1910.119(e)(1): Initial Process Hazard Analysis
Employers must perform an initial process hazard analysis on each covered process that fits the process's complexity and identifies, evaluates and controls its hazards. They must set and document a priority order based on factors like hazard extent, number of affected workers, process age and operating history, and all initial analyses had to be completed by May 26, 1997.
Key takeaways
- 1910.119(e)(1) is part of OSHA's general industry standards (29 CFR Part 1910, Subpart H).
- OSHA cited it 43 times in the last 3 years, in 43 inspections, with $277,384 in current penalties.
- 1 death is linked to inspections that cited this rule.
- Most citations: IL (4), TX (4), MI (4).
- Related part: 1910.119(e) Process hazard analysis (165 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1910.119(e)(1) is one requirement inside 1910.119 Process safety management of highly hazardous chemicals, an OSHA general industry standard (Part 1910, Subpart H). It includes 5 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
(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: 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.
Source: eCFR, text current as of 2026-10-15. Read all of 1910.119.
Injuries linked to this rule
1 death is linked to inspections where OSHA cited 1910.119(e)(1).
At 12:00 p.m. on May 1, 2024, an explosion occurred at a production line, where multiple employees were working. Four employees were hospitalized to treat burnsand toxic gas inhalation, while six others were treated on-site without hospitalization for similar injuries.
Where and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 2 |
| 2024 | 16 |
| 2025 | 15 |
| 2026 | 10 |
Top states: IL (4), TX (4), MI (4), NJ (4), OH (3)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| ACCURATE ENERGETIC SYSTEMS, LLC | MC EWEN, TN | $70,000 |
| ULTIUM CELLS LLC | WARREN, OH | $16,131 |
| OLIN WINCHESTER, LLC | EAST ALTON, IL | $15,625 |
| SOLVCHEM, INC. | PEARLAND, TX | $14,895 |
| SPRAY PRODUCTS CORPORATION | PLYMOUTH MEETING, PA | $14,518 |
Free toolbox talk
A 5-minute crew talk on 1910.119(e)(1), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Clarification of requirements for storage and use of flammable and/or combustible liquids. (2007-12-26)
Related parts of this rule
- 1910.119(e) Process hazard analysis 165 citations
- 1910.119(e)(3) 77 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, appropriate to its complexity.
How is the order of analyses decided?
By a documented rationale including extent of hazards, number of potentially affected employees, age of the process and operating history.
When did all initial analyses have to be done?
By May 26, 1997.
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.
