1910.119(e)(3): What a Process Hazard Analysis Must Cover
Employers' process hazard analysis must address the process hazards, any previous incident with likely catastrophic potential, engineering and administrative controls and how they relate, and the consequences of control failure. It must also cover facility siting, human factors, and a qualitative evaluation of possible safety and health effects of control failure on employees.
Key takeaways
- 1910.119(e)(3) is part of OSHA's general industry standards (29 CFR Part 1910, Subpart H).
- OSHA cited it 77 times in the last 3 years, in 47 inspections, with $731,687 in current penalties.
- 1 death is linked to inspections that cited this rule.
- Most citations: OH (15), PA (9), WI (5).
- Related part: 1910.119(e) Process hazard analysis (165 citations).
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In this article
What this rule covers
29 CFR 1910.119(e)(3) is one requirement inside 1910.119 Process safety management of highly hazardous chemicals, an OSHA general industry standard (Part 1910, Subpart H). It includes 7 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
(3) The process hazard analysis shall address: 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
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)(3).
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…
Where and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 8 |
| 2024 | 18 |
| 2025 | 31 |
| 2026 | 20 |
Top states: OH (15), PA (9), WI (5), NC (5), NJ (4)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| ACCURATE ENERGETIC SYSTEMS, LLC | MC EWEN, TN | $280,000 |
| AMERICAN NITRILE OPERATIONS, LLC. | GROVE CITY, OH | $49,650 |
| HORNADY MANUFACTURING | ALDA, NE | $23,000 |
| VANDEMARK CHEMICAL, INC. | LOCKPORT, NY | $22,500 |
| THE SHERWIN-WILLIAMS COMPANY | GARLAND, TX | $19,358 |
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A 5-minute crew talk on 1910.119(e)(3), plus alerts when this rule changes. Free.
OSHA interpretation letters
- 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)
- Steps for updating and revalidating a Process Hazard Analysis (PHA). (1998-01-22)
Related parts of this rule
- 1910.119(e) Process hazard analysis 165 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
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Frequently asked questions
What must a PHA address?
Process hazards, previous incidents with catastrophic potential, controls, consequences of control failure, facility siting, human factors, and possible effects of control failure on employees.
Does a PHA consider past incidents?
Yes. It must identify any previous incident which had a likely potential for catastrophic consequences.
What detection methods are mentioned?
Process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors, are given as acceptable examples.
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.