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China Issues Two Guidelines on Security Risk Management

Two guidelines on security risk management of chemical parks and hazardous chemical enterprises were officially released by China’s MEM on August 16th, 2019. The responsibilities of hazardous chemical enterprises and chemical parks have been specified in these two guidelines. Recently, Jiangsu provincial government also issued the relevant consultation and warning list on risk assessment and management for chemical enterprises and parks.

On July 24th, 2019, the Ministry of Emergency Management (MEM) issued a public consultation on two guidelines on security risk management of chemical parks and hazardous chemical enterprises (CL News [1]). And on August 16th, China’s MEM officially released two guidelines [2] namely, Guideline on Security Risk Investigation and Management of Chemical Parks (Trial) and Guideline on Security Risk Investigation and Management of Hazardous Chemical Enterprises.

According to MEM, chemical parks and hazardous chemical enterprises should improve their security risk management system, undertake key responsibilities related to security risk investigation and management, and establish a long-term mechanism for security risk investigation and management by studying and comparing the requirements stipulated by the two guidelines.

The Guideline on Security Risk Investigation and Management of Hazardous Chemical Enterprises specifies that hazardous chemical enterprises should take full advantage of the security risk analysis methods or the combination of multiple methods, such as Security Checking Label (SCL), Job Hazard Analysis (JHA), Failure Mode and Effects Analysis (FMEA) and Hazard and Operability Analysis (HAZOP), etc.

The Guideline on Security Risk Investigation and Management of Hazardous Chemical Enterprises also regulates the form and frequency of security risk investigation and management. The form of security risk investigation and management includes everyday investigation, comprehensive investigation, professional investigation, seasonal investigation, key period investigation and investigation before holidays, as well as parallel investigation of accidents and diagnostic investigation by foreign experts, etc. Hazardous chemical enterprises should organize at least one comprehensive investigation and professional investigation semiannually. The site inspection interval for equipment operating personnel should be less than 2 hours, and the site inspection interval for equipment operating personnel concerning with the production and storage device of “Two Key Points and One Major Issue” (refer to the hazardous chemical technology and hazardous chemicals for key inspection, and major hazardous resources inspection by competent authorities) should be less than one hour.

Hazardous chemical enterprises can conduct individualized security risk investigation using the security risk checklist attached to The Guideline on Security Risk Investigation and Management of Hazardous Chemical Enterprises. There are 9 hidden risk checklists and more than 350 checking items and relevant regulatory references included in the security risk checklist and the details of the checklist can be assessed here:

  • Security hidden risk checklist for security foundation management

  • Security hidden risk checklist for design and general view

  • Security hidden risk checklist for pilot production management

  • Security hidden risk checklist for equipment operation

  • Security hidden risk checklist for equipment safety

  • Security hidden risk checklist for instrument

  • Security hidden risk checklist for electricity

  • Security hidden risk checklist for fire and emergency

  • Security hidden risk checklist for special management of key hazardous chemicals

In addition to the guidelines issued by the MEM at national level, the provincial government of Jiangsu also issued a consultation on risk assessment guide for industrial parks (see CL News [3]) and a safety risk warning list for chemical enterprises (see CL News [4]) in order to guide chemical enterprises and parks in Jiangsu Province to conduct risk assessment and management, implement safe production, and prevent and resolve safety risks effectively.

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