Most Cited
Where OSHA inspectors find PSM violations
Mechanical integrity, process safety information, operating procedures, and process hazard analysis drew over 70% of PSM citations in OSHA's Refinery National Emphasis Program.
Share of PSM citations by element, Refinery NEP. Source: OSHA Refinery NEP findings, J. Barab presentation, July 2012 (csb.gov). Refinery NEP inspections averaged 11.2 citations per inspection versus 8.4 for chemical NEP inspections. For the most-cited elements over the last 12 months, see the live tracker.
What inspectors cite within each element
| Para. | Element · common findings | Citations | Share |
|---|---|---|---|
| (j) | Mechanical Integrity Written MI procedures missing; equipment operated with deficiencies; inspection frequency not consistent with RAGAGEP. | 198 | 19.5% |
| (d) | Process Safety Information P&IDs missing or inaccurate; relief system design basis not documented; RAGAGEP compliance not documented. | 177 | 17.4% |
| (f) | Operating Procedures Procedures missing operating phases or safe operating limits; not certified annually; not current. | 174 | 17.1% |
| (e) | Process Hazard Analysis PHA not addressing facility siting or human factors; recommendations not resolved in a timely manner. | 168 | 16.5% |
| (l) | Management of Change Changes made without MOC; impact on safety and health not reviewed. | 92 | 9.0% |
| (m) | Incident Investigation Near misses not investigated; findings not resolved or documented. | 68 | 6.7% |
Common findings summarized from OSHA NEP lessons learned (Primatech summary). Contractors (h) and remaining elements are not shown in the source data.