OSHA PSM Citation Summary


		AcuSafe Home Page -> September 2001 Newsletter
		OSHA PSM Citation Summary

Since the inception of the PSM Standard, OSHA has vigorously enforced the regulation. Citations represent an importance source of guidance on the content and direction of PSM programs. Like written interpretations, employers are not legally responsible for being aware of the status of citations issued against the PSM Standard, nor do they represent official OSHA policy with respect to interpretation of the regulations. However, they do represent what to avoid in PSM practices so that the possibility of receiving the same citation (particularly in the same OSHA Region) is precluded.

Another note on citations: A particular PSM practice might be cited at one covered facility and not cited at another. The subjective opinion of the Compliance Safety and Health Officer (CSHO) and the reason for the inspection are important aspects in how citations are issued at a given site or in a given situation. The overall relationship between the company or site and OSHA (as well as other state and federal regulators) is also an important factor. Therefore, reacting to a specific citation might not be the best course of action. However, examining the entire body of citation information does reveal trends that may be valuable.

Based on the OSHA citation data base for the period 5/26/92 through 12/31/99, the following summary of PSM citations by PSM Element is presented at the following link (Click here).

The Citations broken down by Region/State is presented at the following link (Click here).

In examining this data, the following conclusions can be drawn:

Operating Procedures (1398 of 8056 citations) and Mechanical Integrity (1246 of 8056 citations) are still the most cited PSM elements. These two elements still represent 33% of the total citations. This percentage has remained nearly constant since PSM enforcement began.

OSHA Region 4 leads the pack in the number of PSM inspections performed, followed by Region 5, then Region 6. This data has remained nearly constant over the past 5 years.

There is a belief in the industry that OSHA has curtailed inspection activity because of budget cutbacks. The data, at least for PSM, does not support that belief.

In the past 2 weeks, OSHA has made a presentation on the status of PSM citations as part of the API PSM Best Practices Seminar in New Orleans. This presentation, which included both federal and state data through 6/30/01, revealed the following:

The number of PSM inspections has risen to a total of 1,560.

The number of proposed PSM citations has risen to a total of 8,356.

The total of proposed fines has risen to $25.2M.

The average number of PSM inspections is 183/year.

For further information on citations, visit OSHA's website at http://www.osha.gov/oshstats. OSHA's August 2001 presentation from the PSM Best Practices Seminar may be found at http://www.acusafe.com/API_conference/papers/23_Marshall_OSHA.pdf