SafeGuard PSM
SafeGuard PSMPSM Consulting
OSHA 1910.119
OSHA 1910.119Free PSM Resource
M&A Process Safety Due Diligence

You're buying more than a facility.
You're buying its PSM liability.

Fast-turnaround process safety gap assessment for acquisitions, mid-construction ownership transfers, and PE firm investments in PSM-covered facilities. Written report. Prioritized action plan. Fixed fee.

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PSM gaps don't appear in a standard facility audit.

A standard environmental and safety due diligence review checks OSHA recordable rates, environmental compliance, and general safety programs. It does not assess whether a PSM program is actually functional — whether PHAs are current, whether mechanical integrity records are complete, whether MOC procedures are being followed, whether the SIS has ever been proof-tested.

PSM deficiencies are invisible until they produce a citation, a process safety incident, or a failed audit. If you acquire a facility with a broken PSM program, you own the liability from day one — including liability for conditions that predated your ownership.

This is a niche with almost no specialized service providers. We've built our careers in process safety. We know exactly what to look for.

Who This Is For

Private equity firms acquiring PSM-covered chemical, refining, or gas processing facilities. Strategic buyers evaluating facilities mid-construction. Companies receiving project ownership transfer from an EPC. New operators inheriting a facility from a prior owner who may not have maintained the PSM program.

Typical Timeline

Document review: 3–5 days. On-site visit: 1–2 days. Written report and briefing: within 10 business days of document receipt. We can work within M&A timeline constraints — contact us to discuss your closing schedule.

Two very different situations, same urgent need.

Acquiring an Operating Facility

You're buying a refinery, chemical plant, or gas processing facility that's been running under PSM. The seller's data room has a PSM program document. You need to know if that program is real.

  • Is the PHA current? When was it last revalidated?
  • Are MI inspection records complete and on schedule?
  • Has MOC been used consistently, or is it a paper program?
  • Are process safety incidents being properly investigated?
  • What's the OSHA inspection history and open citation status?
  • What will it cost to bring the program to defensible compliance?

Taking Ownership Mid-Construction

Project ownership is transferring before the facility starts up. You're inheriting a capital project in progress — along with whatever PSM gaps have accumulated during construction.

  • Is there a construction-phase MOC program, and is it being used?
  • Are the P&IDs current with field-installed conditions?
  • Has a HAZOP been completed? Are action items tracked?
  • What PSM deliverables are required before startup?
  • Is there a PSSR plan, and who has authority to sign it?
  • What's missing from the PSM program that needs to be built?

Every PSM element. No gaps in the review.

We assess all 14 PSM elements against the standard, current OSHA enforcement posture, and facility-specific conditions. The result is a written gap register with severity ratings and a prioritized remediation roadmap.

PSM ElementWhat We AssessCommon Gaps Found
Process Safety InformationP&ID currency, equipment specs, chemical inventory documentationOutdated P&IDs, missing MAWP documentation, incomplete chemical hazard data
Process Hazard AnalysisPHA completeness, revalidation schedule, action item closureOverdue revalidation, action items closed without documentation, wrong methodology used
Operating ProceduresCompleteness, accuracy relative to current process, certification datesProcedures describing equipment that no longer exists; unsigned, undated
TrainingInitial training records, refresher schedule, contractor trainingMissing training records, no documented refresher program
ContractorsContractor safety program evaluation, periodic reviewsNo contractor safety program on file; host employer responsibilities not documented
Pre-Startup Safety ReviewPSSR completion for past modifications, documentation qualityMOC-triggered PSSRs missing; signed by unqualified personnel
Mechanical IntegrityInspection schedule currency, overdue inspections, QA/QC recordsInspection backlog, no thickness measurement baseline, undocumented RBI decisions
Hot Work PermitPermit program, records retention, confined space overlapMissing permit records; no hot work procedure for off-hours work
Management of ChangeMOC program rigor, change log completeness, P&ID markupUndocumented process changes; MOC used for admin changes but not process ones
Incident InvestigationInvestigation quality, root cause methodology, recommendation trackingNear-misses not investigated; corrective actions not closed
Emergency PlanningLEPC coordination, emergency response plan currency, drill recordsERP not updated since last process change; no drill documentation
Compliance AuditsAudit frequency, team qualification, finding resolutionAudits done internally with no qualified team; findings not formally closed
Trade Secrets / Employee ParticipationEmployee access to PSM information, consultation documentationNo documented employee consultation process

A written assessment you can act on immediately.

Not a checklist. Not a traffic-light dashboard. A substantive written report that tells you what you have, what you don't, and what it will take to fix it.

01

14-Element Gap Register

Every finding documented with the specific PSM standard requirement, current facility condition, severity rating (critical/significant/minor), and potential enforcement exposure.

02

Prioritized Remediation Roadmap

Findings ranked by risk and regulatory exposure. Short-term actions required before startup or ownership transfer versus longer-term program improvements.

03

Cost-to-Remediate Estimate

Rough order-of-magnitude resource estimate for closing the identified gaps — useful for purchase price negotiation, escrow structuring, or post-close budgeting.

04

Executive Briefing

One-hour call with acquiring team leadership to walk through findings, answer questions, and discuss remediation options. Available in person for complex situations.

05

Ongoing Support (Optional)

Following the assessment, we can remain engaged as the remediation PSM consultant — building missing program elements, completing overdue PHAs, or providing PSM On-Call support during the integration period.

Closing soon? Let's talk this week.

We work within M&A timelines. Tell us your closing date and we'll tell you what's possible. Most assessments can be scoped, scheduled, and delivered within 10–15 business days.

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