1910.119(e): Process Hazard Analysis
Employers covered by process safety management must perform an initial process hazard analysis suited to the complexity of the process that identifies, evaluates and controls its hazards, and document the priority order for doing them. The analysis must use one or more methods such as What-If, Checklist, HAZOP, FMEA, Fault Tree Analysis or an appropriate equivalent.
Key takeaways
- 1910.119(e) is part of OSHA's general industry standards (29 CFR Part 1910, Subpart H).
- OSHA cited it 165 times in the last 3 years, in 112 inspections, with $1,444,227 in current penalties.
- 2 deaths are linked to inspections that cited this rule.
- Most citations: OH (24), PA (16), IL (11).
- Related part: 1910.119(e)(3) (77 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1910.119(e) ("Process hazard analysis") is one requirement inside 1910.119 Process safety management of highly hazardous chemicals, an OSHA general industry standard (Part 1910, Subpart H). It includes 26 sub-paragraphs. The official text below is copied word for word from the Electronic Code of Federal Regulations (eCFR). The numbers, injury cases and training on this page show how OSHA enforces it on real job sites.
Official text
(e) Process hazard analysis. 165 citations
(1) The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. The process hazard analysis shall be conducted as soon as possible, but not later than the following schedule: Open (e)(1) 43 citations
(i) No less than 25 percent of the initial process hazards analyses shall be completed by May 26, 1994;
(ii) No less than 50 percent of the initial process hazards analyses shall be completed by May 26, 1995;
(iii) No less than 75 percent of the initial process hazards analyses shall be completed by May 26, 1996;
(iv) All initial process hazards analyses shall be completed by May 26, 1997. 1 citations
(v) Process hazards analyses completed after May 26, 1987 which meet the requirements of this paragraph are acceptable as initial process hazards analyses. These process hazard analyses shall be updated and revalidated, based on their completion date, in accordance with paragraph (e)(6) of this section.
(2) The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed. 1 citations
(i) What-If;
(ii) Checklist;
(iii) What-If/Checklist;
(iv) Hazard and Operability Study (HAZOP):
(v) Failure Mode and Effects Analysis (FMEA);
(vi) Fault Tree Analysis; or
(vii) An appropriate equivalent methodology.
(3) The process hazard analysis shall address: Open (e)(3) 77 citations
(i) The hazards of the process; Open (e)(3)(i) 20 citations
(ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace; 2 citations
(iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.); Open (e)(3)(iii) 14 citations
(iv) Consequences of failure of engineering and administrative controls; Open (e)(3)(iv) 10 citations
(v) Facility siting; Open (e)(3)(v) 10 citations
(vi) Human factors; and Open (e)(3)(vi) 15 citations
(vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. 4 citations
(4) The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used. Open (e)(4) 2 citations
(5) The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. Open (e)(5) 23 citations
(6) At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process. Open (e)(6) 15 citations
(7) Employers shall retain process hazards analyses and updates or revalidations for each process covered by this section, as well as the documented resolution of recommendations described in paragraph (e)(5) of this section for the life of the process. 4 citations
Source: eCFR, text current as of 2026-10-15. Read all of 1910.119.
Injuries linked to this rule
2 deaths are linked to inspections where OSHA cited 1910.119(e).
At 8:15 a.m. on July 3, 2024, Employee #1, Employee #2, and Employee #3 were inserting smoke composition material into aluminum pyrotechnic vessels when an explosion occurred. Employee #1 was fatally injured. Employee #2 was hospitalized, and Employee #3 sustained non-hospitalized injuries. The incident involved…
Full case list with employer, penalty, filters and download is part of OSHA Data (Purple Belt).
Unlock with Purple BeltWhere and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 13 |
| 2024 | 53 |
| 2025 | 58 |
| 2026 | 41 |
Top states: OH (24), PA (16), IL (11), VA (11), MI (9)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| ACCURATE ENERGETIC SYSTEMS, LLC | MC EWEN, TN | $490,000 |
| INTERTAPE POLYMER CORP | MARYSVILLE, MI | $50,400 |
| AMERICAN NITRILE OPERATIONS, LLC. | GROVE CITY, OH | $49,650 |
| SPRAY PRODUCTS CORPORATION | PLYMOUTH MEETING, PA | $29,036 |
| OLYMPIA FOOD INDUSTRIES INC. | FRANKLIN PARK, IL | $24,000 |
Free toolbox talk
A 5-minute crew talk on 1910.119(e), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Discretion in Enforcement when Considering an Employer's Good Faith Efforts During the Coronavirus Disease 2019 (COVID-19) Pandemic (2020-04-16)
- Updates to PHA Extended Shutdown Facility (2019-09-20)
- "Applicability of the PSM standard's mechanical intergrity requirements to refinery structures." (2010-02-01)
- Clarification of requirements for storage and use of flammable and/or combustible liquids. (2007-12-26)
- PSM compliance for ammonia refrigeration systems. (2006-07-12)
- Documentation methods used to comply with the qualitative evaluation of a range of possible safety/health effects of "failure of controls" requirement of the PSM standard. (2005-02-01)
- Process hazard analysis facilitator's training requirements. (2001-11-19)
- Applicability of the PSM standard to a flammable liquid manufacturing process. (1999-07-09)
- Steps for updating and revalidating a Process Hazard Analysis (PHA). (1998-01-22)
Related parts of this rule
- 1910.119(e)(3) 77 citations
- 1910.119(e)(1) 43 citations
- 1910.119(e)(5) 23 citations
- 1910.119(e)(3)(i) 20 citations
- 1910.119(e)(6) 15 citations
- 1910.119(e)(3)(vi) 15 citations
- 1910.119(e)(3)(iii) 14 citations
- 1910.119(e)(3)(v) 10 citations
- 1910.119(e)(3)(iv) 10 citations
- 1910.119(e)(4) 2 citations
Get your crew competent
Trainers on Black Belt Safety: Marc Harvey, Dana Reyes
Trainers and suppliers: feature your business on this rule for $25/month.
Frequently asked questions
What must a process hazard analysis do?
Identify, evaluate and control the hazards involved in the process.
What methods can be used?
What-If, Checklist, What-If/Checklist, HAZOP, FMEA, Fault Tree Analysis, or an appropriate equivalent methodology.
How is the order of analyses chosen?
By a documented rationale that considers the extent of hazards, number of affected employees, age of the process and operating history.
About this page
Sources
- 29 CFR 1910.119 (eCFR), text current as of 2026-10-15
- U.S. Department of Labor enforcement data: OSHA inspections, citations and accident records, copied nightly; data as of 2026-10-21
3-year window. Federal OSHA only; state-plan rules are not counted. Plain-language text is a summary, not legal advice; the official text controls. Black Belt Safety is not part of OSHA or the Department of Labor.
