«Judgment Criteria» for 20 Major Accident Hazards in Chemical Enterprises

1. The principal persons in charge and safety production management personnel of hazardous chemical production and operation units have not passed the required assessments in accordance with the law. In recent years, investigations into accidents in the chemical (hazardous chemicals) industry have revealed common issues among the companies involved: a lack of legal awareness and safety risk awareness among key executives and safety managers, insufficient knowledge of safety management practices, and safety management capabilities that are not adequate to meet the requirements of safe production. Human factors are the most important constraint on safe production in the chemical (hazardous chemicals) industry. Safe production of hazardous chemicals is a task that requires a high degree of scientific knowledge and professionalism. Only by firmly establishing an awareness of safety limits and risks, and by mastering the basic knowledge related to the safe production of hazardous chemicals as well as the essential skills for safety management, can the key executives and safety management personnel in enterprises truly fulfill their responsibilities regarding safe production. The Work Safety Law, the Regulations on the Safety Management of Hazardous Chemicals, and the Provisions on Safety Training for Production and Business Entities (**Order No. 3 of the State Administration for Work Safety**) all set clear requirements regarding the training and assessment of employees in hazardous chemical production and business entities. Article 24 of the Work Safety Law stipulates that the principal persons in charge of production and business entities, as well as those responsible for work safety, must possess the work safety knowledge and management skills necessary for the types of production and business activities carried out by their respective entities. The principal persons in charge and safety production management personnel of units that produce, operate, or store hazardous materials, as well as those in mining, metal smelting, construction, and road transportation industries, must pass assessments conducted by the competent departments responsible for safety production supervision to prove their knowledge of safety production and their management capabilities. Assessments shall not be charged.” The Provisions on Safety Training for Production and Business Operations stipulate that the principal persons in charge and safety production management personnel of entities engaged in the production and operation of hazardous chemicals must pass an assessment of their safety production knowledge and management capabilities by the safety production supervision and inspection authorities within 6 months from the date of taking up their positions. On January 25, 2017, the **General Administration of Work Safety issued the \"Key Assessment Points for Safety Management Knowledge of Key Persons in Charge of Chemical (Hazardous Chemicals) Enterprises (First Edition)\” and the \"Key Assessment Points for Safety Management Knowledge of Safety Management Personnel in Chemical (Hazardous Chemicals) Enterprises (First Edition)\” (Document No. An Jian Zong Ting Xuan Jiao [2017] 15), setting clear requirements regarding the key areas that need to be assessed for such enterprise leaders and safety managers. The departments responsible for work safety supervision and management are required to assess the relevant personnel in accordance with relevant laws and regulations.

II. Special operation personnel are working without proper certificates. Safety risks in special operation positions are relatively high, and they require a high level of professional competence from the personnel. In recent years, accidents have occurred frequently due to untrained personnel without the necessary qualifications working in special operation roles. The \"5·13\" chlorine poisoning incident in Cangzhou, Hebei in 2017, the severe explosion incident on \"6·5\" in Linyi, Shandong, and the explosion incident on \"7·2\" in Jiujiang, Jiangxi, all revealed the problem of accidents arising from people working in such roles without proper certification and from their insufficient professional skills. The Work Safety Law and the Provisions on the Administration of Safety Technology Training and Assessment for Special-Type Workers (**Order No. 30 of the State Administration of Work Safety**) set clear requirements regarding the training and corresponding qualifications for special-type workers; for example, workers engaged in hazardous chemical-related tasks must have a high school education or an equivalent level of education or higher. As stipulated, for special types of work involved in the production and operation of chemicals and hazardous chemicals, in addition to common types of work such as electrical work, welding and thermal cutting, and work at heights, these also include operations related to hazardous chemical processing processes, as well as the installation, repair, and maintenance of chemical automation control instruments (covering 15 types of hazardous processing processes including phosgene and phosgenation processes, chlor-alkali electrolysis processes, chlorination processes, nitration processes, ammonia synthesis processes, cracking processes, fluorination processes, hydrogenation processes, diazotization processes, oxidation processes, peroxidation processes, amination processes, sulfonation processes, polymerization processes, and alkylation processes, along with the installation, repair, and maintenance of chemical automation control instruments). Personnel performing the aforementioned tasks must undergo training and assessment to obtain a special operation permit. Those working without a license should be classified as major accident hazards.

III. The external safety protection distances for production units and storage facilities related to the “two key areas and one major issue” do not meet the **standard requirements. The main purpose of this provision is to require relevant entities to establish external safety protection distances in accordance with regulatory standards as buffer zones, in order to prevent severe casualties and property losses resulting from fires, explosions, or toxic gas leaks at hazardous chemical production facilities and storage sites. The external safety protection distance is neither a fire prevention distance nor a health protection distance; it should be determined scientifically based on the type and quantity of hazardous chemicals, as well as the risk levels acceptable to individuals and society. Setting an external safety distance is a common practice in international risk management. In May 2014, the **General Administration of Work Safety issued Announcement No. 13, \"Personal and Societal Acceptable Risk Standards for Hazardous Chemicals Production and Storage Facilities (Trial)\」, which established standards for the external safety protection distances required for newly built, renovated, expanded, and existing production and storage facilities of hazardous chemicals enterprises on land. At the same time, standards such as the \"Code for Fire Protection Design of Petrochemical Enterprises\" (GB50160-2008) and the \"Code for Fire Protection Design of Buildings\" (GB50016-2014) specify requirements regarding the external distances of production units, storage facilities, and other buildings; production units and storage facilities that fall under the category of \"two key areas and one major hazard\" must also meet these requirements. In the 2009 \"7·15\" explosion incident in Luoyang, Henan, the safety distance between the enterprise and the surrounding residential areas was severely insufficient; the accident resulted in 8 deaths, 8 severe injuries, and 108 residents in the vicinity were injured by glass shards caused by the explosion’s shock waves.

IV. The units involving key hazardous chemical processes that are subject to strict supervision do not have automated control systems; the systems lack emergency shutdown functions, and the automated control systems and emergency shutdown systems installed are not in use. The “Implementation Measures for Safety Production Licenses of Hazardous Chemicals Production Enterprises” (Order No. 41 issued by the State Administration for Work Safety) require that automated control systems be installed in facilities that involve hazardous chemical processes or key chemicals subject to strict supervision ； Large-scale chemical plants involving hazardous chemical processes are equipped with emergency shutdown systems.” In recent years, enterprises involved in high-risk chemical processes that are subject to strict regulation have adopted automated control systems and emergency shutdown systems to reduce the number of operators in high-risk areas such as plant zones, thereby improving the intrinsic safety level of the production facilities. However, some enterprises involved in high-risk chemical processes that are subject to strict supervision have not implemented automated control and emergency shutdown functions as required, or they have installed such systems but fail to use them properly. On December 9, 2017, an explosion occurred in the dichlorobenzene production facility of Juxin Biotechnology Co., Ltd. in Lianyungang City, Jiangsu Province. This explosion caused the collapse of Workshop 4, where the facility was located, as well as adjacent Workshop 6. The incident resulted in 10 deaths and 1 injury. The low level of automation in the facility and the large number of workers on site were key factors contributing to the severe casualties.

V. The hazardous chemical storage areas that constitute Class I and Class II major hazard sources do not have an emergency shutdown function； The hazardous chemical storage areas that constitute Class I and Class II major hazard sources involving toxic gases, liquefied gases, and highly toxic liquids are not equipped with independent safety instrument systems. The Interim Provisions on the Supervision and Management of Major Hazard Sources of Hazardous Chemicals (**Order No. 40 of the State Administration for Work Safety**) require that \"major hazard sources of Grade 1 or Grade 2 be equipped with emergency shutdown systems,\" and that \"major hazard sources of Grade 1 or Grade 2 involving toxic gases, liquefied gases, or highly toxic liquids be equipped with independent safety instrumented systems.\" In chemical storage areas that constitute level 1 and level 2 major hazard sources, due to the severe consequences of accidents, emergency shutdown systems must be installed in each storage tank to enable emergency isolation. For storage tanks directly connected to upstream production units, if installing an emergency shut-off device could lead to abnormalities such as overpressure in the production units, an emergency switching mechanism can be employed to prevent issues like excessive liquid levels or overpressure in the tanks, thereby fulfilling the function of emergency shutdown. On July 16, 2010, an explosion occurred in the oil pipeline at the crude oil depot of Dalian CNPC International Storage and Transportation Company, triggering a fire and resulting in a large-scale spill of crude oil. The accident caused 1 death and 1 injury, with direct economic losses amounting to 223.3019 million yuan. A key reason for the escalation of this accident was the absence of an emergency shutoff system in the crude oil storage tank that leaked; the crude oil continued to flow out of the tank without being able to be stopped urgently, which led to the spread of the fire. On January 7, 2010, a fire and explosion occurred at tank area 316# of the synthetic rubber plant at Lanzhou Petrochemical Company, resulting in 6 deaths, 1 person seriously injured, and 5 people lightly injured. As the C4 material leaked and vaporized within the fire dike, it became impossible for personnel to approach and shut off the bottom valve; furthermore, the storage tank involved in the accident was not equipped with an emergency shutdown system, which led to a massive leakage of the material.

VI. The fully pressurized liquefied hydrocarbon storage tanks do not have water injection measures in place in accordance with **standards. When a fully pressurized storage tank leaks, filling the tank with water to raise the level of the liquefied hydrocarbon and submerging the leak site underwater can reduce or prevent the leakage of liquefied hydrocarbons, thus nipping the accident in the bud. On March 5, 1998, a leak, fire, and explosion occurred in a liquefied gas storage tank at the Liquefied Gas Management Office of Xi’an Gas Company, resulting in 12 deaths. The main cause was a failure in the sealing of the flange above the drainage valve of the 400 m³ spherical tank; the attempt to seal the leak failed, which led to the fire and explosion. Article 6.3.16 of the Code for Fire Protection Design of Petrochemical Enterprises (GB50160-2008) requires that \"full-pressure storage tanks shall be equipped with water injection measures to prevent the leakage of liquefied hydrocarbons.\" Clause 7.4 of the \"Code for Safety Design of Spherical Storage Tanks for Liquefied Hydrocarbons\" (SH3136-2003) requires that \"spherical storage tanks for propylene, propane, mixed C4, raffinate C4, and liquefied petroleum gas shall be equipped with water injection facilities.\" The installation of water filling measures for fully pressurized liquefied hydrocarbon storage tanks must go through proper design, construction, and acceptance procedures. The design of water injection measures should be guided by the principles of safety, speed, effectiveness, and ease of operation; remote control valves with manual functions should be installed, in compliance with the provisions of **relevant standards. Liquefied hydrocarbon storage tanks that require the installation of water injection facilities are mainly normal-temperature, full-pressure liquefied hydrocarbon storage tanks; water injection measures may not be necessary for semi-frozen pressure liquefied hydrocarbon storage tanks (such as those for ethylene) or storage tanks for certain liquefied hydrocarbons that react upon contact with water (such as chloromethane). Furthermore, the established water injection measures should ensure an adequate supply of water for injection, meet the requirements in emergency situations, and fully leverage the effectiveness of these measures.

VII. For the filling of flammable, explosive, toxic, and harmful liquefied gases such as liquefied hydrocarbons, liquid ammonia, and liquid chlorine, a universal piping filling system is not used. Flammable, explosive, toxic, and harmful liquefied gases such as liquefied hydrocarbons, liquid ammonia, and liquid chlorine pose high safety risks during filling; in the event of a leak, they can easily cause explosions, fires, and poisoning incidents. The universal pipeline filling system features flexible rotation, high sealing reliability, low risk of static electricity, and a long service life. Its safety performance is far superior to that of metal hoses, and it is easy to operate, enabling effective reduction of safety risks during the filling of flammable, explosive, toxic, and harmful liquefied gases such as liquefied hydrocarbons, liquid ammonia, and liquid chlorine. The \"Guiding Opinions on Further Strengthening Work Safety in the Handling of Hazardous Chemicals\" issued by the Office of the State Council’s Work Safety Committee (Anwei Ban [2008] No. 26), as well as the \"Implementation Opinions on Ensuring That Hazardous Chemical Enterprises Comply with the State Council’s Guidelines on Further Strengthening Enterprise Work Safety\" issued by the State Administration of Work Safety and the Ministry of Industry and Information Technology (Anjian Zongguan San [2010] No. 186), both require that metal universal piping systems be used instead of filling hoses in the process of filling hazardous chemicals. The use of hoses for filling liquid chlorine, liquid ammonia, liquefied petroleum gas, liquefied natural gas, and other liquefied hazardous chemicals is prohibited. The \"Code for Fire Protection Design of Petrochemical Enterprises\" (GB50160-2008) sets high requirements for the loading and unloading of liquefied hydrocarbons and flammable liquids. Paragraph 6 of Article 6.4.2 stipulates as a mandatory requirement that \"underwater loading and unloading nozzles shall be used for the loading and unloading of Class A B, Class B, and Class C A liquids.\" Article 6.4.3 states that \"1. Liquefied hydrocarbons (i.e., Class A flammable liquids) must not be discharged on-site\" ； 2. The loading and unloading cranes for low-temperature liquefied hydrocarbons should be installed separately.” On September 18, 2015, an ammonia synthesis leak occurred at Henan Zhonghong Coal Chemical Company, resulting in the poisoning of some villagers living near the plant. The cause of the accident was a rupture in the metal hose at the bottom of the ammonia synthesis tower in the chemical plant area of Zhonghong Coal Chemical Company, which led to an ammonia leak.

VIII. Pipelines for highly toxic gases such as phosgene and chlorine, as well as hydrogen sulfide, passing through public areas other than factory premises (including chemical parks and industrial parks). The Provisions on the Safety Management of Hazardous Chemical Pipeline Transportation (Order No. 43 of the State Administration for Work Safety) require that pipelines carrying highly toxic chemicals such as phosgene and chlorine be prohibited from passing through public areas; strict controls are also imposed on pipelines carrying other toxic gases such as ammonia and hydrogen sulfide when they pass through public areas. With the rapid development of China’s economy and the accelerating pace of urbanization, some pipelines for transporting hazardous chemicals have gradually found themselves surrounded by newly built residential and commercial areas, moving away from previously remote suburban areas. In the event of a leak from such toxic gas pipelines that pass through public areas, it can pose a serious threat to the lives of the residents living in those areas. At the same time, chlorine, phosgene, and hydrogen sulfide all have densities greater than that of air and are highly corrosive; they can corrode equipment, leading to its failure. In the event of a leak, they can easily cause serious accidents. For example, the \"4·16\" chlorine leak and explosion incident that occurred at Tianyuan Chemical Plant in Chongqing in 2004 was caused by long-term corrosion and perforation of the equipment, which led to an explosion in the liquid chlorine storage tank and subsequent release of chlorine gas. Additional explosions occurred during the efforts to control the accident, resulting in 9 deaths, 3 injuries, and the urgent evacuation of 150,000 people.

X. Operating chemical plants lack proper design and have not undergone safety design assessments. The main purpose of this provision is to control safety risks at the source for entities engaged in the production and operation of chemical and hazardous substances, to ensure compliance with safety production requirements, and to improve the intrinsic safety level of existing chemical plants. In some areas, certain chemical processing units that were built early on lack proper design or were designed by entities without the appropriate qualifications; as a result, their planning, layout, processes, equipment, and automated control systems fail to meet safety requirements, resulting in unknown or high safety risks. In June 2012, the **General Administration of Work Safety**, the **National Development and Reform Commission**, the Ministry of Industry and Information Technology, and the Ministry of Housing and Urban-Rural Development jointly issued the \"Notice on Carrying Out a Special Campaign to Improve the Inherent Safety Level in the Hazardous Chemicals Sector\" (An Jian Zong Guan San [2012] No. 87), which required safety design assessments to be conducted on existing chemical plants that had not been designed properly, in order to eliminate all potential safety hazards. In June 2013, the **General Administration of Work Safety and the Ministry of Housing and Urban-Rural Development jointly issued the \"Notice on Further Strengthening the Safety Design Management of Hazardous Chemicals Construction Projects\" (An Jian Zong Guan San [2013] No. 76), which stipulated that the design units for such projects must possess the relevant engineering design qualifications in the fields of chemicals, petrochemicals, pharmaceuticals, oil and gas (offshore oil), etc., as specified in the \"Engineering Design Qualification Standards\" issued by the former Ministry of Construction (Jian Shi [2007] No. 86) ； For large-scale construction projects involving highly regulated hazardous chemical processes, highly regulated hazardous chemicals, and major hazard sources of hazardous chemicals, the design unit must possess a comprehensive engineering design qualification, or a corresponding professional qualification of grade A in the fields of chemical, petrochemical, pharmaceutical, or oil and gas (offshore oil) engineering. For new, modified, and expanded hazardous chemical construction projects, the design must be carried out by design firms that possess the appropriate qualifications and relevant design experience; safety design assessments for existing chemical plants should also be conducted in accordance with relevant requirements. For example, in 2012, during the serious explosion incident on February 28 in Zhaoxian County, Hebei Province, the company Kel Chemical Co., Ltd. did not carry out proper design; there were significant flaws in the layout of the facilities, the process technologies and procedures, the equipment and pipelines, the safety measures, as well as the automation controls.

11. Use processes and equipment listed in the catalog of obsolete and backward safety technologies and processes. Article 35 of the Work Safety Law stipulates that \"a system for phasing out processes and equipment that pose a serious threat to work safety shall be implemented; the specific list shall be formulated and published by the work safety supervision and management department of the State Council in conjunction with relevant departments of the State Council.\" Where laws or administrative regulations provide otherwise regarding the formulation of the catalog, such provisions shall apply. The people’s **s of provinces, autonomous regions, and municipalities directly under the Central Government may formulate and publish specific lists based on the actual conditions in their respective regions, in order to phase out those processes and equipment that pose a threat to production safety and are not covered by the provisions of the preceding paragraph. Production and business operations entities shall not use processes or equipment that have been phased out due to posing a threat to production safety. Therefore, the \"list of outdated safety technologies, processes, and equipment to be phased out\" mentioned in this clause refers to those processes and equipment specified in relevant documents such as the \"Notice on Issuing the List of Outdated Safety Technologies and Equipment to Be Phased Out (First Batch in 2015)\」 issued by the General Administration of Work Safety (An Jian Zong Tang Ke Ji [2015] No. 43) and the \"Notice on Issuing the List of Outdated Safety Technologies, Processes, and Equipment to Be Phased Out (2016)\」 (An Jian Zong Ke Ji [2016] No. 137); regions may also formulate and publish their own specific lists. For example, in the \"5·16\" accident that occurred in Jincheng, Shanxi, the enterprise in question used an outdated production process that had been explicitly banned – the indirect coke method for producing carbon disulfide. This process is prone to safety accidents such as leaks and poisonings during operation, posing significant safety risks.