Already, in less than 24 hours from when I posted the OSHRC decision on the BP Refinery, I have received over a dozen e-mails asking me “do I have to have U-1 forms for my pressure vessels?”. There are not many PSM/RMP facilities that have not been dinged with one of these findings over the past 20 years. So my response to each one is YES, you MUST have THE DATA on your pressure vessels in order to properly manage these CRITICAL safety items. The OSHRC took issue with the fact that the CSHO actually found ALL THE U-1 form DATA for the pressure vessel in question within 30 minutes! As the OSHRC stated, the U-1 form is NOT listed in the PSI data requirements, BUT here is why the DATA from the U-1 form is ABSOLUTELY CRITICAL and REQUIRED for a properly functioning process safety management system…