New Regulations Exposed by the China Ministry of Emergency Management: Fine Chemical Companies are Riddled with Safety Vulnerabilities, 14 Dangerous Processes Face the Toughest Regulation Ever, Are Your Companies Ready?

On August 26, the official website of the Ministry of Emergency Management of China officially published the "Safety Management Standards for Fine Chemical Enterprises" (draft for comments), aiming to solicit valuable opinions from all aspects of society, and the deadline for soliciting comments is October 26, 2024.

The draft for Comments clearly points out that the specification is mainly applicable to the new construction, reconstruction and expansion projects of fine chemical enterprises. The specification puts forward specific safety technology and management measures for process technology, design basis, general layout, process equipment and unit operation, automation control, power supply and distribution facilities, operation management and other aspects.

The specification puts forward clear requirements on the source of process technology and process safety of construction projects, emphasizing that enterprises should choose safe, advanced, mature and reliable process technology, and carry out reaction safety risk assessment and process risk analysis after small and pilot tests when using self-developed process technology. For chemical processes used for the first time in China, safety and reliability demonstration should be carried out in accordance with regulations. At the same time, enterprises should fully identify the risk of the relevant materials involved in the fine chemical process, master its physical and chemical properties, harm degree classification data, and establish a chemical compatibility matrix.

The draft for Comments clearly specifies the qualification requirements of fine chemical construction project design units, that material thermal stability analysis, reaction safety risk assessment and process risk analysis should be carried out before design, and that these work results should be integrated into the design to improve the essential safety level of the project.

The draft for Comments puts forward the requirements for the site selection, planning layout and general layout of the enterprise, the requirements for the safety protection distance from the protection target, and the layout requirements for the presence of enterprise personnel and the storage of hazardous chemicals.

The draft for Comments subdivides the process equipment into reaction, separation/drying/packaging, storage, transportation, auxiliary, collinear and other facilities and unit operations, and puts forward clear requirements.

The draft for Comments puts forward the requirements for automatic control, and makes specific provisions for automatic control instruments and their management.

The draft for Comments stipulates the requirements for power supply load of fine chemical enterprises, and clarifies the power supply load grade of typical devices and facilities; The division of explosion danger areas in some special places is stipulated.

According to the draft for Comments, the academic qualifications and professional requirements of the main person in charge of the fine chemical enterprise, the person in charge of the safety and the safety management personnel are clarified; The trial production operation, the formulation and improvement of safety management system, the preparation of operation procedures and process cards, the storage of chemicals on the production site and the control of the number of personnel are stipulated. The change management and special operation management are emphasized. The corresponding provisions are also made in the handling of abnormal conditions and the emergency handling of accidents.

The appendix of the specification describes 14 typical hazardous chemical processes involved in the fine chemical industry, such as nitrification process, chlorination process, fluorination process, diazotization process, peroxide process, Grignard reaction process (including Grignard reagent preparation), hydrogenation process, phosgene and phosgenation process, polymerization process, oxidation process, alkylation process, amination process, sulfonation process, azo process, etc. According to the characteristics of the process itself, the key requirements of safety risk control are put forward.

In addition to the Grignard reaction process (including Grignard reagent preparation), the remaining 13 processes belong to the key supervision of dangerous chemical processes, considering the Grignard reaction process (including Grignard reagent preparation) heat release, water avoidance, risk of reaction out of control and other characteristics, and is a common process in the fine chemical industry, the key requirements for safety risk management and control are put forward.

In addition, the appendix specifically clarifies the specific content of the preparation outline of the demonstration report when the enterprise carries out the process technology safety and reliability demonstration, which should include the project overview, self-identification opinions, process introduction, process technology comparative analysis, process safety analysis, main equipment selection, reaction safety risk assessment results, emergency facilities analysis, etc., to facilitate the standardized preparation of the demonstration report.