What are the procedures for the \"three simultaneities\" requirement for hazardous substance-using units? What procedures are needed for all of these?
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According to current regulations, what are the procedures for safety assessments, design reviews, trial production, acceptance, use licenses, and hazard registration? I earnestly request advice from those more knowledgeable; I am deeply grateful
We produce carbon fiber using acrylonitrile; should we be considered a hazardous substance handling unit?
Under the three simultaneities requirement, you must conduct a safety pre-assessment as soon as the feasibility study report is ready; after that, the report needs to be submitted first. Next, a dedicated section on the design of safety facilities should be prepared, and a trial production report should be drafted for approval by the safety supervision agency and other relevant authorities. It is only after 180 days that an application can be submitted for the completion inspection of the safety facilities. During this period, efforts must be made to achieve safety standardization, and it is necessary to apply for a **chemical registration certificate by registering an account at the **** Chemical Registration Center. Safety labels and safety data sheets also need to be prepared, with standards governing their creation. In addition, a production safety emergency response plan must be developed and filed with the safety supervision agency and other authorities. Only after going through all these procedures can an application be submitted for inspection.
I. **Review of the “three simultaneities” requirement for chemical construction projects: Relevant basis:** In accordance with Order No. 45 issued by the State Administration for Work Safety, the **Measures for the Supervision and Management of Safety in Chemical Construction Projects**, the procedures for reviewing the “three simultaneities” requirement for such projects are carried out； It is the responsibility of the local work safety supervision departments to handle this matter; detailed information can be found on the official websites of these local work safety agencies. Below are the local requirements:
Review of safety conditions for construction projects
(1) Application form and relevant documents for the review of safety conditions for construction projects ； (2) Report on the assessment of safety conditions for the construction project ； (3) Safety assessment report for the construction project ； (4) Documents approving, authorizing, or registering the construction project and planning-related documents (copies) ； (5) A copy of the business license issued by the administrative department for industry and commerce, or the notice of prior approval for the enterprise name. Review of the design of safety facilities for construction projects (1) Application form and documents for the review of the design of safety facilities for construction projects ； (2) Proof of design qualification from the design agency (copy) ； (3) Special section on the design of safety facilities for the construction project. Pilot production (use) of construction project (1) Registration form for pilot production (use) plan ； (2) Pilot production (use) plan ； (3) Opinions of the design, construction, and supervision units on the trial production (use) plan and whether the conditions for trial production (use) are met ； (4) Experts’ comments on the trial production (use) plan ； (5) Report on significant changes in the design of safety facilities ； (6) Report on the implementation of safety facility design during construction ； (7) Report on deficiencies in organizational design, inspections of project quality and potential risks, as well as the implementation of corrective measures ； (8) Qualification certificates (copies) of the construction and supervision units for the project ； (9) Quality supervision procedures for construction projects (copy) ； (10) Certificates of the principal person in charge, safety production management personnel, and registered safety engineers (copies), as well as a list of personnel engaged in special operations ； (11) Proof of successful safety education and training for employees ； (12) Explanation of the provision of labor protection equipment ； (13) Documents on the safety production responsibility system, list of safety production regulations and rules, list of safety operating procedures for various positions ； (14) Documents (copies) establishing the work safety management organization and appointing full-time work safety management personnel. Completion inspection of safety facilities for construction projects (1) Application form and documents for the completion inspection of safety facilities in construction projects ； (2) Report on the construction and supervision of safety facilities for the construction project ； (3) Safety acceptance evaluation report for construction project ； II. Procedures for obtaining a **chemical use license and required application documents 1. Licensing procedures: (i) Enterprises at the municipal level or above shall submit their application documents directly to the Municipal Work Safety Supervision Bureau. For the application materials required to obtain permits from other enterprises, they must first be reviewed and approved by the county-level work safety supervision agency, which will issue a formal opinion confirming that the requirements for issuing a permit are met (indicating that the safety conditions are satisfied and approval is given for the application). Only after that can the enterprise submit the application to the municipal work safety supervision agency. For those with production and storage devices and facilities, it shall be handled in accordance with **Order No. 8 of the Bureau. (II) The municipal work safety supervision bureau shall examine the application materials for issuing permits; in principle, it should organize experts and the county-level work safety supervision bureaus to conduct on-site inspections, or delegate such inspections to the county-level bureaus, and issue an opinion on the on-site safety inspection. The enterprise makes corrections and improvements based on the results of the document review and on-site inspections; once it passes the acceptance checks, the county-level work safety supervision agency issues its approval, after which the enterprise submits an application to the municipal work safety supervision agency. Applications that are incomplete or not in compliance with the required standards, those where on-site inspections fail to meet safety requirements, and those in which potential hazards are not rectified as required will not be processed. 2. Application documents: **When applying for a license, the entity using the chemical shall submit the following documents and be responsible for their accuracy: (1) **Application Form for Chemical Use License** (three copies) ； (II) Safety assessment report ； (III) Copy of the business license or notice of pre-approval of the business name ； (IV) Replicas of property rights or lease agreement documents for the premises and facilities used for storage ； (5) Fire safety inspection documents for the buildings where use and storage take place ； (VI) Valid professional qualification certificates and copies for the main persons in charge and supervisors of the unit, as well as for safety production management personnel and special operation personnel ； (7) Safety management systems, safety operation procedures for specific positions, and practical emergency response plans ； (8) Proof of insurance coverage in accordance with the law ； (IX) Certificate of payment of the safety production risk deposit in accordance with the standards ； (10) Panoramic color photos of important areas such as tank farms, warehouses, and work sites ； (11) Gas stations and **chemical trading enterprises with storage facilities** that apply for a chemical trading license must follow the procedures stipulated in **Order No. 8 of the Bureau**; in addition, they must submit electrical inspection reports, lightning protection inspection reports, and certificates of compliance with fire safety regulations ； ( XII) On-site Safety Inspection Report ； (13) Other materials required by laws and regulations. III. **Processing of chemical registration certificates: Basis: Article 13 of the **Regulations on Chemical Registration. Chemical registration is carried out in accordance with the following procedures: (1) The registering enterprise submits an application through the registration system ； (II) The registration office shall conduct a preliminary review of the applications submitted by the enterprises seeking registration within 3 working days; if the requirements are met, it shall notify the enterprises through the registration system to proceed with the registration procedures ； (III) Upon receiving notification from the registration office, the registered enterprise shall fill in the registration details accurately in the registration system in accordance with relevant requirements, and submit the relevant paper-based registration documents to the registration office ； (IV) Within 20 working days from the date of receiving the registration documents from the enterprise seeking registration, the registration office shall examine each item of the registration documents and the details provided for registration; if necessary, on-site inspections may be conducted. If all requirements are met, the registration documents will be submitted to the registration center ； Those that do not meet the requirements will be notified to the registering enterprise through the registration system, along with the reasons ； (5) Within 15 working days from the date of receiving the registration documents submitted by the registration office, the registration center shall examine those documents and the information contained therein; if they meet the requirements, it shall issue a **Chemical Registration Certificate to the registered enterprise through the registration office ； Those that do not meet the requirements shall inform the registration office and the registering enterprise through the registration system, along with an explanation of the reasons. The time required for an registered enterprise to modify its registration documents and address identified issues is not included in the period specified in the preceding clause. Article 14: When registering **chemicals, registered enterprises shall submit the following documents and be responsible for the accuracy of their contents: (1) Two copies of the **Chemical Registration Form ； (II) A copy of the business license of the manufacturing enterprise, and a copy of the registration form for foreign trade operators of the importing enterprise, as well as the qualification certificate for import and export enterprises of the People’s Republic of China, or the approval certificate for foreign-invested enterprises in the People’s Republic of China, or the approval certificate for enterprises invested by people from Taiwan, Hong Kong, Macao and overseas Chinese ； (III) One copy each of the chemical safety data sheet and the chemical safety label that are **consistent with** the chemicals they produce or import and that meet the relevant standards ； (IV) 1 copy of the emergency consultation service phone number that meets the requirements specified in Article 22 of these measures, or a copy of the authorization letter for emergency consultation services ； (5) Standards for the **chemical products** to be registered (if **standards** or industry standards are adopted, provide the standard numbers used).
Review of safety conditions for construction projects
(1) Application form and relevant documents for the review of safety conditions for construction projects ； (2) Report on the assessment of safety conditions for the construction project ； (3) Safety assessment report for the construction project ； (4) Documents approving, authorizing, or registering the construction project and planning-related documents (copies) ； (5) A copy of the business license issued by the administrative department for industry and commerce, or the notice of prior approval for the enterprise name. Review of the design of safety facilities for construction projects (1) Application form and documents for the review of the design of safety facilities for construction projects ； (2) Proof of design qualification from the design agency (copy) ； (3) Special section on the design of safety facilities for the construction project. Pilot production (use) of construction project (1) Registration form for pilot production (use) plan ； (2) Pilot production (use) plan ； (3) Opinions of the design, construction, and supervision units on the trial production (use) plan and whether the conditions for trial production (use) are met ； (4) Experts’ comments on the trial production (use) plan ； (5) Report on significant changes in the design of safety facilities ； (6) Report on the implementation of safety facility design during construction ； (7) Report on deficiencies in organizational design, inspections of project quality and potential risks, as well as the implementation of corrective measures ； (8) Qualification certificates (copies) of the construction and supervision units for the project ； (9) Quality supervision procedures for construction projects (copy) ； (10) Certificates of the principal person in charge, safety production management personnel, and registered safety engineers (copies), as well as a list of personnel engaged in special operations ； (11) Proof of successful safety education and training for employees ； (12) Explanation of the provision of labor protection equipment ； (13) Documents on the safety production responsibility system, list of safety production regulations and rules, list of safety operating procedures for various positions ； (14) Documents (copies) establishing the work safety management organization and appointing full-time work safety management personnel. Completion inspection of safety facilities for construction projects (1) Application form and documents for the completion inspection of safety facilities in construction projects ； (2) Report on the construction and supervision of safety facilities for the construction project ； (3) Safety acceptance evaluation report for construction project ； II. Procedures for obtaining a **chemical use license and required application documents 1. Licensing procedures: (i) Enterprises at the municipal level or above shall submit their application documents directly to the Municipal Work Safety Supervision Bureau. For the application materials required to obtain permits from other enterprises, they must first be reviewed and approved by the county-level work safety supervision agency, which will issue a formal opinion confirming that the requirements for issuing a permit are met (indicating that the safety conditions are satisfied and approval is given for the application). Only after that can the enterprise submit the application to the municipal work safety supervision agency. For those with production and storage devices and facilities, it shall be handled in accordance with **Order No. 8 of the Bureau. (II) The municipal work safety supervision bureau shall examine the application materials for issuing permits; in principle, it should organize experts and the county-level work safety supervision bureaus to conduct on-site inspections, or delegate such inspections to the county-level bureaus, and issue an opinion on the on-site safety inspection. The enterprise makes corrections and improvements based on the results of the document review and on-site inspections; once it passes the acceptance checks, the county-level work safety supervision agency issues its approval, after which the enterprise submits an application to the municipal work safety supervision agency. Applications that are incomplete or not in compliance with the required standards, those where on-site inspections fail to meet safety requirements, and those in which potential hazards are not rectified as required will not be processed. 2. Application documents: **When applying for a license, the entity using the chemical shall submit the following documents and be responsible for their accuracy: (1) **Application Form for Chemical Use License** (three copies) ； (II) Safety assessment report ； (III) Copy of the business license or notice of pre-approval of the business name ； (IV) Replicas of property rights or lease agreement documents for the premises and facilities used for storage ； (5) Fire safety inspection documents for the buildings where use and storage take place ； (VI) Valid professional qualification certificates and copies for the main persons in charge and supervisors of the unit, as well as for safety production management personnel and special operation personnel ； (7) Safety management systems, safety operation procedures for specific positions, and practical emergency response plans ； (8) Proof of insurance coverage in accordance with the law ； (IX) Certificate of payment of the safety production risk deposit in accordance with the standards ； (10) Panoramic color photos of important areas such as tank farms, warehouses, and work sites ； (11) Gas stations and **chemical trading enterprises with storage facilities** that apply for a chemical trading license must follow the procedures stipulated in **Order No. 8 of the Bureau**; in addition, they must submit electrical inspection reports, lightning protection inspection reports, and certificates of compliance with fire safety regulations ； ( XII) On-site Safety Inspection Report ； (13) Other materials required by laws and regulations. III. **Processing of chemical registration certificates: Basis: Article 13 of the **Regulations on Chemical Registration. Chemical registration is carried out in accordance with the following procedures: (1) The registering enterprise submits an application through the registration system ； (II) The registration office shall conduct a preliminary review of the applications submitted by the enterprises seeking registration within 3 working days; if the requirements are met, it shall notify the enterprises through the registration system to proceed with the registration procedures ； (III) Upon receiving notification from the registration office, the registered enterprise shall fill in the registration details accurately in the registration system in accordance with relevant requirements, and submit the relevant paper-based registration documents to the registration office ； (IV) Within 20 working days from the date of receiving the registration documents from the enterprise seeking registration, the registration office shall examine each item of the registration documents and the details provided for registration; if necessary, on-site inspections may be conducted. If all requirements are met, the registration documents will be submitted to the registration center ； Those that do not meet the requirements will be notified to the registering enterprise through the registration system, along with the reasons ； (5) Within 15 working days from the date of receiving the registration documents submitted by the registration office, the registration center shall examine those documents and the information contained therein; if they meet the requirements, it shall issue a **Chemical Registration Certificate to the registered enterprise through the registration office ； Those that do not meet the requirements shall inform the registration office and the registering enterprise through the registration system, along with an explanation of the reasons. The time required for an registered enterprise to modify its registration documents and address identified issues is not included in the period specified in the preceding clause. Article 14: When registering **chemicals, registered enterprises shall submit the following documents and be responsible for the accuracy of their contents: (1) Two copies of the **Chemical Registration Form ； (II) A copy of the business license of the manufacturing enterprise, and a copy of the registration form for foreign trade operators of the importing enterprise, as well as the qualification certificate for import and export enterprises of the People’s Republic of China, or the approval certificate for foreign-invested enterprises in the People’s Republic of China, or the approval certificate for enterprises invested by people from Taiwan, Hong Kong, Macao and overseas Chinese ； (III) One copy each of the chemical safety data sheet and the chemical safety label that are **consistent with** the chemicals they produce or import and that meet the relevant standards ； (IV) 1 copy of the emergency consultation service phone number that meets the requirements specified in Article 22 of these measures, or a copy of the authorization letter for emergency consultation services ； (5) Standards for the **chemical products** to be registered (if **standards** or industry standards are adopted, provide the standard numbers used).
I hope you will pay close attention to this document — the **Implementation Measures for the Permit for the Safe Use of Chemicals** (issued by Order No. 57 of the State Administration of Work Safety on November 16, 2012, and amended by Order No. 79 of the State Administration of Work Safety on May 27, 2015).
Order No. 57 only outlines the procedures and documents required to apply for a use permit; what are the steps to follow for the simultaneous implementation of safety, environmental, and operational requirements in early stages of hazardous chemical use projects? Thank you
If you are merely a unit using hazardous substances, then the requirements regarding simultaneous implementation of various measures in the project’s initial stage shall be complied with in accordance with Order No. 36 issued by the State Administration for Work Safety (as amended by Order No. 77).