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For pharmaceutical companies that produce hazardous chemicals, their products are not hazardous chemicals, and the intermediate products are not used as such but are reused directly. How should hazardous chemical production projects be defined? For example, during the reaction process of active pharmaceutical ingredients, a side reaction leads to the formation of hazardous chemicals; these hazardous chemicals are then used directly in subsequent esterification reactions, and the resulting products are not hazardous chemicals.
In such cases, pharmaceutical companies that generate hazardous chemicals need to consider the following points in order to define the hazardous chemical construction projects: 1. Determine whether the hazardous chemicals produced fall under the category of hazardous substances, based on the definitions provided in **relevant laws, regulations, and documents. If it is a hazardous chemical, the construction project must be carried out in accordance with the requirements of relevant laws and regulations such as the Regulations on the Safety Management of Hazardous Chemicals. 2. For the hazardous chemicals generated during the reaction process, corresponding risk assessments and safety control measures are required. This includes assessing the properties of such hazardous chemicals, their hazardous characteristics, the types of accidents they may cause, and the consequences of those accidents, and establishing corresponding safety control measures such as flaw prevention, classified storage of hazardous chemicals, fire and explosion protection, etc. 3. For the subsequent use of hazardous chemicals, it is also necessary to evaluate them based on their hazardous properties and usage conditions, and to establish corresponding safety control measures. 4. It is necessary to establish a comprehensive management system for hazardous chemicals to ensure their safe transportation, storage, and use, while also raising employees’ awareness and capabilities regarding the safety of such chemicals. In summary, pharmaceutical companies that handle hazardous chemicals need to take into account various factors such as the nature of these chemicals, their hazardous properties, risk assessments, safety control measures, and relevant laws and regulations when defining projects related to the handling of hazardous chemicals. They must also implement effective measures to ensure the safe management of such chemicals. .
Should the definition be carried out by the safety supervision department, a third-party evaluation agency, or the construction unit?