Confusion about Article 255
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(1) Report cover font layout issues: The General Principles of Safety Assessment are the guiding basis for all assessment guidelines. Since the report format is stipulated in the General Principles, other guidelines and laws should be followed and implemented (such as the General Principles and Current Status Assessment Guidelines, the Pre-Evaluation Guidelines and Order No. 8, Detailed Rules and General Principles, etc.). However, the cover requirements of the detailed rules, including the text font requirements, are obviously in conflict with the guidelines. Which one should prevail? (2) Conflicts between regulations 1. The detailed rules stipulate that the project establishment report must analyze the "safety conditions of the construction project", while Order No. 8 stipulates that the project should conduct safety condition analysis and evaluation during the feasibility study stage. Obvious conflict. 2. The detailed rules stipulate the "analysis of risk degree". The analysis of risk degree is stipulated in the project establishment evaluation. The "analysis of risk degree" is also stipulated in the design of project safety facilities, and the contents are basically the same. It obviously conflicts with the guidelines for the preparation of special articles on the design of safety facilities for hazardous chemical construction projects. (3) Questions in the detailed rules 1. 6.1.1 in the detailed rules briefly describes the main technologies and processes (methods) used in the design of construction projects and the comparison of the levels of similar construction projects at home and abroad. The current situation is that as long as a construction project meets the * * industrial policy, as long as it is right or wrong * * Only eliminated and restricted projects can be constructed. What is the significance of "comparison of the levels of similar construction projects at home and abroad"? Furthermore, there are many types of construction projects, and it is impossible for safety assessors to understand the latest processes and technologies for all construction projects. Even if you search online, you may not be able to find it. 2. “6.1.4” in the detailed rules describes the process flow selected for the construction project and the layout of the main devices (equipment) and facilities selected and the relationship between the upstream and downstream production devices. ”, at the project establishment (i.e. research and development stage), it is based on the level of device layout, and the relationship between upstream and downstream production devices is not clearly defined. For chemical production, its production equipment is connected from the previous to the bottom. Any specific description of the "relationship between the upstream and downstream production equipment" in the safety assessment report is really irrelevant. 3. In the details 6.4.2.2 Determination of safety evaluation methods “For process safety analysis of construction projects that adopt new technologies and processes for the first time in China, in addition to other safety evaluation methods, the hazard and operability study method should be selected as much as possible. ” The hazard and operability study method requires relatively high specific requirements for the process, which leads to an obvious conflict between the detailed requirements and the actual operation. I think this method is not the best evaluation method. As a guiding document, Document No. 255 does not necessarily require evaluators to use any methods for evaluation. Such regulations are not conducive to improving the level of evaluators and may easily lead to uniformity in safety evaluation reports across the country. 4. The details are in“ 6.4.2.3 In the third point of "Analysis of Inherent Risk Level", T needs to be calculated * T equivalent substances: Explosive chemicals, flammable chemicals, toxic chemicals, corrosive chemicals. Does it refer to those parts that are major hazard sources, or all substances involved in the project. If it refers to all items, if the number of dangerous goods in the project is very small, is it making a fuss? If it refers to major hazard sources, it seems that there are omissions. The expression is not clear. 5. in“ 6.4.2.4 In "Analysis of Risk Level", Article 2. The conditions and time required to cause an explosion or fire accident after the leakage of explosive or flammable chemicals are met ； At present, our country still has a weak basic data situation. When doing quantitative calculations, we cannot obtain usable basic data, and we cannot truly contribute to a more scientific risk analysis. The conditions that cause explosions and fire accidents are easy to understand and analyze, but how to determine the time required? Any place where flammable and explosive media exists must prohibit all ignition sources (take a series of fire and explosion prevention measures). Once the flammable and explosive media leaks and forms an explosive mixture with air, no explosion will occur without an ignition source. Generally speaking, everyone knows that flammable and explosive media leaks and forms an explosive mixture with air. When it encounters an ignition source, it explodes. So how to determine the time required? If it is based on assumptions, what is the meaning? 6. Details 6.5.1.1 according to 5.4.2.4 The scope of casualties caused by explosions, fires, and poisoning accidents is obtained, and the production and operation activities and residents' lives within 24 hours around the construction projects within this scope are collected, investigated, and sorted out. “What is the concept of "the situation of production and business activities and residents' lives within 24 hours"? Production and business activities and residents’ living conditions are long-term. What is the significance of defining “within 24 hours”? Again. “How should we understand "residents' living conditions"? The living conditions of residents across the country are probably similar. How to express it specifically? If it is necessary to write about "the living conditions of residents within 24 hours", then this topic alone can fill a large article. Is this still a safety evaluation report? If you explain it briefly, wouldn't it be just a formality?
That's what the original poster said, and I feel the same way. A simple sentence in the article is sometimes a task that evaluators cannot complete no matter how hard they rack their brains. Maybe, this way experts can ask questions. Haha, just follow Document No. 255 and get started. You can't cover everything anyway.
Yes, if this continues, every report will be like a motherless child.
1. What is the significance of “comparison of the level of similar construction projects at home and abroad”? Indeed, I think the domestic situation of technology is fine, and there is no need to integrate with international standards. After all, China and the West abroad * * The technical gap is large. 2. I personally think the following calculations are not very meaningful!
The "Detailed Rules" are not written at a high level and are inconsistent with AQ8001, 8002, and 8003. Some requirements are impossible to complete and meaningless, and have various flaws. However, the direction is clear: to provide convenience for safety supervision and enterprise safety management, to be as quantitative and objective as possible, to appropriately separate safety facility construction plans from production construction plans, and to focus safety evaluation on safety facilities and countermeasures. The direction of the "Detailed Rules" is very clear, so everyone should do their best. Environmental assessment is relatively standardized, which is the result of long-term efforts. Perhaps the safety assessment ten years from now can be as standardized as the current environmental assessment.
The original poster is right! I have also participated in discussions on the application of new rules. I always feel that the new rules and previous evaluation rules are not documents issued by the same system. According to normal thinking, the preparation of evaluation reports should mainly be carried out in accordance with the guidelines, but now that the detailed rules have been published late, experts may require that they be prepared in accordance with the detailed rules. In fact, the relevant departments should have organized and systematized the laws and regulations on evaluation long ago so that evaluators can better comply with them. Furthermore, relevant scientific research units should make efforts to conduct theoretical research on safety aspects so that the risk level analysis of projects can be based on theoretical basis.
Since 255 is a trial implementation, it is recommended that you summarize relevant issues and give feedback to* * Department of Environmental Protection
I'm at a loss as to what to do, the file is difficult to operate.
There are some issues with the details, and they were published in a hurry, which has aroused criticism from everyone. I won’t go into the bad parts, because everyone has said a lot. But there are also places worth recommending.: 1. The detailed rules point out that HAZOP is used for process hazard analysis. You must know that HAZOP is a method required by law in foreign countries, and its effect is better than the current evaluation method. 2. The detailed rules require more quantitative calculations. Although it may not meet the requirements because there is not much basic data at present, it should have more scientific and in-depth content than the current evaluation report. It is also a direction for future safety assessment. 3. The specification of detailed rules has reduced those empty and hollow evaluation reports. Many of today's evaluation reports are just a formality and have little content. Enterprises take the reports and just shelve them. The strict requirements of the detailed rules are to make the evaluation reports play their due role. Anyway, I look at the fine print pro and con.
in the details 6.4.2.2 The hazop requirements for the safety evaluation method are good, but as the core element of the evaluation, they are a bit limited, and there are also danger sources that hazop cannot identify. It seems that the Work Safety Supervision Bureau is too smart in its calculations, and it costs Qing Qing's life. It seems that someone is going to be unlucky and doesn't understand anything.
The same problem in 225 as in 255 seems to have really confused a lot of people.
If you study the details carefully and follow them strictly, you will be dizzy!
How do people generally do quantitative risk assessments now?
The original poster is right. Thank you for providing such a clear opinion for us to think about: hug:
The actual operation and the content of the file still go separate ways.
The original poster’s analysis is absolutely perfect! This detailed rule is really confusing. Didn’t it say that it will be implemented on a trial basis for one year? Now that a year has passed, is there any new statement?
There is no new explanation, so let’s just follow the text!