2026 PENALTY MAXIMUMS: Willful / Repeat $165,514 per violation  ·  Serious $16,550 per violation Unchanged from 2025 — OSHA memo, May 21, 2026
The enforcement record of 29 CFR 1910.119
The Record

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.

$87.43M

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.

YearFacilityWhat OSHA foundTypeProposed
2009BP Products
Texas City, TX · Refinery
Failure to abate 2005 settlement items; pressure relief and PSM violationsWillfulFTA$87,430,000
2010BP-Husky Refining
Oregon (Toledo), OH · Refinery
Inadequate pressure relief, fuel accumulation in process heatersWillfulSerious$3,042,000
2013Chevron USA (Cal/OSHA)
Richmond, CA · Refinery
Corroded pipe left in service despite internal recommendations since 2002WillfulSerious$963,200
2020TPC Group
Port Neches, TX · Chemical
No emergency shutdown procedures; process vessel and piping not inspected/testedWillful$514,692
2021Limetree Bay Refining
St. Croix, USVI · Refinery
20 PSM violations following releases and flaring eventsSerious$259,407
2024Schoep's Ice Cream
Madison, WI · Ammonia refrigeration
Insufficient PSM procedures after worker ammonia exposureSerious$145,097
2020Philadelphia Energy Solutions
Philadelphia, PA · Refinery
PSM violations after 2019 HF alkylation unit fire and explosionsSerious$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 →
Mechanical Integrity · (j)
19.5%
Process Safety Information · (d)
17.4%
Operating Procedures · (f)
17.1%
Process Hazard Analysis · (e)
16.5%
Management of Change · (l)
9.0%
Incident Investigation · (m)
6.7%

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 →
Willful
$165,514

per violation · minimum $11,823

Employer knew of the requirement and chose not to comply, or was plainly indifferent.

Repeat
$165,514

per violation · minimum $4,256

Same or similar violation cited previously.

Serious
$16,550

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.

Before the inspector does

Find your gaps first.

A PSM program can look complete on paper and still fail in the field. An independent PSM assessment finds what an inspector would — while it's still a work order instead of a citation.

Assess Your FacilityWalk a Mock Inspection