Process Safety Management (PSM): OSHA Requirements, Training, and Who Needs It (2026)

Safety professionals who’ve spent their careers in general industry or construction often hit a wall the first time they walk into a refinery or chemical plant. The PSM standard is unlike anything else in the OSHA catalog. It’s not a single rule you can read in an afternoon. It’s a system with 14 interlocking elements, each with its own documentation requirements, review cycles, and training obligations. And it applies to some of the most hazardous workplaces in the country.

If you work at or aspire to work at a PSM-covered facility, you need to understand what the standard actually demands, not just that it exists.

What PSM Is and Why OSHA Created It

Process Safety Management under 29 CFR 1910.119 is OSHA’s framework for preventing catastrophic releases of toxic, reactive, flammable, or explosive chemicals. The standard was published in 1992. It came after decades of major process industry disasters: Bhopal in 1984, which killed thousands of people in a single night from a methyl isocyanate release; Pasadena, Texas in 1989, when a polyethylene plant explosion killed 23 workers; and a string of refinery fires and explosions that made clear the industry needed a systematic approach to process risk.

The 2005 Texas City refinery explosion, which killed 15 workers and injured 180, demonstrated that even a PSM-regulated facility could fail catastrophically when its management systems broke down. The explosion became a landmark case in process safety, studied by investigators and referenced in OSHA enforcement for years afterward.

PSM’s core idea is that catastrophic process incidents aren’t accidents. They result from failures in management systems: inadequate hazard analysis, operating procedures that don’t reflect reality, equipment that wasn’t inspected on schedule, or changes to a process that weren’t properly reviewed. The 14 elements of PSM address each of these failure modes directly.

Which Facilities Are Covered

PSM applies to facilities that have any of the 137 highly hazardous chemicals listed in 29 CFR 1910.119 Appendix A at or above their threshold quantities. The list includes chlorine (threshold: 1,500 pounds), anhydrous ammonia (10,000 pounds), hydrogen fluoride (1,000 pounds), and many others. Flammable liquids and gases have a separate threshold of 10,000 pounds for processes that are not covered by the specific chemical list.

The industries most commonly covered include petroleum refining, chemical and petrochemical manufacturing, pharmaceutical production, natural gas processing plants, and pulp and paper mills that use covered chemicals. Water treatment facilities that use chlorine above threshold quantities are also frequently covered.

Several categories of processes are exempt. Retail facilities, hydrocarbon fuels used solely for workplace consumption (like a gas station), oil and gas well drilling and servicing operations, and normally unoccupied remote facilities all fall outside the standard. But the exemptions are narrower than facilities often assume, and OSHA has consistently interpreted coverage expansively when chemicals are present at threshold levels.

The 14 PSM Elements

The 14 elements function as a system. Weaknesses in one area create vulnerabilities in others. A facility with excellent operating procedures but a failing mechanical integrity program is still a serious accident risk.

Process Safety Information requires that facilities compile and maintain written information about the hazardous chemicals in the process, the technology of the process, and the equipment used. This means chemical properties, reactivity data, process design parameters, equipment specs, and piping and instrumentation diagrams. If the documentation doesn’t exist or isn’t current, everything downstream from it is compromised.

Process Hazard Analysis (PHA) is the structured review of hazards associated with the covered process. PHAs must be revalidated every five years. HAZOP (Hazard and Operability Study), What-If analysis, and failure mode and effects analysis (FMEA) are the most common methodologies. The PHA team must include workers who have experience with the process, not just engineers and managers.

Operating Procedures must cover each operating phase: startup, normal operations, temporary operations, emergency shutdown, and restart. They must reflect actual practice. An operating procedure that describes how the process should work in theory, while workers follow a different actual sequence, is a PSM violation and a serious hazard.

Training under PSM requires initial training for each employee operating a covered process, followed by refresher training every three years at minimum. More on this below.

Contractors who work on or near covered processes must be evaluated for safety performance and training, informed of known hazards associated with the work, and trained on the facility’s safety rules. The contractor’s own employees must have documentation of training before they start.

Pre-Startup Safety Review (PSSR) requires a formal review before any new or modified covered process starts up. The PSSR confirms that construction meets design specs, safety procedures are in place, and the PHA recommendations have been addressed.

Mechanical Integrity covers the inspection, testing, and maintenance of process equipment. Vessels, piping systems, relief devices, emergency shutdown systems, controls, and pumps all require documented inspection and testing on defined schedules. Mechanical integrity failures generate more OSHA citations at PSM facilities than almost any other element.

Hot Work Permits are required for any ignition source work, like welding or grinding, in or near a covered process area. The permit system must confirm that flammable and combustible materials have been assessed before work begins.

Management of Change (MOC) requires a formal review process before any change to the process, equipment, procedures, or chemicals. Changes must be evaluated for safety impact before implementation. Workers and contractors affected by the change must receive training before work resumes. MOC failures are a leading cause of process incidents.

Incident Investigation requires that incidents involving releases of highly hazardous chemicals, near-misses included, be investigated promptly. The investigation team must include a person knowledgeable about the process. Findings and recommendations must be addressed on a documented schedule.

Emergency Planning and Response requires coordination with local emergency responders and emergency action plans specific to the covered process.

Compliance Audits must be conducted at least every three years to verify that the PSM program is complete and functioning. The audit findings must be acted on with documented timelines.

Trade Secrets provisions allow employers to protect confidential business information but require that all information necessary for PSM compliance be provided to workers, PHA teams, and incident investigators regardless of trade secret status.

Employee Participation requires that workers be involved in developing and implementing all elements of the PSM program. Workers must have access to all PSM documentation. This element is often treated as a formality. It shouldn’t be.

The Training Requirement in Practice

The training element under 29 CFR 1910.119(g) requires initial training for employees before they operate a covered process. The training must cover operating procedures, safe work practices, emergency operations including shutdown, and safe practices applicable to the employee’s job tasks.

Refresher training is required every three years, and more frequently when operating procedures are revised. The facility must certify in writing that the employee has received and understood the training. Those certifications must be kept.

The content of training is tied to the specific process. A worker at a chlor-alkali plant and a worker at a natural gas processing facility both have PSM training requirements, but the content has to address their actual process hazards. Generic PSM orientation doesn’t satisfy the requirement for process-specific operators.

Contractors get their own training requirement. The host employer must train contractors on the process hazards, the facility’s emergency action procedures, and the facility’s safety rules before they start work. The contractor employer must also verify that its workers have the skills and knowledge to safely perform their assigned work.

The PSM and EPA RMP Overlap

Facilities covered by PSM are often also subject to EPA’s Risk Management Program under 40 CFR Part 68. The two programs use similar chemical lists and threshold quantities but serve different purposes. PSM focuses on worker protection. RMP focuses on off-site consequence analysis and community notification.

EHS professionals at PSM-covered facilities typically manage both simultaneously. RMP requires a worst-case release scenario analysis, a hazard assessment, a prevention program, and an emergency response program. The prevention program for Program 3 processes, the highest tier, mirrors PSM requirements closely. Many elements can be documented once to satisfy both standards.

If you’re working toward an EHS manager role in a PSM-covered industry, understanding both programs is expected. Facilities that treat them as separate compliance exercises typically have more compliance gaps than those that manage them as a single system.

What OSHA Cites Most Often

OSHA’s PSM National Emphasis Program (NEP) directs inspection resources toward refineries, chemical facilities, and other covered industries. Based on OSHA’s inspection data and published enforcement cases, the elements that generate the most citations are mechanical integrity, operating procedures, process hazard analysis, and management of change.

Mechanical integrity citations often involve missing or overdue inspection and testing records for pressure vessels, piping, relief devices, or safety instrumented systems. Operating procedure citations typically involve procedures that haven’t been reviewed on the required schedule or that don’t match current practice. PHA citations appear when five-year revalidations are overdue or when PHA recommendations haven’t been resolved with documented timelines. MOC citations usually involve changes that were made without going through the formal review process.

The pattern in major PSM incidents is consistent with these citation areas. Equipment failures traced to deferred inspections, changes made informally without MOC review, procedures that didn’t reflect how the process actually operated. The citations aren’t bureaucratic nits. They point to the failure modes that precede catastrophic events.

PSM Experience in a Safety Career

Working at PSM-covered facilities adds complexity and pay. Petroleum refining, chemical manufacturing, and natural gas processing consistently appear at the top of Bureau of Labor Statistics compensation data for safety and health occupations. The highest-paying industries for safety professionals are heavily weighted toward PSM-covered sectors.

The reason is straightforward: PSM compliance requires continuous, technically demanding work. PHAs require multi-day facilitation with cross-functional teams. Mechanical integrity programs require coordination with inspection and maintenance. MOC reviews require safety involvement in every process change. That depth of work commands higher salaries and creates real differentiation in the job market.

There’s no shortcut to building PSM knowledge. The Center for Chemical Process Safety (CCPS), part of AIChE, offers training programs and publishes the most widely used technical guidance in the field. The American Society of Safety Professionals (ASSP) offers process safety professional development through its annual conference and specialty programs. Some training providers offer 40-hour PSM coordinator courses that cover the standard systematically.

But the most effective teacher is time at a PSM facility. The gaps between what the standard says and what compliance actually requires only become clear when you’re writing operating procedures for a real process, facilitating a PHA for equipment with 30 years of operational history, or tracking down inspection records for a vessel that was last opened before the current system existed.

If you’re early in your EHS career and have the option to take a role at a PSM-covered facility, take it. The knowledge you build there transfers to every other part of the safety field. The reverse isn’t true.