Process Safety Management (PSM) is OSHA’s performance-based regulatory framework for facilities that handle highly hazardous chemicals above specified threshold quantities. Governed by 29 CFR 1910.119, PSM requires systematic management of 14 interconnected elements — from Process Hazard Analysis (PHA) to Mechanical Integrity to Emergency Planning. Non-compliance can result in penalties exceeding $165,000 per violation in 2026.
Porritt Inc. provides AI-powered PSM consulting and compliance services for refineries, chemical plants, and industrial facilities. Based in Salt Lake City, Utah, we serve clients across the Intermountain West and nationwide.
The 14 Elements of OSHA PSM
OSHA’s PSM standard requires facilities to develop, implement, and maintain programs covering all 14 elements. Each element is interconnected — gaps in one area create vulnerabilities across the entire program.
1. Process Safety Information (PSI)
PSI is the foundation of the entire PSM program. It includes chemical hazard data (Safety Data Sheets, toxicology), technology information (process chemistry, operating limits, consequences of deviation), and equipment information (materials of construction, piping specifications, design codes, RAGAGEP compliance documentation). All PSI must be kept current — this is where RAGAGEP compliance reviews directly apply.
2. Process Hazard Analysis (PHA)
PHAs must be conducted for all covered processes and revalidated every 5 years. Methodologies include HAZOP, What-If, FMEA, fault tree analysis, and checklist reviews. AI tools are now being used to pre-screen PHA nodes and accelerate deviation identification, though human-led multi-disciplinary PHA teams remain the regulatory standard.
3. Operating Procedures
Written operating procedures must address normal operations, temporary operations, emergency shutdown, startup/shutdown sequences, and emergency operations. Procedures must be reviewed annually and certified as current. This is a frequent citation area in OSHA PSM inspections.
4. Training
All employees involved in operating a covered process must be trained in applicable operating procedures. Initial training and refresher training (every 3 years minimum) must be documented. Contractors performing maintenance on covered processes require equivalent training documentation.
5. Contractors
Employers must evaluate contractor safety performance before selecting contractors for work on or adjacent to covered processes. Contractors must be informed of known potential fire, explosion, and toxic release hazards. Contractor training and safety record documentation must be maintained.
6. Pre-Startup Safety Review (PSSR)
Before startup of a new or modified covered process, a PSSR must confirm that equipment is installed per design, procedures are in place, a PHA has been performed (for new processes), and training has been completed. PSSR documentation must be retained.
7. Mechanical Integrity (MI)
MI is one of the most technically complex PSM elements. It requires written procedures for maintaining ongoing integrity of pressure vessels (API 510), piping systems (API 570), pressure relief devices, emergency shutdown systems, controls, and pumps. Inspection frequencies and acceptance criteria must comply with current RAGAGEP. This is the element most commonly cited in OSHA enforcement actions following major incidents.
8. Hot Work Permit
A hot work permit system must be in place for welding, cutting, and other ignition-source activities in or near covered process areas. Permits must document fire prevention and protection measures.
9. Management of Change (MOC)
All changes to process chemicals, technology, equipment, and procedures (except replacements-in-kind) require a formal MOC process. MOC must address technical basis, impact on safety and health, modifications to PSI and procedures, training requirements, and authorization requirements. Unauthorized or undocumented changes are a leading cause of PSM incidents.
10. Incident Investigation
Facilities must investigate every incident that resulted in or could reasonably have resulted in a catastrophic release of highly hazardous chemicals. Investigations must begin within 48 hours, be conducted by a team including at least one person knowledgeable in the process, and result in a written report with root cause analysis and recommendations.
11. Emergency Planning and Response
Facilities must establish and implement an emergency action plan covering detection, notification, evacuation, and emergency response for potential releases. This must be coordinated with local emergency response agencies under OSHA 1910.38 and EPA RMP requirements.
12. Compliance Audits
Employers must certify that they have evaluated compliance with PSM provisions at least every 3 years. Audits must be conducted by at least one person knowledgeable in the process. A report of findings must be developed and deficiencies addressed in a timely manner.
13. Trade Secrets
Employers must make all necessary information available to employees involved in compiling PSI, conducting PHAs, developing operating procedures, incident investigations, emergency planning, compliance audits, and OSHA inspections — regardless of trade secret status. Confidentiality agreements may be required.
14. Employee Participation
Employers must develop a written plan of action regarding the implementation of employee participation. Employees and their representatives must be consulted on the conduct and development of PHAs and other PSM elements. Access to PSI must be provided to employees.
How Porritt Inc. Supports Your PSM Program
Porritt Inc. combines deep PSM engineering expertise with AI-powered tools to deliver faster, more comprehensive compliance support. Our NORMEX Standards AI platform accelerates RAGAGEP gap analysis from weeks to days. Our NEXUS Compliance AI tracks PSM element status across your facility in real time.
We work with refineries, chemical plants, and modular processing facilities across Utah and the United States, providing:
- PSM Program Development — Build a defensible, audit-ready PSM program from the ground up
- RAGAGEP Compliance Reviews — AI-assisted gap analysis against current API, ASME, and NFPA standards
- Triennial PSM Audits — Independent third-party compliance audits meeting 1910.119(o) requirements
- PHA Facilitation — HAZOP, What-If, and LOPA studies for covered processes
- MI Program Development — Inspection plans, acceptance criteria, and RAGAGEP alignment
- MOC System Implementation — Workflow design, training, and documentation systems