Fuller Industries, LLC, operates an aerosol can filling operation using isobutane and/or propane as a propellant. As such, Fuller is required
to comply with the Risk Management Program regulations at 40 CFR Part 68. EPA inspected the facility on October 23, 2019, and found
numerous violations of the risk management program, including failure to review and update the offsite consequence analysis at least once
every five years; failure to include all required steps for each operating phase, operating limits, consequences of deviation, safety and health
considerations, properties and hazards of chemicals in the process, control measures to be taken if exposure to chemicals occurs, quality
control, and special or unique hazards in the written standard operating procedures; failure to establish a mechanical integrity program
consistent with applicable manufacturers' recommendations and good engineering practices, and to conduct nondestructive testing of