Is it necessary to implement the two key points and one major SIS system?

According to Document No. 116, I think it’s necessary… No one would dare take the responsibility and claim that it’s not required (especially the safety supervision departments). Then it can only be made stricter…

Whether to adopt the SIS system should be determined based on the classification resulting from an assessment or calculation of the safety integrity level (SIL) of the safety instrument system, which is carried out by a third party commissioned by the enterprise. However, in general, devices that involve two key points and one major aspect are all included in the SIS system.

**Guiding Opinions of the State Administration of Work Safety on Strengthening the Management of Process Safety Instrumented Systems, Document No. An Jian Zong Guan San [2014] 116: (1) Process safety instrumented systems (SIS) include safety interlock systems, emergency shutdown systems, as well as detection and protection systems for toxic and harmful gases, flammable gases, and fires. The safety instrumented system is independent of the process control systems (such as distributed control systems, etc.). It remains in a dormant or inactive state during normal production, but can act instantly and accurately once a situation that could lead to a safety accident occurs in the production facility, thereby stopping the production process safely or bringing it into a predetermined safe state. It must have high reliability (i.e., functional safety) as well as proper maintenance and management. If the safety instrumented system fails, it can often result in serious safety accidents; in recent years, most major chemical (hazardous chemicals) accidents that have occurred in developed countries have been related to failures in the safety instrumented systems or improper setup of these systems. Based on the consequences and risks resulting from the failure of safety instrument functions, these functions are classified into different safety integrity levels (SIL1-4, with level 4 being the highest). Safety instrumented systems of different levels have varying technical requirements in terms of design, manufacturing, installation and commissioning, as well as operation and maintenance. At present, in China’s safety instrumented systems and related safety protection measures, throughout all stages of their life cycle – including design, installation, operation, and maintenance – there are issues such as insufficient hazard and risk analysis, inappropriate design choices, unreasonable redundant fault-tolerant structures, a lack of defined inspection and testing schedules, and preventive maintenance strategies that are not effective enough. It is therefore urgent to strengthen the regulation of safety instrumented system management. As China’s chemical processing facilities and hazardous chemical storage installations become larger in scale and the level of automation in production processes continues to improve, it is extremely urgent and necessary to strengthen and standardize the management of safety instrumented systems. (12) Starting from January 1, 2016, qualified chemical enterprises such as large-scale enterprises and those wholly owned by foreign investors that construct new chemical plants or hazardous chemicals storage facilities related to the \"two key areas and one major project\" must design safety instrument systems that comply with relevant standard requirements, in accordance with the provisions of these guiding principles. (13) Starting from January 1, 2018, all newly constructed chemical processing units and hazardous chemical storage facilities related to the \"two key areas and one major project\" must be designed with safety instrument systems that meet the required standards. For the safety instrument systems of other newly built chemical processing units and hazardous chemical storage facilities, starting from January 1, 2020, it is necessary to comply with the requirements of functional safety standards and design safety instrument systems that meet those requirements.

(12) Starting from January 1, 2016, qualified chemical enterprises such as large-scale enterprises and those wholly owned by foreign investors that construct new chemical plants or hazardous chemicals storage facilities related to the \"two key areas and one major project\" must design safety instrument systems that comply with relevant standard requirements, in accordance with the provisions of these guiding principles. (13) Starting from January 1, 2018, all newly constructed chemical processing units and hazardous chemical storage facilities related to the \"two key areas and one major project\" must be designed with safety instrument systems that meet the required standards. For the safety instrument systems of other newly built chemical processing units and hazardous chemical storage facilities, starting from January 1, 2020, it is necessary to comply with the requirements of functional safety standards and design safety instrument systems that meet those requirements.

Regarding the two key points and one major aspect, it is necessary to implement a SIS system; for new projects, this system should be implemented alongside the existing ones. If it is just an old project, a new SIS rating is required.

The above document makes it clear that it’s mandatory. Although it’s not necessarily the case after HAZOP analysis: lol

If it only involves key chemicals, is it possible to omit them? Jiangsu’s safety inspection regulations do not require special oversight for hazardous chemicals

If SIS is not used in the hazop analysis, should it still be installed?

Perhaps different regions have varying interpretations and approaches to implementing these regulations; in Zhejiang, it is sufficient to have an SIL rating – there is no need to pursue an SIF rating if that is not required.