Unreasonable aspects of AQ 3062-2025 \"Safety Management Standards for Fine Chemical Enterprises\" – Update to 26.3.21
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This post was last edited by wx_KhkO2 on 2026-3-21 at 17:14. One of the unreasonable aspects of AQ 3062-2025 \"Safety Management Standards for Fine Chemical Enterprises\" is that Appendix A lists over a dozen hazardous processes and imposes mandatory control requirements for them. Designating more than a dozen hazardous processes solely based on reaction type without considering other factors, and imposing mandatory control requirements for them, is clearly unreasonable and unscientific. For reactions such as those catalyzed by biological enzymes, although they are classified as hazardous reactions, the reaction conditions are mild, the risk assessment for these reactions is rated at level 1, and the products formed are stable with no risk of decomposition; therefore, there is no need to follow all the stringent requirements specified in the regulations. Also, in a certain hydrogenation reaction, the operating pressure is only 0.4 or 0.5 MPa; it differs from normal hydrogenation reactions, so it should not be treated as such. Also, a certain alkylation reaction takes place in the aqueous phase, which is different from the usual occurrence in the organic phase. The standard should set certain conditions, specifying under what prerequisites control measures are to be applied. The results of the reaction risk assessment should be taken into consideration; otherwise, what is the point of conducting such an assessment? Second unreasonable point: Clause 7.4.1.3 states that \"high-risk process units should achieve automation for the entire process, including material feeding (referring to continuous or multiple feedings during the reaction, excluding a one-time feeding before the reaction), reaction, and post-treatment.\" This is clearly unreasonable. High-risk processes often simply indicate that the risk at this stage is higher than that of ordinary reactions or unit operations; the risks in the post-treatment stage are not significant, and as long as there is proper separation, full automation of the entire process is not necessary. The specifications should be set as follows for rationality: in the case of high-risk reactions, the reaction area and the downstream processing areas should be located in separate buildings, or within the same building but separated by blast-resistant walls, firewalls, or gas-proof partitions (depending on the risks of explosion, fire, gas leakage, etc.). Moreover, if the fluids produced by the reaction do not possess hazardous properties such as flammability, self-ignition, or high toxicity (acute toxicity category 1), then full automation of the entire processing process is not necessary (except for operations that involve the concentration and purification of hazardous materials). Third flaw: Paragraph 7.2.2.5 states that “distillation (rectification) solvent removal equipment should be equipped with two separate temperature measurement instruments, at least one of which must have remote transmission capabilities, to ensure that the temperature of the material at the lowest liquid level can be detected.” ” This one is also unreasonable. The current equipment conditions weren’t taken into account. These days, reaction vessels are often used as equipment for distillation and solvent removal, and the reaction vessels in the chemical industry come equipped with only one thermometer port. The standards developed by this emergency response department take into account only the control of its own processes, without considering equipment issues, which leads to conflicts between different fields. It is very difficult to add another thermometer to the reactor; even if a small opening is made in a large flange dedicated as a spare port to insert the thermometer, it is still necessary to consider whether inserting it through that port will cause interference with the stirrer blade. Often, it’s not possible to insert a second thermometer, and it’s not like pressure gauges where you can install as many as you want. So this point is unrealistic.
It seems that the idea behind formulating these regulations is conservative; many aspects of them do not correspond to reality and are unreasonable.
The experts established a general framework; it’s not possible to go that detailed
The most important issue is that that rule is a mandatory rule. If it’s a recommended standard, it’s not mandatory; no one cares how it’s written. But if you force it to be done, for some companies it represents a matter of life or death. So, unreasonable and harsh poor regulations kill people.
I believe it is more reasonable to modify the standard in this way: add a prerequisite that this standard is applicable only to reactions between pure compounds, and not to reactions involving biological substances such as enzymes.
I believe it is more reasonable to modify the regulations in this way: add another prerequisite – reactions that yield a risk assessment score of level 1 can follow the measures recommended in their reports, without having to strictly adhere to the basic safety control requirements outlined in Appendix A.
Mandatory standards require enforcement during design and inspection. Indeed, for reactions with the same name, the safety risks can vary greatly.
Many unreasonable and impractical aspects were identified in this regulation, which has not yet been implemented; due to time constraints, not all of them were listed, and they will be updated gradually in the future.
The biggest flaw in this standard is its mandatory provisions throughout the entire text.