PSM Regulation Citations: Trends in OSHA PSM Enforcement

Since OSHA began issuing citations under the Process Safety Management (PSM) standard (29 CFR 1910.119), the relative frequency of citations related to some subsections of the regulations has increased dramatically, while the frequency of others has decreased just as dramatically. Has OSHA changed its focus over time? Will there be new trends in the future? These issues can be better understood by looking at citation history and the continuing deadlines built into the regulation.

I. OSHA PSM Citations From May 1992 to May 1995

Federal and State OSHA Programs cited 384 establishments for 1,843 violations of the PSM standard during the first 36 months after its effective date (May 26, 1992). This reflects an average of approximately 5 violations per PSM-cited inspection, covering the full range of inspection types (regularly scheduled, complaints, catastrophes, etc.). Table 1 lists the total numbers of cited violations under each of the 14 subsections of the PSM regulation.

The overall data provides useful information about citation emphasis during the first 36 months of enforcement of the PSM standard. Clearly operating procedures, mechanical integrity, and training have been major concerns, together making up nearly 50% of all the cited violations. The industry should also focus attention on the next five items in the table (employee participation, contractors, process hazard analysis, process safety information, and management of change), which together comprise over 40% of the cited violations. Through May 31, 1995, the remaining six elements make up only 10% of the citations.

II. Trends in OSHA PSM Citations

From time to time, JBF Associates, Inc. (JBFA) and the Process Safety Institute (PSI) have compiled summaries of OSHA citations of the PSM standard. The different periods of time covered by the summaries are not of a consistent length, so care needs to be exercised in interpreting the data; however, JBFA and PSI found comparisons of the data to be of interest, and the data are used in this article to illustrate areas that OSHA has focused on (and that industry probably should focus on, too).