A Quick Review of Recent OSHA PSM Citations

Last week we published OSHA's top 10 safety and health violations for 2018. In this article, we're going to focus specifically on violations related to the Process Safety Management (PSM) standard. If you weren't aware, the U.S. Department of Labor (DOL) provides a vast amount of raw data related to OSHA activities (inspections, violations, etc.) directly through their website. One can find lists of OSHA citations, as well as those that stem specifically from PSM.

What follows is a quick summary of 2016-2017 OSHA violation data pulled directly from the DOL website. Only citations related to the PSM standard (1910.119) were considered. Caveat emptor: there is no guarantee that this data is completely accurate, and as those in the world of finance like to say, past performance is not indicative of future results.

The first chart shows PSM citations in 2016 and 2017 by section/paragraph. Overall, there were significantly less citations in 2017 (653 citations) compared to 2016 (1,009 citations). That’s a 35% drop in year-over-year citations. In both years, Mechanical Integrity (paragraph J) is the most-cited, followed by Process Safety Information (paragraph D).

The second chart focuses specifically on Mechanical Integrity citations. The most cited subsection in both years was Inspection and Testing, followed by Written Procedures. While there was an overall drop in MI-related citations, their relative frequencies hardly changed.

And finally, the following chart further narrows the data to only Inspection and Testing citations. For reference, the full descriptions of each of the Inspection and Testing subsections are:

• (j)(4)(i): Inspections and tests shall be performed on process equipment.
• (j)(4)(ii): Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
• (j)(4)(iii): The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
• (j)(4)(iv): The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.