14 Elements of PSM: OSHA Requirements and Violation Costs

The 14 elements of PSM are the components of OSHA’s Process Safety Management standard at 29 CFR 1910.119, and every facility covered by the standard must implement all of them. The elements cover process information, hazard analysis, employee participation, operating procedures, training, contractors, pre-startup review, mechanical integrity, hot work, management of change, incident investigation, emergency planning, compliance audits, and trade secrets. What follows is what each one requires.

Who Has to Follow These Rules

PSM applies when a facility has a listed highly hazardous chemical on site at or above its threshold quantity, or when a process involves 10,000 pounds or more of a Category 1 flammable gas or a flammable liquid with a flashpoint below 100°F. Appendix A to the standard lists more than 130 chemicals with specific thresholds, including 10,000 pounds for anhydrous ammonia, 1,500 pounds for chlorine, and 1,000 pounds for hydrogen fluoride.¹

Retail facilities, oil and gas well drilling or servicing operations, and normally unoccupied remote facilities are fully exempt. Hydrocarbon fuels used solely as workplace fuel and flammable liquids stored in atmospheric tanks below their normal boiling point without refrigeration are also carved out of the flammable-materials trigger.² A facility exempt from PSM may still be covered by EPA’s Risk Management Program under 40 CFR Part 68, which has similar prevention requirements.³

1. Process Safety Information

Before any hazard analysis can begin, the employer must compile written process safety information covering the hazards of the chemicals, the technology of the process, and the equipment. Chemical data includes toxicity, permissible exposure limits, physical properties, reactivity, and corrosion characteristics. Technology documentation must include at least a block flow diagram or simplified process flow diagram, process chemistry, maximum intended inventory, and safe upper and lower limits for temperatures, pressures, flows, and compositions. Equipment information covers materials of construction, piping and instrumentation diagrams, design codes, and electrical classification.²

2. Process Hazard Analysis

Every covered process must go through a process hazard analysis that identifies what could go wrong and how bad the consequences would be. OSHA permits several methodologies:

What-If
Checklist
What-If/Checklist
HAZOP (Hazard and Operability Study)
FMEA (Failure Mode and Effects Analysis)
Fault Tree Analysis
Any equivalent methodology

The team performing the analysis must include at least one person with expertise in the specific process and at least one person experienced in the chosen methodology.⁴ The PHA must address previous incidents with catastrophic potential, engineering and administrative controls, consequences of control failures, facility siting, human factors, and a qualitative evaluation of possible safety and health effects on employees. It must be updated and revalidated at least every five years.²

3. Employee Participation

The employer must develop a written action plan that ensures employees participate in the hazard analysis and in the other elements of the PSM program. Workers and their representatives must have access to all process safety information and PHA documentation.²

4. Operating Procedures

Every covered process requires written operating procedures with clear instructions for each phase of operation. At a minimum they must address initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround or emergency shutdown. Procedures must be readily accessible to employees who work with the process.²

5. Training

Every employee involved in operating a covered process must receive initial training on the specific safety and health hazards, emergency operations, and safe work practices for their role. Refresher training is required at least every three years, or more often if the employer and employees agree. The employer must document that each employee has received and understood the training.²

6. Contractors

When contractors perform maintenance, repair, turnaround, major renovation, or specialty work on or near a covered process, both the host employer and the contractor have obligations. The host must evaluate the contractor’s safety performance before hiring, brief contract workers on the fire, explosion, and toxic release hazards relevant to their tasks, and keep a log of injuries and illnesses tied to contractor work in process areas. The contractor must train its workers in the safe practices needed for the job, document that training, and ensure its workers follow the facility’s safety rules.²

7. Pre-Startup Safety Review

Before a new facility begins operation, or before a modified facility restarts after a change significant enough to alter the process safety information, the employer must conduct a pre-startup safety review. The review must confirm that construction and equipment match design specifications, that safety and operating procedures are in place and adequate, that the PHA has been performed or updated, and that training has been completed for affected employees.²

8. Mechanical Integrity

The employer must keep critical process equipment in reliable working condition through written maintenance procedures, inspections, and testing. The element covers six categories:

Pressure vessels and storage tanks
Piping systems, including valves
Relief and vent systems and devices
Emergency shutdown systems
Controls, including monitoring devices, sensors, alarms, and interlocks
Pumps

Inspections and testing must follow recognized and generally accepted good engineering practices (RAGAGEP).² RAGAGEP includes published industry codes and standards from organizations such as ASME, NFPA, and ANSI, as well as manufacturer recommendations. Internal standards must meet or exceed applicable published RAGAGEP.⁵

9. Hot Work Permits

Any hot work performed on or near a covered process requires a permit. Hot work includes welding, cutting, brazing, and similar operations that produce sparks or flames. The permit must document that fire prevention and protection measures are in place before the work begins.²

10. Management of Change

Any change to process chemicals, technology, equipment, procedures, or facilities that affects a covered process must go through a formal management of change procedure. The only exception is a replacement in kind, meaning a direct swap of identical equipment with no change in process conditions. Before implementation, the employer must evaluate the technical basis for the change, its impact on safety and health, whether operating procedures need updating, whether the PHA needs revision, how long the change will be in effect, and what authorization is required. Affected employees must be informed and trained before startup.²

Organizational changes can trigger MOC too. OSHA has stated that staffing reductions, reorganizations, and budget cuts that affect PSM-covered processes may require an MOC review. Cutting operators from a shift, for example, may mean existing procedures can no longer be followed as written. Changes to administrative personnel whose duties do not relate to operations or maintenance do not trigger MOC.⁶

11. Incident Investigation

The employer must investigate every incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical. Near misses count. The investigation must begin no later than 48 hours after the incident, and the team must include at least one person knowledgeable in the process. The final report documents the date, a description of the incident, contributing factors, and recommendations to prevent recurrence. The employer must establish a system to promptly address the recommendations, review the report with all affected personnel (including contract employees), and retain the report for five years.²

12. Emergency Planning and Response

The employer must establish and implement an emergency action plan for the entire plant in accordance with 29 CFR 1910.38. The plan must set out the actions employees will take during a release of highly hazardous chemicals, including evacuation routes, alarm systems, and procedures for employees who remain to perform critical shutdown operations.²

13. Compliance Audits

The employer must audit the entire PSM program at least every three years to verify that procedures and practices comply with the standard. The audit produces a written report of findings, and any deficiencies must be documented and promptly resolved. Employers must retain the two most recent compliance audit reports.²

14. Trade Secrets

Employers may protect proprietary information, but they cannot use trade secret status to withhold information from anyone responsible for compiling process safety information, conducting hazard analyses, writing operating procedures, or investigating incidents. Those people must have access to all relevant data regardless of trade secret classification. Confidentiality agreements are permitted; blocked access is not.²

What Violations Cost

PSM violations follow OSHA’s standard penalty structure. As of 2025, a serious violation carries a maximum penalty of $16,550, and a willful or repeated violation can reach $165,514. The amounts are adjusted annually for inflation.⁷ Because a single PSM inspection can cite multiple elements separately, total proposed penalties in major cases routinely reach seven figures. Under the OSH Act, a willful violation that results in an employee’s death can lead to a fine of up to $250,000 for an individual or $500,000 for an organization, plus up to six months in prison; a second conviction doubles the maximum jail term.

1
Occupational Safety and Health Administration. List of Highly Hazardous Chemicals, Toxics and Reactives
2
eCFR. 29 CFR 1910.119 – Process Safety Management of Highly Hazardous Chemicals
3
U.S. Environmental Protection Agency. Why Are Industries Exempt Under OSHA’s PSM Subject to RMP?
4
Occupational Safety and Health Administration. Compliance Guidelines and Recommendations for Process Safety Management
5
Occupational Safety and Health Administration. RAGAGEP in Process Safety Management Enforcement
6
Occupational Safety and Health Administration. Management of Organizational Change
7
Occupational Safety and Health Administration. OSHA Penalties