PSM NEP ACTIVE — PROGRAMMED INSPECTIONS ONGOING WILLFUL VIOLATIONS: UP TO $156,259 PER INSTANCE — NO CAP ON TOTAL PENALTY EACH VIOLATION INSTANCE IS SEPARATELY PENALIZED PSM NEP ACTIVE — PROGRAMMED INSPECTIONS ONGOING WILLFUL VIOLATIONS: UP TO $156,259 PER INSTANCE — NO CAP ON TOTAL PENALTY EACH VIOLATION INSTANCE IS SEPARATELY PENALIZED
oshapsm.com → Penalty Calculator

PSM Penalty Exposure Calculator

Model your potential penalty exposure across multiple PSM elements. Add violations, adjust parameters, and see total exposure calculated per OSHA's published penalty methodology. This is what a multi-element citation looks like on paper.

Violation Builder
Add PSM violations to model your exposure scenario
Facility Size
Citation History
Applies to all violations below

No violations added yet. Click Add Violation to start building your exposure scenario.

📊 Exposure Summary

Total Estimated Exposure
$0
Across all modeled violations.
Does not include criminal referral risk.
Add violations to see breakdown

Per-Violation Summary

No violations added

These numbers model the penalty structure. The real risk is the inspection finding them first. SafeGuard PSM provides hands-on gap assessment and closure for covered facilities.

Contact SafeGuard PSM → Browse PSM Documents →
How This Works

OSHA's Penalty Methodology

This calculator applies the four-step OSHA penalty methodology from the Field Operations Manual. The math below is what OSHA area directors use when drafting citations.

Step 1 — Violation Type Sets the Ceiling

  • Willful: $15,625 minimum, $156,259 maximum
  • Repeat: same as willful ($156,259 max)
  • Serious: up to $15,625
  • Other-than-Serious: up to $15,625

Penalty tables are adjusted annually by OSHA for inflation. FY2024 figures shown.

Step 2 — Gravity Sets the Base Penalty

  • Gravity 1 (Low): ~10–25% of ceiling
  • Gravity 2 (Moderate): ~25–50% of ceiling
  • Gravity 3 (High): ~50–85% of ceiling
  • Gravity 4 (Critical): 85–100% of ceiling

Most PSM violations are gravity 3 or 4 — the chemical hazards involved are inherently high-consequence.

Step 3 — Reductions Applied

  • Good Faith: up to –25% (no credit for willful)
  • History: up to –10% (no prior citations in 3 years)
  • Employer Size: up to –70% (very small employers)
  • Quick Fix (OTS only): up to –15%

Reductions are not guaranteed. OSHA may decline to apply them based on inspection findings.

Step 4 — Instances Multiply the Result

  • Each separate instance of a violation is cited separately
  • 12 overdue PHA items = 12 separate citations
  • 8 untrained operators = up to 8 separate citations
  • No statutory cap on total penalty amount

Multi-instance citations for high-gravity willful violations have resulted in penalties exceeding $1M at a single facility.