Are certifications required for atypical hazardous processes?
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This post was last edited by liibh on 2016-5-16 at 15:07. Our facility has a process that is classified as an atypical alkylation process in the safety design documentation. Some experts say that regardless of whether an alkylation process is atypical or typical, evidence collection is necessary for any alkylation process. So, should evidence indeed be collected?
Wrong. Our facility has a process that is identified in the safety design document as a non-typical alkylation process. Some experts say that regardless of whether an alkylation process is typical or non-typical, evidence collection is necessary for any alkylation process. So, should evidence indeed be collected?
Carry out evidence collection as required by the experts; evidence collection is necessary whenever it involves an alkylation process. It will be troublesome to request corrections during the safety inspection later on. Just check Order No. 30 issued by the General Administration to find out more.
I don’t agree with your view. Take the oxidation process as an example: any chemical reaction involving the gain or loss of electrons is a redox reaction, and thus falls under the category of oxidation processes. Does that mean evidence needs to be collected for all of them? !
It really doesn’t matter whether you agree or not; the safety supervision agency only accepts opinions from qualified third parties, and such qualified third parties will certainly not give contrary opinions to the ambiguous provisions of the regulations. So it’s better to just do as required.
Why distinguish between typical and atypical cases? Typical cases are just common examples. If I say Jack Ma and Pony Ma are typical successful people, does that mean others aren’t successful people? So as long as it meets the definition, it counts. But there is definitely a problem with this standard set by the authorities; the definition applied is too broad, and many reactions, although they are oxidation reactions, are actually not dangerous at all. Now, safety and environmental measures have gone too far.
What kind of evidence is worth collecting? Regarding processes subject to enhanced supervision, it is not the typical nature of the process that matters, but rather the description of its hazards; as long as you can prove that your process does not possess the hazards described, it need not be classified as a hazardous chemical process requiring enhanced supervision
What kind of certificate are you applying for? Is it the special operation certificate for hazardous chemicals issued by the Work Safety Supervision Bureau?