\"Ten Musts\" for Safety Supervision of Enterprises with Major Hazard Sources”

Thread Content

(1) It is necessary to fully complete the actions aimed at improving the level of intrinsic safety. By the end of June this year, the three-year special campaign launched by the State 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 to enhance the level of intrinsic safety in the chemical sector will come to an end; however, some tasks have not yet been fully implemented by enterprises. In such situations, it is recommended that safety supervision departments inform enterprises in writing that those failing to meet the requirements by the deadline will not have their safety production licenses extended, and they will be ordered to suspend operations ； For enterprises with no hope of improvement, it is recommended that the local **order their closure. (II) It is necessary to complete the acceptance assessment for meeting safety production standardization requirements. Safety production standardization is a responsibility and obligation imposed on enterprises by the new Safety Law; in other words, it is illegal for enterprises to fail to implement such standardization. (III) It is necessary to establish and improve safety management organizations. There should be independent, specialized organizations for work safety, with a sufficient number of safety management personnel assigned to them. More importantly, full-time safety management personnel should have a secondary vocational education degree or above in the field of chemistry and chemical engineering, or hold a professional technical title at the intermediate level or above in the same field. At the same time, the provision in the new Work Safety Law stating that \"enterprises shall have registered work safety engineers specializing in hazardous materials to handle work safety management\" must be strictly enforced, in order to put an end to the situation where those who have received training and obtained certificates do not actually carry out work safety management tasks, while those who are actually in charge of such tasks lack the necessary certifications. (IV) It is essential to strictly implement safety management systems. In recent years, many new national and industry standards have been introduced; the new Safety Law, as well as the Safety Regulations for Special Operations in Chemical Production Units (GB30871-2014), among others, impose higher requirements on enterprises’ safety practices. Companies must, in accordance with the new requirements, promptly revise and improve their management systems and operating procedures, and strictly enforce them throughout the process of production and operation management. It is particularly emphasized that all **chemicals production, operation, and filling units must establish comprehensive safety management systems and operating procedures for the shipping and loading/unloading processes, ensuring compliance with the \"four mandatory checks\": 1. It is necessary to verify that the vehicle’s Road Transport Permit, as well as the professional qualification certificates of the drivers, escorts, and those involved in loading/unloading operations, are appropriate for the goods being transported ； 2. It is necessary to check whether the pressure vessel is within its valid inspection period ； 3. It is necessary to check whether the vehicle is equipped with signs that meet **standard requirements (‘Signs for Vehicles Transporting Dangerous Goods by Road’ GB13392) ； 4. When selling **chemicals** or **explosives-prone chemicals**, it is necessary to verify the corresponding purchase licenses or certification documents. If the carrier lacks the necessary qualifications or operates outside its authorized scope, if its staff are unqualified, or if the transport vehicles or containers are not up to standard, shipments must not be dispatched or loading must not take place. Overloading, mixing different types of goods together, incorrect handling, and excessive load carrying are strictly prohibited. Transport vehicles that do not meet safety requirements must not be used to transport chemicals; it is essential to ensure safety at the source by conducting thorough inspections of all relevant procedures. At the same time, the hazardous materials sold by enterprises must be accompanied by a \"one document per item\" system; a registration system for product flow information should be established to record details such as the name of the goods, quantity, as well as information regarding the sender, carrier, buyer, and vehicle. These records must be retained for at least 1 year. This is not only a requirement for enterprises but also something that our safety inspectors must check when examining them. (5) It is necessary to establish and improve a system for identifying and addressing potential hazards. Addressing such hazards is the core of safety production prevention efforts. Enterprises must strictly comply with the requirements set out in the **General Administration of Work Safety’s “Guidelines for the Identification, Investigation, and Rectification of Hidden Dangers in Chemical Enterprises” (An Jian Zong Guan San [2012] No. 103)** and the **“Guiding Opinions on Strengthening Safety Management in Chemical Processes” (An Jian Zong Guan San No. 88)**. They should organize personnel from departments such as production, technology, and equipment to carefully identify the safety risks associated with their own enterprises, thoroughly investigate and rectify any existing hidden dangers, analyze in depth the causes of these dangers, and further improve the mechanisms for identifying and addressing such hazards. The identification and resolution of potential hazards should be carried out on a regular basis, in a sustainable manner, through established systems, and involving all employees. On top of conducting such inspections independently, experts should be hired every six months to help identify the underlying issues that affect the safe development of the enterprise. For enterprises that fail to hire experts to identify potential hazards, safety supervision departments at all levels should work together to step up supervision and enforcement efforts, and impose strict penalties in accordance with the law when such problems and hazards are detected. (VI) It is necessary to strengthen the control of major hazard sources. First, it is essential to determine the exact number of such sources; at present, the figure for major hazard sources in enterprises in general industries is not very accurate. Through the registration of major hazard sources, it is essential to obtain key information regarding each such source, including its name, location, quantity of hazardous materials stored there, the surrounding environment, routine monitoring measures, as well as emergency response plans in case of an accident, along with details on rescue teams and experts. Second, enterprises should be urged to conduct regular assessments of major hazard sources and keep records thereof; special attention should be paid to whether the issues identified in the assessment reports have been addressed, and whether the control measures for these major hazard sources have been properly implemented. Third, enterprises should establish emergency rescue teams and conduct regular emergency rescue drills, ensuring that such drills take place in normal times while emergency response is ready on site, so as to nip accidents in the bud. (7) It is necessary to strengthen safety supervision of enterprises engaged in the production and operation of fireworks and firecrackers. Common problems in such enterprises include production beyond approved staffing levels and dosage limits, employment of special workers without proper training, and a large number of people present during loading and unloading processes ； Wholesale enterprises engage in severe overstocking, deal in illegal non-standard finished products, and practice rough loading and unloading. It should be emphasized here that for manufacturing enterprises, it is not allowed for anyone to work without a valid license ； Second, it is necessary to strictly prevent exceeding the allowed number of workers, using excessive amounts of chemicals, altering the intended use of workshops without authorization, and subcontracting production lines ； Third, it is necessary to ensure that internal monitoring covers all key areas, with records being retained for 30 days; this serves as an important basis for safety supervision agencies to conduct routine oversight of enterprises and to retrieve evidence in the event of an accident ； Fourth, do not supply raw materials or sell products to illegal enterprises. Wholesale businesses shall not deal in illegal or non-standard products, shall not maintain excessive inventory, shall not store products outside designated locations, shall handle products with care during loading and unloading, and shall not exceed the permitted number of staff. (8) Strict enforcement of administrative permits for safe production is mandatory; all new chemical and pharmaceutical construction projects must be located within chemical industrial parks (concentrated chemical areas). Those that are not located in such parks will not be approved under any circumstances ； Any enterprise that does not meet the **industrial policies and entry requirements will have its new, revised, or expanded projects denied approval ； Any entity that fails to apply for an extension of its safety production and business operation licenses within the statutory time limits shall not engage in production or operations ； Enterprises whose production licenses have expired and are undergoing automation control upgrades are not allowed to resume operations under any circumstances ； It is strictly prohibited to carry out production while carrying out renovations ； Construction projects that have not completed the administrative procedures required for safe production shall not commence operations under any circumstances ； Enterprises that do not meet the conditions for safe production must be ordered to suspend operations immediately. Measures regarding enterprises that have ceased operations: For hazardous chemical enterprises that have stopped production, the relevant chemical processing units and equipment must be dismantled, and the licenses issued by the safety supervision authorities must be reclaimed to ensure complete cessation of production and prevent illegal operations ； For those carrying out design diagnostics or automated upgrades to existing chemical plants that have ceased operations, all rectifications must be completed by the end of the year. Those that fail to complete these tasks on time will have their relevant safety production licenses revoked; any subsequent production, operation, or use of such facilities will be treated as that of a newly established enterprise, requiring compliance with the \"three simultaneities\" requirements ； For those existing small chemical enterprises whose internal or external safety distances do not meet the requirements, or which have other serious safety hazards that cannot be rectified and lack the capacity to relocate to a chemical industrial park, their safety licenses shall be revoked and they shall be requested to be **closed down. Regarding the situations mentioned earlier in which production is absolutely not allowed to commence, the local work safety supervision agency must issue relevant documents and ensure strict oversight of their implementation; any violations shall be punished in accordance with the law, and the relevant licenses shall be temporarily seized or revoked. (IX) It is necessary to strengthen safety management during the trial production phase. Trial production of a construction project is an important stage for identifying and eliminating problems and defects in the project; it represents a comprehensive assessment of the safety and reliability of the project’s equipment, facilities, and processes. It is also the period with the highest risks, and where production safety accidents are most likely to occur. The project owner must attach great importance to safety management during the trial production phase. Before starting trial production, the project owner or general contractor should promptly organize engineering and technical personnel from design, construction, supervision, and production units to carry out the “three inspections and four determinations” (“the three inspections” mainly refer to checking for missing items in the design, assessing the quality of the work and any potential hazards, and examining any unfinished work)” ； “The “four fixations” refer to addressing the identified issues by \"setting tasks, assigning personnel, determining timelines, and specifying measures to be completed within a set deadline\". Strictly adhere to the working requirement that driving is not permitted until potential hazards are eliminated, conditions are met, and emergency response measures have been implemented. Under the new regulations, although the trial production plan does not require registration with the safety supervision authorities, and it is up to the enterprise to organize experts to evaluate the plan, this does not mean that oversight can be relaxed. The trial production phase is when accidents are most likely to occur; therefore, safety supervision agencies at all levels must strengthen supervision during and after this period, strictly control the duration of trial production, and require suspension of operations for rectification in case of any issues or if the trial production deadline is exceeded. (10) It is necessary to strictly enforce the regulations regarding the handling of companies involved in accidents. After a production safety accident occurs, in addition to imposing economic penalties in accordance with the law, there are also clear provisions regarding the suspension or revocation of safety licenses, and even the recommendation to shut down such companies. **The General Administration of Work Safety issued the \"Notice on Further Strengthening the Supervision and Management of Work Safety in Chemicals and Chemical Enterprises\" (An Jian Zong Guan San [2014] No. 46), which stipulates six requirements: First, in the event of a fatal accident, the company’s safety license shall be suspended for a period of not less than one month but not more than six months in accordance with the law ； Second, in the event of a fatal accident occurring during direct operations such as hot work or entry into confined spaces, their safety license shall be suspended for between 2 and 6 months in accordance with the law ； Third, in the event of a major accident or two death accidents occurring within one year, its safety license shall be temporarily suspended for not less than 3 months but not more than 6 months in accordance with the law ； Fourth, in the event of an accident of major severity or more, or two accidents of significant severity within one year, its safety license shall be revoked in accordance with the law. Fifth, for chemical and chemical manufacturing enterprises that, according to accident investigations, do not meet the requirements for safe production, they must be ordered to suspend operations for rectification; only after passing the inspection by the provincial safety supervision authorities can they resume production. Sixth, those that still do not meet the safety production requirements even after suspension of operations for rectification must be requested by the relevant local authorities to be closed down; for enterprises that have obtained safety licenses, such licenses must also be revoked in accordance with the law.