OSHA PSM Penalty Exposure Estimator

Step 1 — Employer Size

How many employees does the company have?

OSHA counts the employer's maximum number of employees at all workplaces nationwide at any one time in the previous 12 months. The size reduction shown is for serious and other-than-serious items; serious willful items use a separate table (up to 80% for 20 or fewer employees).

1–20 employees 70% size reduction

21–25 employees 70% size reduction

26–30 employees 30% size reduction

31–40 employees 30% size reduction

41–50 employees 30% size reduction

51–100 employees 30% size reduction

101–250 employees 10% size reduction

251+ employees 0% size reduction

Step 2 — Add Citation Items

Citation Items

For each item, pick the classification and gravity. Gravity comes from severity and probability: OSHA reserves high gravity for the most serious conditions, such as danger of death or extremely serious injury.

Classification	Gravity / basis	Items	Extra	Est. per item

Step 3 — Adjustment Factors

Good Faith, History, and Quick-Fix

Applied in this order after size, per OSHA's Field Operations Manual, Chapter 6 (revised July 14, 2025).

Good Faith

15% for a documented, effective safety and health management system with only incidental deficiencies; 25% for a written system with all core elements. Not given for high-gravity serious, willful, repeat, or failure-to-abate items, or if any willful, repeat, or FTA item is found in the inspection.

History

20% reduction if never inspected, or inspected in the past 5 years with no serious, willful, or repeat findings. 20% increase if serious high-gravity citations became final orders in the past 5 years. Not applied to repeat or FTA items.

Quick-Fix (15%)

For other-than-serious and low or moderate gravity serious items that are permanently abated during the inspection or within 5 days (up to 15 with justification). Not for high-gravity, willful, repeat, FTA, or fatality/serious-injury related items.

Estimated Penalty Exposure

$0 Add citations in Step 2 to see your estimated penalty exposure.

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Understanding OSHA PSM Penalties

Current penalty amounts from OSHA’s 2026 penalty memo and reduction factors from FOM Chapter 6 (revised July 14, 2025).

Willful

$11,823–$165,514

Issued when an employer intentionally and knowingly violated a requirement, or acted with plain indifference to employee safety. The statutory minimum is $11,823 per violation. Only size and history reductions apply; good faith does not.

Repeat

up to $165,514

Issued when the employer was previously cited for a substantially similar violation that became a final order. Under the FOM, the gravity-based penalty is multiplied by 2 or 5 (250 or fewer employees) or by 5 or 10 (more than 250), and only the size reduction applies.

Serious

up to $16,550

Issued when there is a substantial probability that death or serious physical harm could result. The gravity-based penalty ranges from $7,093 (low) to $16,550 (high) depending on severity and probability, before size, good faith, history, and Quick-Fix adjustments.

Other-Than-Serious

up to $16,550

Rare in PSM enforcement. Reserved for violations that have a direct relationship to workplace safety but would not likely cause death or serious injury. PSM paperwork deficiencies sometimes fall here, but OSHA typically classifies incomplete PHA or MOC documentation as serious.

Failure to Abate

up to $16,550/day

Issued when a previously cited violation has not been corrected by the abatement deadline. FTA penalties accrue per day, making this the fastest path to catastrophic penalty exposure. FTA penalties are normally capped at 30 days, so one item at the maximum daily amount could reach $496,500.

Real PSM Enforcement Numbers

$76.8K Average proposed penalty per Refinery NEP inspection, 2007–2011 (11.2 citations each)

$31.6K Average proposed penalty per Chemical NEP inspection with citations, through Nov. 2011 (8.4 citations each)

6 mo OSHA must issue citations within six months of the violation (OSH Act §9(c))

15 days Working days an employer has to contest citations after receiving them

NEP figures: OSHA presentation to the CSB, July 2012.

OSHA Penalty Reduction Factors

Factor	Criteria	Reduction	Applies to Willful?
Size	1–25 employees (nationwide)	70%	Willful: up to 80% for 20 or fewer (separate table)
Size	26–100 employees	30%	Yes, per willful table
Size	101–250 employees	10%	Yes
Good Faith	Documented, effective safety & health management system with only incidental deficiencies	15%	No
Good Faith	Written system with all core elements (leadership, hazard ID, controls, training, evaluation)	25%	No
History	Never inspected, or no serious/willful/repeat findings in past 5 years	20%	Yes
History (increase)	Serious high-gravity citations became final orders in past 5 years	+20%	Yes
Quick-Fix	Permanent abatement during the inspection or within 5 days (up to 15 with justification); OTS and low/moderate serious only	15%	No

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The CCPS Guidelines for Auditing Process Safety Management Systems is the field reference for pre-inspection PSM auditing and documentation review. Used by PSM auditors and compliance specialists to find gaps before OSHA does.

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OSHA PSM PenaltyExposure Estimator