How to determine \"significant design changes\" for chemical engineering projects”

AQ/T 3033-2022 \"Guidelines for Safety Design Management of Chemical Engineering Construction Projects\" 9.2.2 Major design changes mainly include, but are not limited to, the following: a) Significant changes in the conditions surrounding the project； For example: military facilities (this basically doesn’t matter whether they are newly built, renovated, or expanded) ； New construction or expansion of important facilities (higher distance requirements) ； Plan high-level roads ； The park plan has changed. b) Change in the address of the construction project ； For example: A site intended for construction by a company is located at the boundary of a chemical industrial park. During the planning phase, the boundaries of the park were redrawn in accordance with the requirements regarding buffer zones between chemical industrial parks and residential areas; as a result, the site in question was excluded from the chemical industrial park, forcing the company to find a new location ； Before the feasibility study phase of a company’s project, the surrounding villages were included in the area to be demolished (due to insufficient external protection distance, and the local authorities agreed to carry out the demolition), but (omitted); as a result, the location had to be chosen anew. c) Significant changes occur in the main technologies, process routes, product designs, or the scale of the facilities: This aspect is highly subjective and prone to disputes, requiring confirmation through discussions among various parties (same as below) ； Example: Changing 2 units of 15-cubic-meter reactors to 1 unit of 30-cubic-meter reactor (without involving the initial process) ； During the project’s energy-saving assessment, the approach proposed by an energy-saving expert regarding commissions was adopted by the company ； Combining two into one reduces energy consumption); some consider this to be a major change, while others do not ； The core unit undergoes a \"diameter change\", which theoretically results in a change in scale; however, many experts (including patent holders) consider this to be no significant change (for reference only). d) Modifications to the safety facilities, including changes to the flare system and safety venting systems: e) Changes to important design documents ； For example: PID diagrams, equipment layout diagrams, calculation sheets, etc. f) Principle-based modifications to SIFs or safety interlocks ； g) Changes that may involve government approvals related to safety, fire protection, etc ； h) Other design changes that may reduce the safety performance of the construction project. 9.2.5 After the design documents for the safety facilities of a construction project have been approved by the relevant authorities, if there are significant changes to the safety design, the project owner shall go through the necessary procedures for such changes in accordance with relevant regulations.

\"Measures for the Safety Supervision and Management of Hazardous Chemicals Construction Projects\" (**Order No. 45 of the State Administration for Work Safety**, amended by Order No. 79 of the State Administration for Work Safety) Article 20: If the design of the safety facilities for a construction project that has already been approved undergoes any of the following changes, the project owner shall apply to the original approval authority for a review of the revised design of those safety facilities: (1) Changes to the design of the safety facilities that may reduce their safety performance； (II) Redesigned during the construction period. Article 14: If a construction project that has passed the safety condition review falls under any of the following circumstances, the project owner shall conduct a new safety assessment and apply for another review: (1) There are significant changes in the conditions surrounding the construction project ； (II) Change in the construction location ； (III) Significant changes occur in the main technologies, process routes, product designs, or plant scale ； (IV) The construction project has not commenced construction within the validity period of the safety condition review opinion, and construction is required to start after the expiration of that period. For a certain project, the preliminary evaluations for phases 1 and 2 were originally issued in a combined report; however, phase 2 began construction 3 years after the approval from the regulatory body (with an expiration period of 2 years), which meant that new preliminary evaluations, regulatory approvals, safety assessments, and so on were required.

“Guidelines for the Prevention and Control of Safety Risks in Hazardous Chemicals Production and Construction Projects (Trial)” (Emergency [2022] No. 52): 1.2.2 Other chemical industry construction projects shall follow these guidelines as well. 7.2.1 Review Process (Excerpt) (3) If the design of the safety facilities has already passed the review, any significant changes to that design that may reduce its safety performance, or any major design modifications such as redesigning the safety facilities during construction, require a review of the altered design. (4) After a construction project passes the safety facility design review, if minor changes occur that do not fall under the circumstances requiring re-review as stipulated in the Measures for the Safety Supervision and Management of Hazardous Chemicals Construction Projects, and such changes do not affect the overall process technology plan or the risk level of the project, the design unit shall prepare a document detailing the design changes, along with an explanation of the reasons for those changes and an analysis of their compliance status after the changes. →The design unit issues a “Statement of No Significant Changes”, a “Change Statement” or similar document