On automatic control and interlock devices for hazardous chemical processes under strict supervision
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Our company has a fine chemical project that results from the relocation of an existing manufacturing facility; the process route, process parameters, and production capacity remain unchanged. This reaction falls under the category of hazardous chemical processes that are subject to strict supervision. As required, interlock and automatic control facilities seem necessary; due to the mild reaction and very low heat release, the old plant does not have such facilities. The new plant is required to be installed, but according to the regulations, it needs to be set up based on the specific circumstances of the reactions involved. It seems that a risk assessment of those reactions is necessary, and the appropriate facilities should be installed based on the results of that assessment. Furthermore, according to relevant regulations, for reactions in which there are no changes in the process route, process parameters, or production capacity, it is not necessary to conduct a reaction risk assessment. Is this not a dead end?
I don’t remember it saying in the document that \"for reactions where there are no changes in the process route, process parameters, or production capacity, a reaction risk assessment is not necessary.\" It should be something like \"for reactions where there are changes in the process route, process parameters, or production capacity, a reaction risk assessment is required.\" The opposite is not correct. If you didn’t conduct a risk assessment for this step before, then be sure to carry it out properly when moving; we need to make up for all the outstanding tasks related to older projects here.
It’s okay to say this sentence in reverse, right? With the relocation of the old projects over there, have the process parameters changed? And there is also a deadline of 2020 in the guidelines.
Or in other words, this is what’s known as a borderline case: what the law requires must be done, while what the law does not require does not necessarily have to be done?
Accurately determine the scope and content of safety risk assessment for fine chemical reactions. (1) For batch and semi-batch reactions in enterprises that involve hazardous chemical processes under strict supervision as well as metal-organic synthesis reactions (including Grignard reactions), a safety risk assessment of these reactions is required in any of the following situations: 1. When a new process or new formula is used for industrial production for the first time in China, or when a new process introduced from abroad has not yet undergone a safety risk assessment； 2. Changes occur in the existing process routes, process parameters, or plant capacity, and there is no reaction safety risk assessment report ； 3. Accidents involving production safety have occurred due to problems with the reaction process. The regulations specifically mention the need to \"accurately understand the scope and content,\" which implies that things outside those three items do not need to be addressed. With only 5 evaluation agencies announced so far, considering the large number of fine chemical enterprises and projects across the country, this is a reasonable figure.
It can’t be cycled; this is a new project, and heat reaction assessments must be conducted before the construction of any new project. For any fine chemical project that involves processes subject to strict supervision, automatic control and interlock systems are necessary, as well as an emergency shutdown system; subsequently, an SIS system is installed.
Those of us who work with synthetic resins are not involved in hazardous processes, but we still need to install interlock devices. As for your hazardous processes, it’s sufficient to leave those tasks to the design institutes; however, the production processes must be described clearly, without any ambiguity.
I don’t think it’s possible; don’t rely on luck
Thank you all for your replies. Regarding the control measures for hazardous chemical processes that are under strict supervision, it isn’t stated that they must be implemented. Or is it that after some kind of assessment, based on the results of that assessment, it is then decided whether to implement certain control measures and what those measures should be? Must this evaluation process be carried out by a qualified third party? In our company’s oxidation reaction, all the raw materials are added to the reactor together, and the mixture is heated and kept at that temperature for 4 hours. Once the desired reaction temperature is reached, intermittent heating is required to continue the reaction. How to achieve self-control and interlocking? It doesn’t meet any of the conditions for being flammable or explosive.
Investing in chains and SIS requires a large amount of capital
Personal opinion: Given your situation and the current circumstances, **the department will definitely have you work with the self-control system. The reason is that you are a key process. You can approach a design institute to carry out the HAZOP analysis and DCS/SIS automation design first. Because few organizations can conduct reaction heat risk assessments, one has to wait in line for 3 years. You can define the SIL level, such as Level 0 or Level 1, based on actual conditions and the design institute’s specifications, to enable automated control upgrades.