Ten common misconceptions about special equipment

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Electric forklifts do not require registration. Some sellers mislead companies that purchase forklifts, making them believe that only diesel (or gasoline) forklifts need to be registered, while electric (battery) forklifts do not require such registration; as a result, these companies are fined by the market supervision authorities for using forklifts that have not been inspected or registered. In fact, any forklift that meets the definition of special-purpose motor vehicles within the \"Catalogue of Special Equipment\" falls under this category. Simply put, forklifts that possess three key features – a mast, forks, and a self-propelling mechanism – and are used in areas such as factory premises, tourist attractions, and amusement parks are considered special equipment. This includes pallet stackers that meet the defined criteria; all such devices must undergo registration (and be assigned a license plate) in accordance with the provisions of the \"Law of the People’s Republic of China on Safety of Special Equipment\". Myth 2: Companies with fewer than 20 special equipment units do not need safety managers. Although the \"Rules for the Use and Management of Special Equipment\" (TSG 08-2017) stipulate that companies with 20 or more such units must have certified safety managers, it does not mean that companies with fewer than 20 units are exempt from having safety managers. The actual situation is that all entities that use special equipment must appoint safety managers for such equipment; this appointment shall be documented in an official order issued by the entity, and that document must be kept within the records related to the special equipment. If the total number of pieces of equipment is 20 or more, then a full-time safety manager who holds the necessary certification must be appointed. Myth 3: Air storage tanks with a capacity of less than 1 cubic meter are not considered special equipment. This statement seems to be a confusion with simple pressure vessels; simple pressure vessels are a type of special equipment that do not require registration for use or regular inspections – they only need to be discarded once their service life is exhausted. The method for identifying simple pressure vessels is also straightforward; usually, the word “simple” or “simple pressure vessel” is indicated on their factory nameplates. A more professional approach involves checking the parameters: the design pressure should be ≤1.6 MPa, the volume should be ≤1 m3, and the product of pressure and volume should be ≤1. The medium used is mainly air or steam. Therefore, it is not possible to determine whether an air storage tank is a simple pressure vessel based solely on its 1 cubic meter volume; instead, identification must be done through the equipment’s nameplate or factory documentation. It is important to emphasize that although the tank itself does not require registration or inspection, safety accessories such as safety valves and pressure gauges installed on the tank still need to be calibrated and inspected in accordance with the law. Myth 4: Special equipment that has not yet reached the end of its inspection validity period does not need to be submitted for inspection right away. According to the Safety Law of the People’s Republic of China regarding special equipment, the users of such equipment must submit the equipment for inspection to the relevant inspection agencies within one month after the expiration of the inspection validity period. This requirement is based on two main considerations: firstly, it allows the inspection agencies to arrange the necessary inspectors in advance, ensuring that the inspection of special equipment in a given area can proceed smoothly ； On the other hand, if potential issues and faults in various devices are detected during the inspection process, reporting them in advance provides sufficient time to make necessary corrections before the expiration of the inspection period. After these corrections, it is possible to obtain a qualified report on schedule, thereby avoiding any gap between two inspections. Myth 5: Truck cranes are the same as tire cranes. Although tire cranes are listed in the Catalogue of Special Equipment, truck cranes are not included there; these two are entirely different types of equipment. The main difference between the two lies in their operation cabins: a tire crane falls under the category of special equipment and has only one operation cabin used to control movement and lifting of loads, whereas a truck crane is not considered special equipment; it not only has a vehicle driving cabin but also another crane operation cabin. As a result, it is not subject to the \"Law of the People’s Republic of China on Safety of Special Equipment\" and the \"Regulations on the Supervision and Management of Personnel Working with Special Equipment.\" Myth 6: Since ordinary people use liquefied petroleum gas cylinders for cooking, they are the entities that use these cylinders. Both the \"Law of the People’s Republic of China on the Safety of Special Equipment\" and the \"Technical Regulations for Gas Cylinder Safety\" stipulate that the entity responsible for using gas cylinders is the unit that fills them. It is the act of filling cylinders that falls under the scope of regulation regarding special equipment. Moreover, gas cylinder filling units are only allowed to fill cylinders that are in their own ownership according to the law; therefore, ordinary people are the entities that \"use the gas\" rather than those that \"use the cylinders\". Although households with liquefied petroleum gas cylinders are not considered users falling under the scope of special equipment regulation, the use of liquefied petroleum gas must still comply with the relevant laws and regulations set by the authorities in charge of gas management. Myth 7: Hydraulic lifting platforms can be used as “cargo elevators”. A “cargo elevator” is an informal term for a simple lifting device; those with a rated lifting capacity of over 500 kilograms are considered special equipment. Although hydraulic lifting platforms do not fall under the category of special equipment, some companies still place them in shafts within factories or in makeshift shafts constructed from materials such as bricks, wood, and iron plates. They then add components such as floor selection panels, door locks, limit switches, and guide rails, turning these platforms into “illegally manufactured, installed, and used” special equipment – what are commonly known as “home-made elevators”. Not only are the organizations that use such platforms subject to penalties, but those responsible for their installation also face legal consequences. Myth 8: **With the cancellation of the operation certificates for cranes, anyone can operate them.** Cranes fall under the category of lifting machinery listed in the \"Catalogue of Special Equipment.\" In recent years, the State Administration for Market Regulation has abolished the certification requirements for cranes that are operated from the ground or via remote control; however, it has retained the certification requirements for cranes operated from a control cabin, as well as for tower cranes and other similar lifting machinery. Additionally, the \"Rules for the Use and Management of Special Equipment\" and related technical standards stipulate that for equipment for which ground-operation certifications have been cancelled, the employers are still required to provide pre-job training and safety education for the personnel who will operate such equipment. Not everyone is allowed to operate cranes; otherwise, it would violate the relevant provisions of the \"Law of the People’s Republic of China on Safety of Special Equipment.\" Myth 9: Special equipment can be managed by third parties. Safety regarding special equipment places a strong emphasis on the responsibility of the entity in charge of its safety. However, many organizations that use such equipment, especially those responsible for managing elevators, tend to equate elevator maintenance services with their own responsibilities for daily management. In reality, the maintenance companies acting on behalf of elevators function merely like \"4S stores\" for elevators; therefore, when an accident occurs, it is the vehicle owner who is held accountable by the traffic authorities, not the 4S store. Of course, for special equipment that is owned jointly, such as the elevators in residential complexes, they belong to all the owners. Therefore, in accordance with the Regulations on the Management of the Use of Special Equipment, all the owners or the owners’ committee entrust a property management company to manage the elevators through a contract; the property management company assumes primary responsibility for the safety of these elevators, and is responsible for carrying out regular inspections, registering their use, conducting periodic tests, and signing maintenance contracts. For elevators rented out along with the building, if the lease agreement stipulates that the tenant is the entity responsible for their operation and management, then the tenant bears the primary responsibility for safety. In the absence of such a provision in the contract, the owner of the elevator is the legal entity responsible for its operation and management. Myth 10: Elevators that have passed inspections should not experience failures. Inspections are a means of verifying the safety of an elevator’s daily use as well as its maintenance conditions; the various inspection items represent the minimum standards for elevator safety. In other words, passing an inspection only indicates that the elevator’s safety meets the required minimum standards. If elevators are compared to people, then annual inspections are akin to regular health check-ups. The fact that no problems are found during such checks does not mean that the person will not get sick in the following year. Similarly, whether an elevator develops faults depends on proper daily management and maintenance. Therefore, only by ensuring proper daily management by the using unit, proper fulfillment of its responsibilities, and adequate supervision of maintenance and repairs can the probability of elevator failures be reduced to a minimum.