The basic safety control requirements in the \"Catalog of Hazardous Chemical Processes Subject to Stringent Supervision\" need to be changed
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The “Catalogue of Hazardous Chemical Processes Subject to Key Supervision” specifies the basic safety control requirements for the listed hazardous chemical processes. But I think what was established at that time was based on pure chemical reactions ； But with the advancement of technology, some chemical reaction processes are no longer purely chemical reactions; some of them are bio-chemical reactions, such as those that use biological enzymes as catalysts. These reaction conditions are mild; typically, the reaction heat risk assessment assigns a level of 1 (the lowest). According to the safety measures recommended in the report, there is no need for such stringent safety measures as those required for typical hazardous chemical processes. In reality, if owners were to strictly follow the requirements outlined in the \"Catalogue of Hazardous Chemical Processes Subject to Intensive Supervision,\" they would be very reluctant to do so. Therefore, it is recommended that the \"Catalogue of Hazardous Chemical Processes Subject to Stringent Supervision\" be revised in light of contemporary changes; its scope of use could be specified as being limited to reactions between pure compounds only, and it should not apply to reactions involving biological substances such as enzymes. It can be added that for reactions whose reaction heat risk assessment results are rated at level 1, the measures recommended in their reports can be followed, without the need to adhere strictly to all basic safety control requirements.
It is recommended to amend the “Catalogue of Hazardous Chemical Processes under Intensive Supervision” to keep up with the development of modern chemical technologies. The table of contents should clearly state that it applies only to reactions between pure compounds, and does not cover biochemical reactions involving biological substances such as enzymes. For reactions rated as Level 1 in the reaction heat risk assessment, corresponding safety measures can be taken based on the recommendations in the assessment report, rather than strictly adhering to the original safety control requirements. .
I’m afraid that during the evaluation, something that actually poses no risk might still be rejected by some stubborn experts. So it still seems necessary to modify that rule.
Why are you so right? Please give an example: P
For example, a certain reaction catalyzed by biological enzymes falls under the category of alkylation reactions by definition; there is a risk assessment report on the reaction heat, with a rating of level 1. Moreover, past production experience has shown that the reaction conditions are mild, and the properties of the reaction substrates are stable. In accordance with the recommendation in the reaction heat risk assessment report, \"a conventional automatic control system should be installed to enable centralized monitoring and automatic adjustment of the key reaction parameters (DCS or PLC)\". Having temperature and pressure interlocks is sufficient; in the highest-end versions, a safety relief valve may be added as well.
Now, comments can be submitted on the \"Safety Management Standards for Fine Chemical Enterprises\" (draft for comment). This standard includes requirements for the automated control of hazardous chemical processes. (http://www.mem.gov.cn/gk/zfxxgkpt/fdzdgknr/202408/t20240826_498751.shtml)
One of our reactions involves a nitration reaction; the risk assessment for this reaction classifies it as a first-order reaction. Dilute nitric acid is used as the nitrating agent, and the reaction is quite mild. Nevertheless, experts still implement SIS systems, as well as various relief and control measures required for nitration reactions, and they use EPS for power supply and carry out modifications to make the process more continuous. . . . . . .
It’s definitely a high-risk process; it’s not some ordinary reaction
That makes sense; evaluation criteria should keep up with the times
Now it’s about the process type, regardless of the level of risk.