OSHA’s fiscal year 2022 saw a significant change in the leading PSM element for citations. As far as I know, Mechanical Integrity has been the most cited element every year for the past 20 years. And it held that spot convincingly for those years. Last year, SOPs took the top spot with…
78 citations or 18% of the PSM citations issued in 2022. Mechanical Integrity was not far behind with 77 citations or 18%.
But the fact that SOPs saw 54 citations in 2021 and 77 in 2022 (a 35% increase) could be a sign that OSHA is shifting its focus.
FYI, in 2021 OSHA issued 62 MI citations (vs. 77 in 2022) for an increase of 21%.
The #1 SOP element to be cited in 2022 was 1910.119(f)(1), develop and implement SOPs, with 11 citations or 14% of SOP citations.
The #2 and #3 SOP elements to be cited in 2022 were
1910.119(f)(3), annual certifications, with 9 citations or 12% of SOP citations
1910.119(f)(4), safe work practices, with 9 citations or 12% of SOP citations
The #4 and #5 SOP elements to be cited in 2022 were
1910.119(f)(1)(i)(d), emergency shutdown, with 7 citations or 9% of SOP citations
1910.119(f)(1)(ii), operating limits, with 7 citations or 9% of SOP citations
The #6 SOP element to be cited in 2022 was 1910.119(f)(1)(iii)(b), precautions necessary to prevent exposure, with 6 citations or 8% of SOP citations.
The #7 and #8 SOP element to be cited in 2022 were
1910.119(f)(1)(iii)(C), control measures to be taken if physical contact or airborne exposure occurs, with 5 citations or 6% of SOP citations
1910.119(f)(1)(iv), safety systems and their functions, with 5 citations or 6% of SOP citations
The #9 and #10 SOP element to be cited in 2022 were
1910.119(f)(1)(i), steps for each operating phase, with 3 citations or 4% of SOP citations
1910.119(f)(1)(i)(G), startup following a turnaround or after an emergency shutdown, with 3 citations or 4% of SOP citations
The #11-15 spots were
1910.119(f)(1)(i)(A), initial startup, with 2 citations or 2% of SOP citations
1910.119(f)(1)(ii)(a), consequences of deviation, with 2 citations or 2% of SOP citations
1910.119(f)(1)(iii)(A), properties of, and hazards presented, with 2 citations or 2% of SOP citations
1910.119(f)(1)(iii)(D), quality control for raw materials and control of inventory, with 2 citations or 2% of SOP citations
1910.119(f)(2), readily accessible, with 2 citations or 2% of SOP citations
And the last 5 slots belong to the following
1910.119(f)(1)(i)(C), temporary operations, with 1 citation or 1% of SOP citations
1910.119(f)(1)(i)(E), emergency operations, with 1 citation or 1% of SOP citations
1910.119(f)(1)(ii)(B), steps required to correct or avoid deviation, with 1 citation or 1% of SOP citations
1910.119(f)(1)(iii), safety and health considerations, with 1 citation or 1% of SOP citations
1910.119(f)(1)(iii)(E), any special or unique hazards, with 1 citation or 1% of SOP citations