This week the USDOL-OSHA, Directorate of Enforcement Programs, Office of Chemical Process Safety and Enforcement Initiatives team (Jeff Wanko, Jim Lay and Mike Marshall) presented an update on OSHA’s PSM Activities. This is the first such kind of update in over a year so it has some interesting DATA and updates to OSHA CHEM NEP approach. I have listed some of the highlights below, but if you want to download their .ppt just click on the image to the left.
Here is the update by the numbers…
All CHEM NEP Inspections Opened FY14 thru FY16)…
- 692 Inspections in 140 NAICS codes
- 491 inspections with violations
- 23 open and unissued inspections
- 2,202 proposed violations
- Average 4.79 violations per inspection with citations
- Penalties proposed – total $13,989,862
- Mean $26,975 per inspection
- Median $14,000 per inspection
- Max $430,430
- 78 standards cited
- 1910, 1926, 1904, 1903, and General Duty Clause
- 84% standards in General Industry (Part 1910)
- 66% of GI violations in PSM (1910.119)
- Programmed – 52%
- Unprogrammed – 48% (Unprogrammed includes Complaint, Referral, Fatality/Multiple Hospitalization, etc.)
Elements Cited:
NOTE: The TOP three (3) cited elements (PSI, MI, & PHA) accounted for 76%
of ALL PSM citations in FY14 thru FY16!
| Element | Description | % of PSM Citations |
| d | Process Safety Information | 23.6 |
| j | Mechanical Integrity | 23.6 |
| e | Process Hazard Analysis | 15.3 |
| f | Operating Procedures | 13.5 |
| l | Management of Change | 6.4 |
| o | Compliance Audits | 3.8 |
| h | Contractors | 3.4 |
| g | Training | 2.8 |
| n | Emergency Planning & Response | 2.5 |
| m | Incident Investigation | 2.1 |
| c | Employee participation | 1.7 |
| i | Pre-startup Review | 1.0 |
Cited Elements broken down:
| Sub-element | Description | % of PSM Citations |
| 119(j)(2) | MI written procedures | 7.0 |
| 119(d)(3)(ii) | PSI RAGAGEP compliance | 6.4 |
| 119(d)(3)(i)(B) | PSI P&IDs | 4.4 |
| 119(j)(5) | MI Equipment Deficiencies | 3.5 |
| 119(j)(4)(i) | MI I&T not performed | 3.5 |
| 119(l)(1) | Management of Change dev & imp | 3.5 |
| 119(f)(1) | OP Developed & Implemented | 3.2 |
| 119(e)(5) | PHA findings & recommendations | 3.0 |
| 119(j)(4)(ii) | MI I&T not in accordance w/ RAGAGEP | 3.0 |
| 119(j)(4)(iii) | Inspection frequency inconsistent with RAGAGEP | 2.7 |
| 119(n) | Emergency Planning & Response | 2.5 |
| 119(e)(3)(i) | PHA Hazards of the Process | 2.4 |
| 119(d)(3)(i)(D) | Relief System Design | 2.4 |
CLICK ON THE IMAGE ABOVE FOR THE PPT