In OSHA’s fiscal year 2022, Process Hazard Analysis was the #4 most cited element of the PSM standard. Here is a breakdown of those citations…
58 PHA citations or 14% of all PSM citations in 2022
The #1 and 2 PHA elements cited in 2022 with 10 or 17% of the PHA citations, were
1910.119(e)(1), perform an initial process hazard analysis
1910.119(e)(3)(v), facility siting
The #3 PHA citation in 2022 was 1910.119(e)(3)(i), hazards of the process, with 8 or 14% of the PHA citations
The #4 PHA citation in 2022 was 1910.119(e)(5), establish a system to promptly address the team’s findings and recommendations, with 6 or 10% of the PHA citations
The #5 and 6 PHA citations in 2022 were:
1910.119(e)(3)(iii), engineering and administrative controls, with 5 or 9% of the PHA citations
1910.119(e)(6), five (5) year revalidation, with 5 or 9% of the PHA citations
The #7 and 8 PHA citations in 2022 were:
1910.119(e)(3)(iv), consequences of failure of engineering and administrative controls, with 4 or 7% of the PHA citations
1910.119(e)(3)(vi), human factors, with 4 or 7% of the PHA citations
The following elements were each cited once or 2% of of the PHA citations:
1910.119(e)(1)(iv), initial process hazards analyses shall be completed by May 26, 1997
1910.119(e)(2)(iv), HAZOP
1910.119(e)(3), PHA shall address
1910.119(e)(3)(ii), previous incidents
1910.119(e)(4), PHA shall be performed by a team with expertise
1910.119(e)(7), retain PHAs and updates or revalidations for the life of the process