Earlier this month, China State Administration of Work Safety (SAWS) issued a feature article to interpret the Interim Provisions for the Supervision and Administration of Major Hazard Installations of Dangerous Chemicals (“Interim Provisions” in short) which has recently been published on August 5, as SAWS Order No. 40. The Interim Provisions will come into effect from December 1, 2011.
Main Body of the Interim Provisions
The Interim Provisions consist of six chapters (namely, I. the General Rules; II. Identification and Evaluation; III. Safety Management; IV. Supervision and Inspection; V. Legal Liabilities; VI. Supplementary Provisions) and 2 Annexes. The provisions cover important requirements on the major hazard installations identification, classification, assessment, registration and revocation, registration and documentation, monitoring and inspection. Most significantly, it is formulated on the basis of China’s practical exercise of the administration of major hazard installations. Many measures have been through a case-by-case study and summarization.
(1) Exemptions of the Interim Provisions
The provisions are exclusive of urban liquefied gas, hazard installations used for national defense and scientific research purposes, or hazard installations within Port areas. Civil explosives and fireworks shall apply to the national specialized legislature provided that no violation against this Interim Provision should occur. Therefore, all legal entities engaged in the production, storage, usage or operation of dangerous chemicals will be obliged to act in line with the Interim Provisions in terms of their major hazard installations management.
(2) Identification of Major Hazard Installations for Dangerous Chemicals
—What is a major hazard installation unit?
—It refers to the unit in which the quantity of dangerous chemicals surpasses certain limitation specified by the China national standard GB 18218-2009 (on identification of major hazard installations for dangerous chemicals). If a plant engaged in dangerous chemicals business is equipped with more than one (set of) production device(s) or workplace(s) and where the distance between either two facilities is less than 500 m, the plant should be identified as one single major hazard installation unit.
—Identification scope expanded in the new GB
National standard GB 18218-2009 has been modified on the basis of the old GB 18218-2000. Compared with the 4 categories of dangerous chemicals, the new version lists explicitly 78 dangerous chemicals in Sheet 1 and specifies 9 categories of dangerous chemicals in Sheet 2, including explosives, gas, flammable liquids, flammable solid, substance liable to spontaneous combustions, oxidizing substance, organic peroxides and toxics.
(3) Monitoring and Control of Major Hazard Installations for Dangerous Chemicals
The Interim Provisions emphasize that dangerous chemical companies should take in consideration of the category, volume (tonnage), production condition, applied technology or other facility-related background when establish the corporate monitoring & control system. For instance, major hazard installations should be equipped with a non-stop data-gathering and monitoring system covering items of temperature, pressure, liquid level, constituents as well as alarm devices for combustible gas or toxic /hazardous gas leakage. The monitoring & control system should also possess functions like information remote transmission, continuous record, accident warning and data storage. Major hazard installations at level 1 or 2 should even add a function of emergency cut-off. Digital data should be stored in no less than 30 days.
Major hazard installations at level 1 or 2 regarding toxic gas, liquefied gas or highly-toxic liquid should be equipped with an independent SIS (Safe Instrumented System) in compliance with the national standards for petrochemical industry or other SIS fields.
(4) Classification Management of Major Hazard Installations for Dangerous chemicals
The Interim Provisions divide severity of major hazard installations into 4 levels, with level 1 the highest in severity. Classification management involves the calculation of several parameters/indicators:
Indicator R = Actual volume of various dangerous chemicals in a unit / threshold limit specified in GB 18218-2009 + correction coefficient (α and/or β)
Parameter α: Exposure to people outside of the major hazard installation unit
Parameter β: Differentiation on the danger severity of dangerous chemicals
(5) Permissible Risk Standard and Safety Assessment of Major Hazard Installations for Dangerous Chemicals
—introduction of the concept of Permissible Risk Standard by drawing on the successful experience from UK, the Netherlands and Hong Kong
The Permissible Risk Standard is characterized in the Curve of Death Probability, per unit time (usually per year), at a fixed location in a potential accident (fire, explosion, toxic gas leak, etc.) caused by dangerous chemicals within a given major hazard installation unit.
—introduction of the methodology of qualitative risk assessment
Will be discussed later in the section of chemical risk assessment.
—proposal that the safety evaluation on major hazard installations could be organized by an enterprise itself or its appointed agency/institute with competent qualifications.
(6) Record/Registration and Revocation of Major Hazard Installations for Dangerous Chemicals
The Interim Provisions state that dangerous chemical enterprises should report to the local department of work safety at the county level for recording in advance of any plan to construct, reconstruct or expand a project on dangerous chemicals.
