documentation to avoid penalties and, more importantly, to safeguard workers and communities from preventable disasters.
The Close Connection Between RMP and PSM
The EPA’s RMP requirements work hand-in-hand with OSHA’s Process Safety Management (PSM) standard, both aimed at preventing chemical accidents but with complementary focuses. While RMP protects communities and the environment from off-site impacts of hazardous substance releases, PSM ensures process and workplace safety by addressing on-site risks to workers. Despite their different scopes, the two programs share core elements, such as hazard assessments, safe operating procedures, equipment maintenance, and employee training.
For facilities like organicgirl, handling substances like anhydrous ammonia often triggers both RMP and PSM requirements, creating opportunities for integrated safety management. A robust PSM program--addressing process design, maintenance, proper operations, and emergency preparedness--directly supports RMP compliance by reducing the likelihood of releases that could harm nearby communities. Conversely, RMP’s emphasis on community notification and emergency response strengthens workplace safety by ensuring coordination with external responders.
Note: Administrative oversights, like those cited in the EPA’s settlements, often signal weaknesses in both RMP and PSM compliance. The close tie between these programs underscores why the EPA views even minor errors as serious… they can reflect broader failures in process safety that endanger workers and the public.
Lessons for Facilities… The Importance of RMP Compliance
The EPA’s enforcement actions serve as a wake-up call for facilities nationwide. Achieving and maintaining RMP compliance is not just about avoiding fines--it’s about protecting workers, communities, and the environment.
I’ve been saying for years, if you have a good PSM program in place, you’ll ultimately keep it in the pipe, which keeps people safe, and reduces excess emission events.
As such, facilities must:
Regularly audit safety systems, equipment, and documentation to meet RMP standards, with input from compliance teams to verify regulatory alignment.
Address safety recommendations promptly, as delays, like those in organicgirl’s case, can lead to severe penalties and heightened risks. Engineers should collaborate with maintenance teams to prioritize and implement upgrades efficiently.
Emphasize synergies between maintenance, compliance, operations, and engineers by creating integrated workflows. Maintenance teams should work closely with engineers to ensure equipment reliability, while operations staff coordinate with the compliance folks to align procedures with RMP requirements. This collaboration ensures safety systems are designed, maintained, and operated cohesively, reducing the risk of oversights like corrosion or inadequate ventilation.
Train employees thoroughly, providing cross-functional training for maintenance, operations, and engineering staff on safe operating procedures and RMP protocols to enhance accountability and awareness.
Engage with regulators proactively, involving compliance and engineering teams to align plans and resources with the EPA and local emergency responders.
Note: Administrative errors, like failing to update a risk management plan or document safety measures, are not trivial in the EPA’s eyes. These oversights can undermine a facility’s ability to prevent or respond to chemical accidents, making cross-departmental collaboration and compliance a non-negotiable priority.
A Call to Action
The EPA’s settlements with these ten California facilities highlight its relentless focus on chemical safety and RMP compliance. While penalties like organicgirl’s $151,979 grab headlines, the real story is the agency’s commitment to preventing accidents that could devastate communities. Facilities must heed this warning: invest in safety, prioritize compliance, and treat every detail--from documentation to equipment maintenance--as critical to their operations.
For readers in industries handling hazardous substances, now is the time to review your RMP protocols. Engage with EPA resources, such as the agency’s enforcement reporting website, to stay informed and compliant. The cost of non-compliance, both in fines and potential harm, is far too high to ignore.
Final Note: The EPA’s enforcement actions remind us that no violation is too small when it comes to chemical safety. Achieving and maintaining RMP compliance is a continuous responsibility that protects lives, livelihoods, and the environment. Let these settlements be a catalyst for renewed commitment to safety across all regulated facilities.
Source: EPA website and compliance enforcement data.