The largest penalty OSHA ever proposed wasn't for the explosion. It was for what came after.
In 2009, four years after 15 workers died at BP's Texas City refinery, OSHA returned and proposed $87.43 million in penalties — $56.7 million of it for 270 hazards BP had agreed to fix in 2005 and hadn't.
Proposed. BP later paid a $50.6M settlement (2010) for the failure-to-abate items and $13.03M (2012) for 409 willful PSM citations. Sources: OH&S, MPR/AP, ENR.
The Case Record
Full record with sources →| Year | Facility | Type | Proposed |
|---|---|---|---|
| 2009 | BP Products Texas City, TX · Refinery | WillfulFTA | $87,430,000 |
| 2010 | BP-Husky Refining Oregon (Toledo), OH · Refinery | WillfulSerious | $3,042,000 |
| 2013 | Chevron USA (Cal/OSHA) Richmond, CA · Refinery | WillfulSerious | $963,200 |
| 2020 | TPC Group Port Neches, TX · Chemical | Willful | $514,692 |
| 2021 | Limetree Bay Refining St. Croix, USVI · Refinery | Serious | $259,407 |
| 2024 | Schoep's Ice Cream Madison, WI · Ammonia refrigeration | Serious | $145,097 |
| 2020 | Philadelphia Energy Solutions Philadelphia, PA · Refinery | Serious | $132,600 |
All figures are proposed penalties at the time of citation. Employers may contest citations before the OSH Review Commission; final amounts often differ. Each case links to its source on the full record page.
Where Inspectors Find Violations
Element-by-element →Four elements. Seven in ten citations.
In OSHA's Refinery National Emphasis Program, mechanical integrity, process safety information, operating procedures, and process hazard analysis together drew over 70% of PSM citations. Refinery NEP inspections averaged 11.2 citations each.
Source: OSHA, Refinery NEP findings (J. Barab presentation, July 2012), csb.gov. Share of citations by element; contractors (h) and remaining elements not shown.
What a Citation Costs in 2026
How OSHA calculates it →per violation · minimum $11,823
Employer knew of the requirement and chose not to comply, or was plainly indifferent.
per violation · minimum $4,256
Same or similar violation cited previously.
per violation · minimum $1,085
Substantial probability of death or serious harm the employer knew or should have known about.
Penalties apply per violation instance. Failure to abate: up to $16,550 per day past the abatement date. 2026 amounts are unchanged from 2025 because the October 2025 CPI data used for the annual adjustment was not published. Source: OSHA memo, May 21, 2026.