In 1995, OSHA issued more citations for mechanical integrity than for any other PSM element. In 1996, the mechanical integrity was a close second to operating procedures and just ahead of process hazards analysis. The May 1997 Chemical Process Safety Report [6] quoted Mr. John Miles, the Director of OSHA's Compliance Programs, as saying, "Operating procedures and mechanical integrity are two of the more important parts of the standard, and our people are looking for those violations."

The Chemical Process Report reviewed the 1296 citations issued under the OSHA Process Safety Management Standard in 1996. Oddly enough, chemical manufacturing plants were not the usual target of the citations. The analysis showed more that 75 percent of the companies cited for alleged PSM violations were not from the areas (or Standard Industrial Classifications Codes-SIC Codes) assigned to chemical producers or chemical users. Operating Procedures, Process Hazards Analysis, and the Mechanical Integrity elements of the standard had the highest number of citations in 1996.

The mechanical integrity element received 211 citations. Sub-section j-2 ("establish and implement written procedures to maintain mechanical integrity of process equipment") received the highest number (95) of citations followed by 39 citations in subsection j-4-i ("perform inspection and testing on process equipment within that element"). Having readily available procedures is one of the main focal points for OSHA. Even if you are doing the right things in regard to mechanical integrity, if you don't have a written procedure, you can expect citations during...