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:
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1910.119(h)(1) Application. This paragraph applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply to contractors providing incidental services that do not influence process safety, such as janitorial work, food and drink services, laundry, delivery, or other supply services. and § 68.87 Contractors |
Although both standards officially use the word in ONLY their Contractor elements, other elements phrase their requirements differently. For example, let’s look at the Hot Work Permit element(s):
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1910.119(k)(1) The employer shall issue a hot work permit for hot work operations conducted on or near a covered process. and § 68.85 Hot work permit. (a) The owner or operator shall issue a hot work permit for hot work operations conducted on or near a covered process. |
As we can imagine, if we do NOT QUANTIFY these terms, we will have some who will do it for themselves and to their advantage and NOT to the safety of the process. I have seen Hot Work within 10′ of a flammable process without a permit. I wrote this up as a finding in the PSM/RMP audit, and the facility used the fact that they had not QUANTIFIED the distance with respect to the word “near,” thus, who was I to say 10′ was not adequate? So I just wrote up the finding that the 35′ HW fire safe zone was not cleared of all combustibles/flammables; it’s hard to argue that fact. But I think you can begin to see the risks that can creep into our process safety if these terms are NOT OFFICIALLY QUANTIFIED.
So this leads me to how most of my clients have come to define their “battery limits,” which incorporate the terms “adjacent” and “near.” Most will use the Hot Work 35′ fire safety distance. This distance will also cover most Electrical Classification Classes for Low and Moderate Flows/Pressures; so by using this 35′, we are addressing two critically essential elements intended to control ignition sources to the covered process (e.g., flammable processes). Many will also use the 35′ for Toxic processes, as the HW Permit element applies to ALL covered processes, not just flammable processes.
A facility can choose other means/methods to define the terms “adjacent” and “near”; however, this exercise should be viewed as being “safety critical” as it can have far reaching impacts on a covered process.