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The Ministry of Emergency Management is seeking feedback on the \"Safety Management Standards for Fine Chemical Enterprises\" (draft for comment); those with suggestions are urged to submit them promptly

2024-10-07View Original

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The Ministry of Emergency Management is publicly seeking feedback on the \"Safety Management Standards for Fine Chemical Enterprises\" (draft for comment). (http://www.mem.gov.cn/gk/zfxxgkpt/fdzdgknr/202408/t20240826_498751.shtml)
Reply #22024-10-07
My opinion: Regarding clause 4.11, \"For processes involving highly regulated hazardous chemical reactions and Grignard reactions, the corresponding requirements in Appendix A of this document must also be met.\" ”And Appendix A Key Requirements for Safety Risk Control of Typical Hazardous Chemical Processes ; I believe that what was established at that time was based on pure chemical reactions ; But with the advancement of technology, some chemical reaction processes are no longer purely chemical reactions; some of them are bio-chemical reactions, such as those that use biological enzymes as catalysts. These reaction conditions are mild; typically, the reaction heat risk assessment assigns a level of 1 (the lowest). According to the safety measures recommended in the report, there is no need for such stringent safety measures as those required for typical hazardous chemical processes. It is recommended to specify the scope of application of this standard, which is intended for reactions between pure compounds only and is not applicable to reactions involving biological substances such as enzymes. It can be added that for reactions whose reaction heat risk assessment results are rated at level 1, the measures recommended in their reports can be followed, without necessarily adhering strictly to the basic safety control requirements outlined in Appendix A.

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