PSM NEP ACTIVE — PROGRAMMED INSPECTIONS ONGOING WILLFUL VIOLATIONS: UP TO $156,259 PER INSTANCE PSM NEP ACTIVE — PROGRAMMED INSPECTIONS ONGOING WILLFUL VIOLATIONS: UP TO $156,259 PER INSTANCE
oshapsm.com → Most Cited PSM Elements

Most Cited PSM Elements

Two elements account for more than 40% of all PSM penalty dollars assessed. Knowing what inspectors find most often tells you where your program is most exposed.

Citation Frequency Ranking

The 14 PSM Elements — Ranked by Citation Volume

Based on OSHA PSM enforcement data across multiple inspection cycles. Elements ranked by percentage of total citations issued. Two elements — PHA and Mechanical Integrity — account for more than 40% of all PSM penalty dollars assessed.

1
Process Hazard Analysis
§1910.119(e) — Most Cited PSM Element
~22%
The most cited element by volume and the source of the largest individual penalties. Common violations: PHA not performed, PHA not revalidated within 5 years, PHA findings not addressed, team qualifications not documented, prior incidents not incorporated into PHA.
No PHA performedRevalidation overdueAction items not closedInadequate methodologyTeam unqualified
2
Mechanical Integrity
§1910.119(j) — Equipment Safety
~19%
High citation frequency and high penalty amounts. Written MI procedures missing or inadequate. Inspection intervals not established or not followed. Equipment deficiencies not corrected prior to return to service. Fabrication records missing.
No MI proceduresInspection intervals exceededDeficiencies not resolvedRAGAGEP not followed
3
Operating Procedures
§1910.119(f) — Written Procedures
~16%
Procedures exist but are incomplete (missing operating phases, missing safety systems, missing operating limits). Annual certification not completed. Procedures not accessible to operators. Procedures not updated following process changes.
Missing operating phasesNot annually certifiedNot updated for changesNot accessible in field
4
Management of Change
§1910.119(l) — Change Control
~14%
Changes made without MOC procedure. Changes improperly classified as "replacement in kind." Procedures and training not updated before startup of modified process. MOC does not document safety/health impact analysis.
No MOC procedureRIK misclassificationProcedures not updatedNo training before startup
5
Process Safety Information
§1910.119(d) — Documentation
~12%
P&IDs inaccurate or not current. Relief system design basis missing. Technology and equipment information incomplete. SDS information missing or inadequate for covered chemicals. Material and energy balances absent.
Inaccurate P&IDsRelief system docs missingIncomplete SDSNo design codes on file
6
Training
§1910.119(g)
~9%
Employees not trained in operating procedures. No documentation that training occurred or was understood. No refresher training within 3 years. New employees operating without initial training certification.
No training recordsNo refresher within 3 yearsUnderstanding not documented
7
Pre-Startup Safety Review
§1910.119(i)
~7%
No PSSR conducted before startup of new or modified covered process. PSSR did not confirm construction in accordance with design specifications. Procedures, training, and emergency planning not in place before startup.
No PSSR conductedConstruction not confirmedTraining not complete
8
Incident Investigation
§1910.119(m)
~6%
Near-miss incidents not investigated. Investigation reports incomplete — missing contributing factors, recommendations, or due dates. Prior recommendations not resolved and documented before next inspection.
Near-miss not investigatedReport incompleteRecommendations not closed
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