Change in process raw materials
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The raw material in the production process has been changed from methanol to ethanol; is it necessary to conduct a feasibility study before making this design change? Are there any relevant legal and regulatory documents to support this? The enterprise is a company based in Shandong
Mature processes don’t need to be proven, right?
It’s not the same raw material; the manufacturing process has changed! A process validation must definitely be carried out!
It’s definitely necessary; this security department needs to conduct an inspection
Let’s first study these documents: \"Basic Specifications for Standardizing Work Safety in Enterprises\" GB/T 33000-2016, \"General Specifications for Standardizing Safety in Hazardous Chemicals Handling Enterprises\" AQ3013-2008, \"Guiding Opinions of the State Administration of Work Safety on Strengthening Safety Management in Chemical Processes\" An Jian Zong Guan San [2013] No. 88, \"Guidelines for Implementing Process Safety Management in Chemical Enterprises\" AQ/T 3034-2010, and \"Specifications for Implementing Change Management in Chemical Enterprises\" T/CCSAS 007—2020. There are also other documents regarding requirements for change management, but the above ones are the most important. The requirements for change management were drawn from many bloody lessons.
Change management is primarily aimed at risk management; risk identification is necessary for process and technical changes, and the HAZOP analysis method is generally used. References include the \"Guiding Opinions of the State Administration for Work Safety on Strengthening the Safety Management of Chemical Processes\" (An Jian Zong Guan San [2013] No. 88), the \"Guidelines for the Implementation of Process Safety Management in Chemical Enterprises\" (AQ/T 3034-2010), and the \"Specifications for the Implementation of Change Management in Chemical Enterprises\" (T/CCSAS 007—2020)
Change management is primarily about risk management; risk identification is required for process and technical changes, and the HAZOP analysis method is generally used for this purpose. For the change process, please refer to: 1. \"Guiding Opinions of the State Administration of Work Safety on Strengthening the Safety Management of Chemical Processes\", An Jian Zong Guan San [2013] No. 88; 2. \"Guidelines for the Implementation of Process Safety Management in Chemical Enterprises\", AQ/T 3034-2010; 3. \"Specifications for the Implementation of Change Management in Chemical Enterprises\", T/CCSAS 007—2020; 4. 3036
1. The regulations and requirements set by local authorities. 2. Requirements from the original general administration and ministry documents. What matters are the local requirements; in some places, procedures can be simplified for such changes as long as safety conditions are not compromised. At the very least, there should be design changes and acceptance to make it complete. Reference.