The word “adjacent” may be small in terms of letters used to spell it, but it has an enormous impact on the world of process safety. Both OSHA’s Process Safety Standard (1910.119) and EPA’s Risk Management Plan (Part 68) use the word “adjacent.” Here is how Webster defines “adjacent”
adjacent (adjective): not distant: nearby
It is important to note that in the Hot Work Permit element, OSHA and EPA use the word “near” rather than “adjacent.”
In my training courses, I use the phrase “on, in, or adjacent to a covered process” when discussing matters that could impact a covered process. For example,
- work could be IN the battery limits of the covered process and NOT ON the actual physical process, and this work has the potential to impact the process
- work could be ADJACENT to the covered process, but that work COULD IMPACT the covered process (i.e. crane work, electrical work, etc.)
Although OSHA’s latest PSM LOI did not define or quantify the words “adjacent” or “near,” it is imperative that each facility do so, NOT for OSHA compliance reasons but to PROTECT the covered process.
Here is OSHA’s and EPA’s use of the term: