Views and discussions on the \"Fire Protection Standards for Engineering Design of Fine Chemical Enterprises\"
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The \"Fire Protection Standards for Engineering Design of Fine Chemical Enterprises\" (GB51283-2020) was issued on 20200116 and will come into effect officially on 20201001. During this period, I believe everyone has their own opinions, so let’s discuss them. This standard was initially proposed by Shanghai Huayi Engineering and the Shanghai Fire Brigade. In previous years, it seemed that fine chemical industries in the Shanghai area followed local standards, rather than adhering to Document No. 76; construction projects that fell under the category of \"two key areas, one major project\" or those with explosive hazards were required to comply with the strictest standards set out in the \"Petroleum and Chemical Industry Regulations\". After several years of suggestions, reviews, approvals, and finally its release this year, it was truly not easy for this standard to come into existence. However, the regulations specify how to carry out these actions. Regarding the conflicts arising from Document No. 76, some concerned citizens consulted the Ministry of Emergency Management, but the responses they received were vague and did not provide any concrete explanations. Recently, the Shandong Emergency Management Bureau issued the \"Suggestions on Further Clarifying the Construction Standards Applicable to Fine Chemical Enterprises\" (Lu Jing Ji 37), which provides guidelines for determining which standards should be applied by which enterprises, based on the scope of application of those standards. Of course, this is just a local document; as for whether the **Ministry of Emergency Management can provide more precise estimates, we’ll have to wait and see. Personal opinion: I agree with the suggestions put forward by the Shandong Emergency Management Bureau; definitions should be established in accordance with the applicable scope of relevant regulations. It is not appropriate to apply a one-size-fits-all approach to all construction projects that fall under the category of “two key areas, one major issue” or those with explosive hazards. While such a one-size-fits-all approach may seem to enhance safety, it fails to take into account the actual problems existing in the fine chemical industry, as well as the difficulties and uncertainties faced by enterprises. With the issuance of Document No. 76, experts enforced strict controls, requiring that most fine chemical manufacturing projects adhere to petrochemical industry standards regarding fire separation distances. Continuous inspections by experts as well as mutual inspections among experts from different provinces made it extremely difficult for fine chemical companies that had originally built their facilities in accordance with construction industry standards. With limited land available for such facilities, following petrochemical industry standards meant facing insurmountable challenges. This year, the long-awaited regulations for fine chemicals will be issued, in detail **also under great pressure due to safety risks. In my opinion, safety does not mean increasingly strict requirements, but rather increasingly rational and sensible ones. Strictness is not necessarily reasonable; what is reasonable will certainly take safety risks into account. Here is a prediction: **the Ministry of Emergency Management will issue an explanation regarding Document No. 76 or set requirements for the implementation of fine chemicals.** Sea friends, what do you think?
The principle of reasonable feasibility based on risk—ALARP.
I think the fate of this standard is likely similar to that of GB50183-2015
Requiring enterprises or projects to simply adhere to standards actually does not conform to the objective laws of businesses. Business operations are conducted in a market-oriented manner, yet regulation still relies on rules that have remained unchanged for years; the current situation of enterprises is blamed on those enterprises themselves, resulting in a serious problem of dual standards. This approach fails to eliminate potential risks at their root and prevent accidents from occurring. It is recommended that **the department first define its own role and develop a comprehensive framework for supervision. It should adopt an approach that involves engaging with the people and staying close to them, carefully consider the actual situation of the enterprises, and thus ensure safe production in those enterprises as well as long-term stability in society.
It’s unlikely for one enterprise to have one set of policies; the approach of ‘one policy per park’ has only led to chaos. **The intentions at the higher levels are good, but when it comes to those who implement them on the ground, things change. There are differences in skills and competence, and after all, the person in charge on site is often better suited for the task.**
It is unlikely that any changes will be made to Document No. 76. When something goes wrong, they bring up Document No. 76 as an excuse
Fine chemical industries typically involve a wide variety of raw materials and complex reaction mechanisms. It is uncommon for ordinary chemical companies to have a thorough understanding of these mechanisms; many small enterprises haven’t even conducted studies on the heat generated during reactions. They are also unaware whether the materials might be sensitive to heat, experience temperature spikes, or suffer from explosive decomposition； Designers or experts may not necessarily have a good understanding of intrinsic safety; the information they receive is usually provided by the companies themselves, which often do not fully understand the concept either, resulting in data that is partially accurate. Coupled with the varying levels of competence among designers and experts, it is difficult to ensure that no accidents occur, regardless of the standards in place.
Yes, many owners are not clear about the risks associated with such reactions. The organizations capable of conducting thorough risk assessments for fine chemical reactions must be recognized by the China Chemical Safety Association; there are not many such organizations, and their services are quite expensive. Many organizations are unwilling to invest this amount of money in such assessments
The risks in the fine chemical industry lie in the arbitrary changes in production processes, the complexity of the materials used, the presence of many hazardous processes, as well as the mixing of pilot and scale-up production stages, with frequent adjustments made. Companies often cannot clearly explain their production processes, and when an accident occurs, **the challenge in supervision is how to carry out the functions that were once performed by the Ministry of Chemical Industry, rather than relying on passive forms of oversight... Doesn’t it feel like there’s no way out? Apart from the petrochemical industry, which has remained largely unchanged for years, it’s not so much that petrochemicals are that amazing; it’s rather the characteristics of this industry. Regulatory oversight in the field of fine chemicals currently lags behind strategic needs, and tactically, nothing but makeshift solutions can be applied. These days, the Ministry of Emergency Management has become a sort of firefighting agency, rushing to deal with accidents wherever they occur... Think about the powerful functions of the former Ministry of Chemical Industry, and then consider the ups and downs of the State Administration of Work Safety – it was integrated into other agencies only to be forced out again, only to be reintegrated once more. It seems like it’s being given proper status, but in reality, structural reforms haven’t been fully implemented. What should be done? The bed is for sleeping; things still have to be done separately..........
**No explanation will be given for Document No. 76