What puts OSHA at a PSM facility's gate
OSHA doesn't pick facilities at random. Inspections follow a priority order, and a PSM facility can land on the list through an incident, a complaint, a referral, or a programmed emphasis inspection.
The triggers, in OSHA's priority order
| 01 | Imminent dangerAny condition that could reasonably be expected to cause death or serious physical harm immediately. OSHA's highest priority. |
| 02 | Fatalities and severe injuriesEmployers must report a work-related fatality to OSHA within 8 hours, and any in-patient hospitalization, amputation, or loss of an eye within 24 hours (29 CFR 1904.39). At a PSM facility, the investigation that follows usually reaches into the PSM program itself. |
| 03 | Worker complaints and referralsComplaints from employees or their representatives, and referrals from other agencies, the media, or the public. A detailed complaint about a specific process hazard can trigger an on-site inspection. |
| 04 | Targeted and emphasis-program inspectionsProgrammed inspections of high-hazard industries, including the PSM Covered Chemical Facilities National Emphasis Program (CPL 03-00-021, issued January 2017). Facilities can be selected without any complaint or incident. |
| 05 | Follow-up inspectionsOSHA returns to verify that cited hazards were corrected. Uncorrected items become failure-to-abate violations — the source of $56.7 million of BP's 2009 Texas City penalty. |
NEP status: CPL 03-00-021 is listed among OSHA's active National Emphasis Programs by compliance publishers as of August 2026 (J.J. Keller), though OSHA's directive page carries an archive notice. Confirm current status with your OSHA area office or state plan. State-plan states run their own programs, which must be at least as effective as federal OSHA's.
Inside a PSM inspection
Walk one yourself →The compliance officer explains the scope and requests documents — typically PSI, PHAs, operating procedures, training records, MI records, MOCs, incident investigations, and compliance audits.
Inspectors compare what's written to what's in the field: P&IDs against the piping, procedures against what operators actually do, MI records against equipment condition.
Findings are discussed at the closing conference. Citations, if any, must be issued within six months of the violation. Employers then have 15 working days to contest.
In the Refinery NEP, inspections averaged 11.2 citations each (OSHA, 2012). See where those citations land.