How PSM violations are written, paragraph by paragraph. These are representative examples modeled on the way OSHA words citations under 29 CFR 1910.119 — not records of specific inspections. Search by element, violation type, or keyword.
| Standard | Element | Type | Violation Description |
|---|---|---|---|
| 1910.119(c)(1) | Employee Participation | Serious | Employer failed to develop a written plan of action for implementing the employee participation requirements of the PSM standard. |
| 1910.119(c)(2) | Employee Participation | Other-Than-Serious | Employer did not consult with employees and their representatives on the conduct and development of PHAs and other elements of process hazard management. |
| 1910.119(d) | Process Safety Information | Serious | Employer failed to compile written process safety information on the hazards of the highly hazardous chemicals in the process prior to conducting a PHA. |
| 1910.119(d)(2)(i)(A) | Process Safety Information | Serious | Process safety information did not include block flow diagrams or simplified process flow diagrams for the covered process. |
| 1910.119(d)(2)(i)(C) | Process Safety Information | Serious | Employer failed to document the maximum intended inventory of the highly hazardous chemical in the process. |
| 1910.119(d)(3)(i)(B) | Process Safety Information | Serious | Piping and instrumentation diagrams (P&IDs) did not reflect current as-built conditions; multiple field modifications were not incorporated into the drawings. |
| 1910.119(d)(3)(i)(B) | Process Safety Information | Repeat | P&IDs were still inaccurate at a later inspection after a prior citation for the same condition; drawings had not been updated following process modifications. |
| 1910.119(d)(3)(i)(D) | Process Safety Information | Serious | Employer could not produce relief system design basis documentation for pressure vessels in the covered process. |
| 1910.119(d)(2)(i)(E) | Process Safety Information | Serious | Employer had not documented the consequences of deviation from the normal operating range for key process parameters. |
| 1910.119(e)(1) | Process Hazard Analysis | Serious | Employer failed to perform an initial process hazard analysis on the covered process using one of the methodologies listed in the standard. |
| 1910.119(e)(1) | Process Hazard Analysis | Willful | Employer knowingly operated a covered process for an extended period without conducting any process hazard analysis. |
| 1910.119(e)(3)(i) | Process Hazard Analysis | Serious | PHA did not address the hazards of the process — the study failed to identify credible release scenarios for the highly hazardous chemicals present. |
| 1910.119(e)(3)(v) | Process Hazard Analysis | Serious | PHA did not address facility siting — the study contained no evaluation of the impact of a catastrophic release on adjacent occupied buildings. |
| 1910.119(e)(3)(vi) | Process Hazard Analysis | Serious | PHA failed to address human factors, including control room design, alarm management, and the potential for operator error during abnormal operations. |
| 1910.119(e)(4) | Process Hazard Analysis | Serious | PHA team did not include an employee with expertise in the process operations — the team consisted entirely of engineers with no active operations personnel. |
| 1910.119(e)(5) | Process Hazard Analysis | Serious | Employer had not established a system to promptly address the PHA team's findings and recommendations; many recommendations had no documented resolution. |
| 1910.119(e)(5) | Process Hazard Analysis | Repeat | Unresolved PHA recommendations previously cited were still open with no documented corrective action or written schedule. |
| 1910.119(e)(5) | Process Hazard Analysis | Serious | Employer failed to communicate PHA findings and recommendations to operating personnel in the affected process areas. |
| 1910.119(e)(6) | Process Hazard Analysis | Serious | PHA was not updated and revalidated within the required five-year interval. |
| 1910.119(e)(6) | Process Hazard Analysis | Willful | Employer knowingly allowed PHA revalidations to lapse on multiple covered processes with no plan to complete them. |
| 1910.119(f)(1)(i)(A) | Operating Procedures | Serious | Employer had not developed written operating procedures for the initial startup phase of the covered process. |
| 1910.119(f)(1)(ii)(B) | Operating Procedures | Serious | Operating procedures did not address the consequences of deviating from operating limits or the steps required to correct or avoid the deviation. |
| 1910.119(f)(3) | Operating Procedures | Serious | Operating procedures had not been reviewed as often as necessary to reflect current operating practice and changes to the process. |
| 1910.119(f)(3) | Operating Procedures | Repeat | Operating procedures were again out of date at the time of re-inspection — the same deficiency cited in the prior inspection had not been corrected. |
| 1910.119(f)(3) | Operating Procedures | Other-Than-Serious | Employer had not certified annually that operating procedures are current and accurate. |
| 1910.119(g)(1)(i) | Training | Serious | Employees were assigned to operate the covered process without first receiving initial training on the process-specific safety and health hazards. |
| 1910.119(g)(1)(i) | Training | Serious | Initial training did not emphasize emergency operations, including shutdown, for the covered process. |
| 1910.119(g)(2) | Training | Serious | Employer did not provide refresher training at least every three years to employees operating the covered process. |
| 1910.119(g)(2) | Training | Willful | Employer knowingly failed to provide refresher training to process operators after being made aware of the deficiency. |
| 1910.119(g)(3) | Training | Serious | Training certification records did not verify that employees understood the training. Records consisted of attendance sheets only, with no comprehension verification. |
| 1910.119(g)(3) | Training | Other-Than-Serious | Employer's training certification records were incomplete — identity and date of training were documented but the means used to verify understanding was not recorded. |
| 1910.119(h)(2)(i) | Contractors | Serious | Host employer failed to obtain and evaluate information regarding the contract employer's safety performance and programs prior to contracting for work in the covered process area. |
| 1910.119(h)(2)(ii) | Contractors | Serious | Host employer did not inform contract employer of the known potential fire, explosion, and toxic release hazards related to the contractor's work in the process area. |
| 1910.119(h)(2)(iii) | Contractors | Serious | Host employer failed to explain to the contract employer the applicable provisions of the facility's emergency action plan. |
| 1910.119(h)(2)(iv) | Contractors | Serious | Host employer had not developed and implemented safe work practices to control the entrance, presence, and exit of contract employees in covered process areas. |
| 1910.119(h)(2)(v) | Contractors | Serious | Host employer failed to periodically evaluate the performance of contract employers working in or adjacent to the covered process. |
| 1910.119(h)(3)(i) | Contractors | Serious | Contract employer failed to ensure that each contract employee was trained in the work practices necessary to safely perform his or her job in the covered process area. |
| 1910.119(h)(3)(v) | Contractors | Other-Than-Serious | Contract employer did not advise the host employer of unique hazards presented by the contractor's work or of hazards found by the contract employer's work. |
| 1910.119(i)(2)(i) | Pre-Startup Safety Review | Serious | Highly hazardous chemicals were introduced into a modified process without a pre-startup safety review confirming construction and equipment were in accordance with design specifications. |
| 1910.119(i)(2)(ii) | Pre-Startup Safety Review | Serious | PSSR did not confirm that safety, operating, maintenance, and emergency procedures were in place and adequate before startup. |
| 1910.119(i)(2)(iii) | Pre-Startup Safety Review | Serious | PSSR did not confirm that a PHA had been performed for the new facility and its recommendations resolved or implemented before startup. |
| 1910.119(i)(2)(iv) | Pre-Startup Safety Review | Serious | PSSR did not confirm that training of each employee involved in operating the process had been completed before startup. |
| 1910.119(j)(2) | Mechanical Integrity | Serious | Employer had not established written procedures to maintain the ongoing integrity of process equipment including pressure vessels, piping systems, and relief devices. |
| 1910.119(j)(3) | Mechanical Integrity | Serious | Employees performing inspection and testing of pressure vessels had not received training in applicable inspection methods and procedures. |
| 1910.119(j)(4)(iii) | Mechanical Integrity | Serious | Inspections and tests of process piping were not performed at frequencies consistent with the employer's selected RAGAGEP, such as API 570. |
| 1910.119(j)(4)(i) | Mechanical Integrity | Willful | Employer knowingly failed to implement an inspection and testing program for pressure vessels in a covered ammonia process. |
| 1910.119(j)(4)(iv) | Mechanical Integrity | Serious | Inspection and test records did not document the date, the name of the person who performed the inspection, the equipment identifier, the inspection performed, or the results. |
| 1910.119(j)(5) | Mechanical Integrity | Serious | Equipment deficiencies outside acceptable limits were not corrected before further use, and no necessary means were taken to assure safe operation in the interim. |
| 1910.119(j)(5) | Mechanical Integrity | Repeat | Equipment deficiencies previously cited remained uncorrected at a later inspection with no documented corrective action schedule. |
| 1910.119(j)(6)(iii) | Mechanical Integrity | Serious | Employer did not assure that maintenance materials, spare parts, and equipment, such as replacement gaskets and fittings, were suitable for the process application. |
| 1910.119(k)(1) | Hot Work Permit | Serious | Employer failed to issue hot work permits for cutting and welding operations conducted in or near the covered process area. No hot work permit program existed. |
| 1910.119(k)(1) | Hot Work Permit | Willful | Employer knowingly allowed welding on process piping containing flammable hydrocarbons without a hot work permit, contrary to its own written program. |
| 1910.119(k)(2) | Hot Work Permit | Serious | Hot work permits did not document that fire prevention and protection requirements in 1910.252(a) had been implemented prior to beginning hot work operations. |
| 1910.119(l)(1) | Management of Change | Serious | Employer had not established written procedures to manage changes to process chemicals, technology, equipment, and procedures. Multiple undocumented process modifications had been made. |
| 1910.119(l)(1) | Management of Change | Willful | Employer willfully failed to implement an MOC program. Process modifications affecting HHC handling were routinely made by field personnel without documentation, hazard review, or management authorization. |
| 1910.119(l)(2) | Management of Change | Serious | MOC procedure did not address the technical basis for the change or its impact on safety and health before changes to process technology were made. |
| 1910.119(l)(3) | Management of Change | Serious | Employer failed to inform and train affected employees on process changes covered by the MOC procedure prior to startup of the changed process. |
| 1910.119(l)(4) | Management of Change | Serious | Process safety information was not updated after changes were made under the MOC system; P&IDs did not reflect current conditions. |
| 1910.119(l)(4) | Management of Change | Repeat | Process safety information remained out of date at a later inspection; MOC records existed but corresponding P&ID updates had not been completed. |
| 1910.119(m)(1) | Incident Investigation | Serious | Employer did not investigate an incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical. |
| 1910.119(m)(3) | Incident Investigation | Serious | Investigation team did not include a person with knowledge of the process and a contract employee when the incident involved a contractor working in the process area. |
| 1910.119(m)(4) | Incident Investigation | Serious | Incident investigation report did not include the factors that contributed to the incident or recommendations resulting from the investigation. |
| 1910.119(m)(6) | Incident Investigation | Serious | Investigation report and recommendations had not been reviewed with all affected personnel, including contract employees, whose job tasks were relevant to the incident findings. |
| 1910.119(m)(7) | Incident Investigation | Serious | Employer did not retain incident investigation reports for five years. |
| 1910.119(n) | Emergency Planning | Serious | Employer failed to establish and implement an emergency action plan for the entire plant in accordance with 29 CFR 1910.38(a), as required by the PSM standard. |
| 1910.119(o)(1) | Compliance Audits | Serious | Employer had not certified that it evaluated compliance with the PSM standard at least every three years. |
| 1910.119(o)(2) | Compliance Audits | Serious | Compliance audit was not conducted by at least one person knowledgeable in the process. |
| 1910.119(o)(4) | Compliance Audits | Serious | Employer failed to promptly determine and document an appropriate response to each of the compliance audit findings and ensure that the deficiencies are corrected. |
| 1910.119(o)(5) | Compliance Audits | Other-Than-Serious | Employer did not retain the two most recent compliance audit reports. |
| 1910.119(p)(1) | Trade Secrets | Other-Than-Serious | Employer withheld information claimed as a trade secret from persons responsible for compiling process safety information and conducting process hazard analyses. |
Citations are drawn from OSHA enforcement records, NEP inspection reports, and publicly available settlement data under 29 CFR 1910.119. Penalty amounts reflect amounts at or after informal settlement, which typically reduce initial proposed penalties by 15–50%. Maximum penalties as of 2026 are $16,550 per serious violation and $165,514 per willful or repeat violation. This database is updated periodically — for the authoritative enforcement record, use OSHA's Establishment Search.