In my earlier post, my data showed OSHA conducted 66 PSM inspections and issued 347 citations. Now that I have all the data in raw form, I saw 430 citations in 2022.
The discrepancy is likely due to one database using the “issuance date” and the other using the “final order” date.
And yes, SOP citations were #1 in 2022, beating the all-time reigning champion Mechanical Integrity.
Anyway, this is a more detailed look at the PSM citations issued in 2022:
The #1 cited element in 2022 was SOPs, with 78 citations, or 18%
(NOTE: That is a change from MI being the #1 cited element. For as long as I can recall, MI was always the #1 cited element)
The #2 cited element in 2022 was MI, with 77 citations, or 18%
The #3 cited element in 2022 was PSI, with 69 citations, 16%
The #4 cited element in 2022 was PHA, with 58 citations, or 14%
The #5 cited element in 2022 was Contractors, with 34 citations, or 8%
The #6 cited element in 2022 was MOC, with 30 citations, or 7%
The #7 cited element in 2022 was Audits, with 17 citations, or 4%
Tied for #8 and #9 cited elements in 2022 were Training and Emergency P&R, with 13 citations each, or 3%
Tied for #10 and #11 cited elements in 2022 were Employee Participation and PSSR with 10 citations each, or 2%
The #12 cited element in 2022 was Incident Investigation, with 5 citations, or 1%
The #13 cited element in 2022 was Hot Work Permit, with 4 citations, or 1%
The #14 cited element in 2022 was Trade Secrets, with 0 citations, or 0%
MI was still #1 in $ cited in 2022 with $489,964 or 20%
SOP was #2 in $ cited in 2022 with $415,285 or 17%
PSI was #3 in $ cited in 2022 with $400,460 or 16.6%
PHA was #4 in $ cited in 2022 with $382,519 or 16%
Contractors was #5 $ cited in 2022 with $241,235 or 10%
MOC was #6 in $ cited in 2022 with $155,210 or 6%
Audits were #7 in $ cited in 2022 with $93,934 or 4%
ER was #8 in $ cited in 2022 with $78,646 or 3%
PSSR was #9 in $ cited in 2022 with $57,514 or 2%
Employee Participation was #10 in $ cited in 2022 with $38,944 or 1.6%
Incident Investigation was #11 in $ cited in 2022 with $20,722 or 1%
Training was #12 in $ cited in 2022 with $16,576 or 0.6%
Hot Work Permit was #13 in $ cited in 2022 with $13,169 or 0.5%
Trade Secrets was last with $0.00
Of the citations issued…
66 were issued as “Other than Serious.”
3 were issued as “Repeats”
349 were issued as “Serious”
12 were issued as “Willful”


