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AQ 3062-2025 "Safety Management Specifications for Fine Chemical Enterprises" 7.2.2.4 When the heat medium temperature of distillation (rectification) equipment exceeds the medium TD24 (the temperature corresponding to the maximum reaction rate arrival time of 24 hours under adiabatic conditions), safety facilities such as emergency cooling or emergency relief should be installed. Explanation of provisions: It is clarified that the heat medium temperature of the distillation (rectification) equipment exceeds the medium temperature (TD24) (this temperature depends on the thermal stability of the reaction mixture, which is the highest temperature when there is no problem with the thermal stability of the reaction material. ), emergency cooling or emergency relief safety facility requirements should be set. What (types) of media should this TD24 be measured on? How to handle related matters?
This question is very critical, and it is where many companies tend to get stuck when implementing new regulations. The measurement of TD24 is mainly aimed at those reactive materials that may decompose, polymerize or release heat due to heat accumulation during distillation or rectification, such as compounds containing unstable groups such as nitro, peroxy, and alkynes, or materials with a history of overheating decomposition. Simply put, if this process line involves materials that are "prone to thermal runaway", testing is required. As for the handling process, it is generally recommended to first entrust a qualified third-party organization (such as some chemical safety technology centers or university laboratories) to conduct thermal stability analysis (such as DSC, ARC, etc.) to obtain the TD24 value of the material. Then based on the results, combined with your process parameters (maximum temperature of the heating medium, operating pressure, etc.), determine whether to add an emergency cooling or relief system. These changes usually require going through the company's internal change management process and reporting to the local emergency management department when necessary. If you are unsure about the specific material category, it is recommended to directly consult a process safety evaluation expert. After all, this involves investment in safety facilities and compliance review, and cannot be judged based on experience alone. In addition, the new regulations have just been released, and the implementation details may differ from place to place. It is best to confirm the transition period arrangements with the local emergency department.