Is the secondary packaging of hazardous chemicals considered a special operation?

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According to the special operations catalog in the "Regulations on Safety Technical Training and Assessment Management of Special Operators" newly promulgated by the General Administration, there is a hazardous chemical process involved in the safe operation of hazardous chemicals that our company involves, and employees who operate this type of hazardous chemicals need to obtain a certificate. But there is one thing that you need help from CNOOC to discuss.: Is secondary packaging considered a special operation? Our company's products are not granular after crystallization. The first packaging is LDPE plastic sealing, and the second packaging is cardboard box packaging. Nowadays, secondary packaging is outsourced. For various reasons, employees’ educational background does not reach high school. If secondary packaging is also a special operation involving hazardous chemicals, then the employment of these people will be affected. I carefully checked the definition of special operations: The term "special operations" as mentioned in these regulations refers to operations that are prone to accidents and may cause major harm to the safety and health of the operator, others, and the safety of equipment and facilities. However, the secondary packaging does not directly contact the product. Occasionally, particles of dust may be scattered from the packaging, but this will never cause major harm to the safety and health of the operator, others, or the safety of equipment and facilities. So I would like to ask CNOOC to help you analyze it. It would be best if the supervisors of the safety supervision system can clear up the clouds and see the light of day. Although it is said that safety levels need to be improved, packers are also employees, and it is unjustifiable to take someone else's job for no reason. I am worried.