Audit Your Process Safety Information: PSM Element 2 Checklist
Audit Your Process Safety Information: PSM Element 2 Checklist
Author: Fidelis Associates | Published: 2026-03-03 | Last Updated: 2026-03-03
Meta Description: Checklist for OSHA 1910.119(d) Process Safety Information — verify chemical hazard data, process technology documentation, and equipment design records.
OSHA Reference
Under OSHA's Process Safety Management standard 29 CFR 1910.119(d), employers must compile written Process Safety Information before conducting a Process Hazard Analysis (PHA). PSI must include information on:
- The hazards of the chemicals in the process
- The technology of the process
- The equipment in the process
This information must be accurate, complete, and accessible to those who need it.
Fidelis Insight
PSI is more than a regulatory requirement — it's the knowledge base that drives safe, reliable operations. At Fidelis, we see PSI as the bridge between engineering design, day-to-day operations, and long-term asset integrity.
When PSI is done poorly, it becomes a static binder that no one uses. When done well, it becomes a living system that:
- Strengthens Hazard Analyses: A PHA is only as good as the information it's built on. Outdated P&IDs, missing chemical data, or vague operating limits undermine the process and can leave critical hazards unrecognized.
- Guides Operators in the Field: Operators need to know the safe upper and lower limits for temperature, pressure, or flow — and what happens if those limits are exceeded.
- Anchors Mechanical Integrity: Relief devices, materials of construction, and codes are part of PSI because equipment can only be inspected and maintained correctly if its design basis is known and accessible.
- Connects to Change Management: Every modification to a process depends on PSI to define what is changing, what the risks are, and how the system should function afterward.
- Builds Institutional Knowledge: Employees come and go, but PSI preserves what the organization knows about its processes. Accurate PSI reduces reliance on "tribal knowledge."
At Fidelis Associates, we help organizations go beyond assembling documents. We work with leaders and teams to make PSI organized, accessible, and actionable — so it becomes the foundation of safe decision-making at every level of the plant.
Common Gaps We See
- ⚠ P&IDs are outdated or do not reflect as-built conditions
- ⚠ Equipment datasheets missing or incomplete, particularly for legacy equipment
- ⚠ Chemical reactivity and incompatibility data not documented with site-specific scenarios
- ⚠ Safe operating limits defined but consequences of deviation not evaluated
- ⚠ Relief and vent system design bases undocumented or out of date
- ⚠ PSI exists but is not accessible to those who need it (operators, contractors, PHA teams)
- ⚠ No version control — multiple uncontrolled copies in circulation
Best Practices Checklist
Hazards of Chemicals
- [ ] SDS and permissible exposure limits for all covered chemicals
- [ ] Chemical reactivity and incompatibility documented with site-specific scenarios
- [ ] Toxicity, flammability, and corrosivity data available
- [ ] Hazards of inadvertent mixing evaluated
- [ ] Physical properties recorded (flash point, vapor pressure, boiling point, etc.)
Technology of the Process
- [ ] Block or process flow diagrams are accurate and current
- [ ] Maximum intended inventory defined and documented
- [ ] Safe upper/lower operating limits (temperature, pressure, flow, composition) specified
- [ ] Consequences of exceeding limits evaluated and communicated
Equipment in the Process
- [ ] P&IDs up to date and verified in the field
- [ ] Materials of construction identified for vessels, piping, and critical components
- [ ] Relief and vent system design basis documented
- [ ] Electrical classification drawings available and accurate
- [ ] Applicable design codes and standards listed and current
- [ ] Safety systems (detection, suppression, interlocks) documented
Program Management
- [ ] PSI is organized and controlled (with version control)
- [ ] Accessible to engineers, operators, and contractors who need it
- [ ] Reviewed and updated routinely, especially after changes (MOC)
Scoring Tip
- 15–18 checks = Strong PSI program
- 9–14 checks = Needs improvement
- 0–8 checks = Immediate action required
Practical Use
PSI is only valuable if it's used. Treat PSI as a living resource that informs decisions at every stage of a facility's lifecycle:
- Before a PHA — Verify that PSI is current and complete. Outdated or missing information leads to incomplete hazard analysis.
- During Operations — Use PSI to define control limits, alarm setpoints, and operator response actions.
- For Mechanical Integrity — Reference PSI to ensure inspections, tests, and repairs maintain equipment to its original design basis.
- In Management of Change (MOC) — Evaluate proposed changes against PSI. If the PSI doesn't reflect the current plant, update it before approving modifications.
- For Emergency Response — Ensure responders know chemical hazards, reactivity concerns, and physical properties that drive protective actions.
- During Audits & Reviews — Treat PSI as an audit-ready element. Gaps are common in drawings, relief system documentation, or chemical incompatibility data.
PSI should never be a binder on a shelf. It must be integrated into daily operations, project planning, and decision-making.
Key Takeaways
- PSI is the foundation of every other PSM element — inaccurate PSI cascades errors into PHA, procedures, training, and MI.
- The three required categories (chemical hazards, process technology, equipment) must all be complete and current.
- P&ID accuracy is one of the most commonly cited deficiencies in OSHA inspections.
- PSI must be accessible and actionable, not just archived.
- Regular reviews — especially after MOC — are essential to maintaining PSI integrity.
Assess Your Program
Use this checklist as a starting point, then benchmark your program with a FidelisCheck PSM assessment.
Related Resources
- What is Process Safety Management? A Complete Guide
- The 14 Elements of PSM: A Practitioner's Breakdown
- OSHA 1910.119 PSM Compliance Checklist
- PSM Element 3: Process Hazard Analysis Checklist
Frequently Asked Questions
What must process safety information include under OSHA PSM? OSHA 29 CFR 1910.119(d) requires PSI to cover three categories: the hazards of chemicals in the process (toxicity, permissible exposure limits, physical data, reactivity data, corrosivity data, and thermal and chemical stability), the technology of the process (block flow or process flow diagrams, process chemistry, maximum intended inventory, safe upper and lower limits, and consequences of deviations), and the equipment in the process (materials of construction, P&IDs, electrical classification, relief system design basis, and applicable design codes). All three categories must be complete before conducting a PHA.
How often must process safety information be updated? OSHA does not prescribe a specific update frequency for PSI under 1910.119(d). However, the standard requires PSI to be accurate and current. In practice, PSI must be updated whenever changes occur through the Management of Change process under 1910.119(l), after any modification that affects process chemistry, equipment, or operating limits. Best practice is to verify PSI accuracy before each PHA revalidation cycle and after every MOC, turnaround, or equipment replacement.
What happens when PSI is incomplete during a process hazard analysis? If PSI is incomplete or inaccurate at the time of a PHA, the hazard analysis cannot be considered adequate under 1910.119(e). OSHA expects the PSI to be compiled before the PHA is conducted. Conducting a PHA with missing chemical data, outdated P&IDs, or undefined operating limits risks overlooking hazards and producing unreliable recommendations. Best practice is to complete a PSI gap assessment and resolve deficiencies before initiating the PHA, rather than attempting to conduct both activities simultaneously.
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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