Who determines the hazardous chemical processes that require close supervision?
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I have a client who responded as follows: Decamethylcyclopentasiloxane + aminosiloxane ring structure + water = aminosilicone oil. There are no side effects; the temperature is 100 degrees and the pressure is at atmospheric level. Neither the safety design assessments conducted by the design institute nor the regulatory authorities consider it to be a polymerization reaction. The safety assessment agency considers this to be a polymerization reaction, a hazardous chemical process that requires close supervision. May I ask, who is responsible for determining hazardous chemical processes: the design institute, the regulatory authorities, or the safety assessment agency?
The identification of hazardous chemical processes is the responsibility of the work safety supervision and management department. The design institute is responsible for the process design, while the safety assessment agency is tasked with conducting safety evaluations. However, it is up to the regulatory authorities to determine whether a particular chemical process falls under the category of processes that require strict supervision, based on relevant laws and standards. .
Personally, I think it is the result of communication among experts, safety assessment agencies, and the client party; it’s not specified who exactly makes the decision
When it is difficult to confirm the process, it is generally determined through consultation between the safety assessment agency and the regulatory authorities.
I remember there was a supplementary note stating that something like the thermal polymerization of coal tar pitch is merely the polymerization of the binder under normal pressure and does not fall under the category of polymerization processes; you might want to check that out
Some typical processes among the first batch of key hazardous chemical processes to be regulated under the adjustments: Article 1 Production processes under normal pressure involving products such as coatings, adhesives, and paints are no longer classified as “polymerization processes”. Therefore......