OSHA 1910.119 PSM Compliance Checklist

Author: Fidelis Associates | Published: 2026-03-02 | Last Updated: 2026-03-02

Meta Description: A practical checklist for verifying compliance with OSHA 1910.119 Process Safety Management requirements across all 14 PSM elements. Free download.

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Definition / Introduction

This checklist provides a structured, element-by-element verification tool for OSHA 29 CFR 1910.119 Process Safety Management compliance. It is designed for plant managers, PSM coordinators, and compliance auditors who need to confirm that each of the 14 PSM elements is implemented, documented, and functioning in practice — not just on paper.

Each section below corresponds to one of the 14 PSM elements. Use the checkbox items as verification points during internal audits, pre-audit preparation, or program self-assessment. Items marked here reflect OSHA requirements and common audit focus areas based on decades of field experience across refineries, chemical plants, and energy facilities.

For a detailed explanation of each element, see The 14 Elements of PSM: A Practitioner's Breakdown.

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1. Employee Participation

• [ ] A written plan of action for employee participation in PSM exists and is current
• [ ] Employees have access to process hazard analyses and process safety information
• [ ] Employees participate in PHA teams, procedure reviews, and incident investigations
• [ ] The participation plan identifies specific mechanisms for employee involvement, not just acknowledgment signatures

2. Process Safety Information (PSI)

• [ ] Safety Data Sheets are available and current for all highly hazardous chemicals in covered processes
• [ ] Process technology documentation includes block flow diagrams, process chemistry, safe operating limits, and consequence data for deviations
• [ ] Equipment design information is complete — P&IDs, equipment data sheets, relief system design bases, electrical classifications, and materials of construction
• [ ] P&IDs reflect as-built conditions, including field modifications and MOC changes
• [ ] PSI is accessible to personnel who need it (operators, maintenance, PHA teams)

3. Process Hazard Analysis (PHA)

• [ ] An initial PHA has been performed for every covered process
• [ ] PHAs use an appropriate methodology (HAZOP, What-If, Checklist, FMEA, Fault Tree, or equivalent)
• [ ] PHA revalidations are completed at least every 5 years
• [ ] PHA team composition includes personnel with expertise in engineering, operations, and the specific process
• [ ] PHA recommendations are tracked to resolution with documented owner, due date, and closure evidence

4. Operating Procedures

• [ ] Written procedures exist for each covered process covering startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following turnaround
• [ ] Procedures include safe operating limits, consequences of deviation, and safety system functions
• [ ] Procedures are reviewed and certified as current and accurate at least annually
• [ ] Field verification confirms that procedures match actual operating practices
• [ ] Procedures are accessible to operators in the control room and field

5. Training

• [ ] Initial training has been completed for all employees operating covered processes
• [ ] Training covers process overview, operating procedures, safety and health hazards, emergency operations, and safe work practices
• [ ] Refresher training is conducted at least every 3 years
• [ ] Training records document the employee identity, date of training, and means used to verify comprehension
• [ ] Competency verification demonstrates understanding, not just attendance

6. Contractors

• [ ] Contractor safety performance is evaluated during pre-qualification
• [ ] Contractors are informed of known potential fire, explosion, or toxic release hazards
• [ ] The employer's emergency action plan has been explained to contractor employees
• [ ] Contractor employees are trained on safe work practices applicable to the facility
• [ ] A system exists for monitoring contractor performance and documenting injuries and illnesses

7. Pre-Startup Safety Review (PSSR)

• [ ] PSSRs are conducted for all new facilities and modified facilities where the modification requires a change in process safety information
• [ ] PSSR confirms construction and equipment match design specifications
• [ ] PSSR confirms safety, operating, maintenance, and emergency procedures are in place and adequate
• [ ] PSSR confirms PHA recommendations for the new or modified process have been resolved
• [ ] PSSR confirms training of each employee involved in operating the process is complete

8. Mechanical Integrity

• [ ] Written procedures exist for the ongoing maintenance of process equipment (pressure vessels, piping, relief systems, controls, ESD systems, pumps)
• [ ] Maintenance employees are trained on the equipment they maintain
• [ ] Inspection and testing are performed on process equipment at documented frequencies
• [ ] Deficiencies identified during inspections are corrected in a timely manner with documentation
• [ ] Quality assurance is applied to equipment fabrication, installation, and maintenance materials

9. Hot Work Permits

• [ ] A hot work permit system is in place for all hot work on or near covered processes
• [ ] Permits document the date, authorized duration, and object on which hot work is performed
• [ ] Fire prevention and protection measures are verified before work begins
• [ ] Hot work permits are consistently enforced, including during turnarounds and high-activity periods

10. Management of Change (MOC)

• [ ] Written MOC procedures cover changes to process chemicals, technology, equipment, and procedures
• [ ] MOC evaluations address the technical basis for the change, impact on safety and health, modifications to procedures, training requirements, and authorization
• [ ] Replacement-in-kind criteria are clearly defined and documented
• [ ] Temporary changes have defined time limits and are closed out through the MOC process
• [ ] MOC close-out includes PSSR (if required), procedure updates, training, and PSI updates

11. Incident Investigation

• [ ] Investigations are initiated within 48 hours of an incident that resulted in, or could reasonably have resulted in, a catastrophic release
• [ ] Investigation teams include at least one person knowledgeable in the process and a contract employee if contractor work was involved
• [ ] Investigation reports document the date, description, contributing factors, and recommendations
• [ ] Reports are reviewed with affected personnel and made available for future reference
• [ ] Investigation reports are retained for at least 5 years

12. Emergency Planning and Response

• [ ] An emergency action plan is established in accordance with 29 CFR 1910.38
• [ ] The plan addresses handling of small releases as well as large-scale events
• [ ] Evacuation routes, alarm systems, and assembly points are defined and communicated
• [ ] The plan is coordinated with local emergency responders
• [ ] Emergency drills are conducted regularly and include realistic scenario exercises

13. Compliance Audits

• [ ] Compliance audits are conducted at least every 3 years
• [ ] Audits evaluate compliance with all 14 PSM elements
• [ ] At least one audit team member is knowledgeable in the process being audited
• [ ] Audit findings are documented with an appropriate response determined and recorded
• [ ] Deficiency corrections are verified and documented, not just acknowledged

14. Trade Secrets

• [ ] Process safety information is made available to employees and their representatives regardless of trade secret claims
• [ ] Confidentiality agreements, if used, do not restrict access to information needed for PSM compliance
• [ ] PHA participants, incident investigators, and emergency responders have access to all necessary process safety information
• [ ] No trade secret claim prevents employees from understanding the hazards of the process they operate

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Key Takeaways

• Compliance with OSHA 1910.119 requires documented, verifiable implementation across all 14 elements — not just the existence of written programs.
• The most commonly cited deficiencies involve gaps between documentation and field practice, particularly in PSI accuracy, PHA follow-through, procedure currency, and mechanical integrity.
• PSSR, MOC, and incident investigation are the elements where close-out and follow-through failures are most frequently found.
• This checklist should be used alongside field verification, not as a substitute for it.
• Regular internal audits using structured checklists significantly reduce the risk of findings during OSHA inspections.

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Assess Your Program

Use this checklist as a starting point, then benchmark your program with a FidelisCheck PSM assessment for a scored evaluation across all 14 elements.

Start Free PSM Assessment →

For a comprehensive, expert-led compliance evaluation, FidelisGap provides on-site diagnostics with prioritized corrective actions.

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Related Resources

• What is Process Safety Management? A Complete Guide — The pillar guide covering PSM scope, applicability, and program fundamentals.
• The 14 Elements of PSM: A Practitioner's Breakdown — Detailed explanation of each PSM element with common implementation gaps.
• How to Conduct a Process Hazard Analysis (PHA) — Step-by-step PHA methodology guide.
• Management of Change (MOC): Best Practices for Industrial Operations — MOC implementation best practices.

Frequently Asked Questions

How should a facility use this master PSM compliance checklist? This checklist is designed as a structured self-assessment and pre-audit preparation tool — not as a substitute for a formal compliance audit. Work through each of the 14 element sections systematically, verifying each item through a combination of document review and field observation. For each unchecked item, document the specific gap and assign a corrective action owner. The most effective approach is to use this checklist quarterly between formal three-year compliance audits (required by 29 CFR 1910.119(o)) to identify and correct deficiencies before they become audit findings.

What are the most common mistakes when preparing for a PSM compliance audit? The most common preparation mistakes are relying solely on document review without field verification, focusing on the elements that are easiest to demonstrate (like training records) while neglecting elements that require field observation (like mechanical integrity and operating procedure currency), and assuming that closed corrective actions from the previous audit are still effective. Auditors will verify whether procedures match actual field practices, whether PHA recommendations were genuinely resolved, and whether MOC close-out was completed — not just whether paperwork exists. Start preparation by reviewing all findings from the previous two audits and verifying that corrective actions remain in place and effective.

What is the best approach to PSM self-assessment for continuous improvement? Best practice is to conduct element-level self-assessments on a rolling basis throughout the three-year audit cycle, rather than attempting to evaluate all 14 elements at once. Assign element ownership to qualified personnel, conduct field-verified assessments on a rotating schedule, and track findings through a formal corrective action system. Self-assessments should include operator and technician interviews — not just management perspectives — because the gap between documented programs and actual field practices is where most compliance deficiencies are found.

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Fidelis Associates provides PSM compliance consulting and assessment services through FidelisCore and FidelisGap. Our team brings 40+ years of combined experience across major operators including Chevron, Valero, and Shell.

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