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On March 22, 2024, Vietnam's Ministry of Industry and Trade released a draft amendment to National Technical Regulations on Safety in Production, Trading, Use, Storage and Transportation of Dangerous Chemicals (QCVN 05A: 2020/BCT) for public consultation.
The regulation, promulgated under the Circular No.48/2020/TT-BCT on December 21, 2020, has been enforced for over 3 years, leading to overall improvements in chemical management practices in Vietnam. However, certain provisions have proved inappropriate when applied in practice. To address these concerns, the department conducted a public survey in August 2023 to gather feedback in preparation for a forthcoming amendment (click here to see more).
Compared with the existing QCVN 05A: 2020/BCT, the proposed amendments focus on key requirements for factories and warehouses storing hazardous chemicals, storage of flammable and explosive chemicals, corrosive and toxic chemicals, and outdoor chemical storage facilities.
Following is the comparison of draft amendment and QCVN 05A:2020/BCT:
| QCVN 05A:2020/BCT | Draft Amendment |
| I. General regulations | |
Add Point 3.6 as follows: "3.6 Collection system: Dikes, collection trenches and recovery tank pits, storage trays to prevent spilled chemicals from releasing into the environment" | |
| II. Technical regulations | |
| 1.5. QCVN 06: 2020/BXD - National Technical Regulation on Fire Safety of Buildings and Constructions. | 1.5. QCVN 06: 2022/BXD - National Technical Regulation on Fire Safety of Buildings and Constructions. |
| 5.1. The design, construction and renovation of factories and warehouses containing hazardous chemicals shall comply with QCVN 06: 2020/BXD, TCVN 4604: 2012, and other relevant law provisions, and shall be suitable for the nature, scale and technologies for manufacturing and storing chemicals. | Replace "QCVN 06: 2020/BXD" with "QCVN 06:2022/BXD" |
| 5.2. Escape routes of factories and warehouses must be designed and constructed in accordance with QCVN 06: 2020/BXD and current regulations. | Replace "QCVN 06: 2020/BXD" with "QCVN 06:2022/BXD" |
5.8. Factories and warehouses must have at least 2 entrances and exits. Entrances, exits, emergency exits and walkways shall not be obstructed. | 5.8. Factories and warehouses containing hazardous chemicals with a length or width greater than 3m must have at least two doors, including an entrance door and an emergency exit door. The emergency door must not be installed on the same side as the entrance door and should be easily opened from inside. For factories and warehouses with a length or width less than 3m, only one door is needed. |
5.9. Factories and warehouses must install emergency eyewash and shower equipment which shall be placed with 10 m (but not closer than 2 m) to hazardous chemical handling area. | 5.9. Factories and warehouses storing corrosive chemicals within a radius of a maximum of 17m, emergency eyewash and emergency shower equipment must be installed. Factories and warehouses storing other dangerous chemicals must be equipped with portable eyewash equipment or eyewash and emergency shower equipment. |
5.12. When arranging chemicals in the warehouse, the following safety requirements for workers and goods must be satisfied, specifically as follows: - With regard to bagged goods, they must be placed on pedestals or racks, at least 0.5 m from the wall, water reactive chemicals must be placed on pedestals at a height of at least 0.12 m; - Equipment containing chemicals shall not be placed too close to the warehouse’s ceiling and at a height of more than 2 m if stacks are not available; - The primary aisle of the warehouse must be at least 1.5 m wide; - A plan shall be formulated to inspect and supervise areas where there is a risk of an incident occurring in every factory and warehouse. | 5.12. When arranging chemicals in the warehouse, the following safety requirements for workers and goods must be satisfied, specifically as follows: - With regard to bagged goods, they must be placed on pedestals or racks, at least 0.5 m from the wall, water reactive chemicals must be placed on pedestals at a height of at least 0.12 m; - Equipment containing chemicals shall not be placed too close to the warehouse’s ceiling and at a height of more than 2 m if stacks are not available; - The primary aisle of the factories and warehouse must be at least 0.75 m wide, in the case of forklifts, at least 2m. |
8.1.3. Flammable and explosive chemicals must not be stored together with oxygen, oxygen-release substances, hazardous and incompatible chemicals, substances subject to different fire extinguishing requirements or substances capable of triggering hazardous reaction in the case of contact or fire. | 8.1.3. Flammable and explosive chemicals under storage conditions must not be stored together with oxygen, oxygen-release substances, hazardous and incompatible chemicals, substances subject to different fire extinguishing requirements or substances capable of triggering hazardous reaction in the case of contact or fire. |
8.4.9. In case of a fire or explosion incident, every person that is present must use personal protective equipment to participate in the rescue and fire-fighting. Persons who do not have appropriate personal protective equipment are not permitted to participate in fire-fighting. The person who calls the fire department and ambulance services must provide specific address and directly lead the way. | 8.4.9. In case of a fire or explosion incident, every person that is present must use personal protective equipment to participate in the rescue and fire-fighting. Persons who do not have appropriate personal protective equipment are not permitted to participate in fire-fighting. |
9.1.1. The facilities having corrosive chemicals must take measures for preventing the corrosion and protecting construction works. Factories and warehouses containing liquid corrosive chemicals must set up systems for draining, collecting and treating chemicals. | 9.1.1. Factories and warehouses storing corrosive chemicals in liquid form must have a chemical collection system. The collection system must have a minimum capacity equal to 110% of the largest storage vehicle. |
9.1.4. Every warehouse of corrosive chemicals must be made of materials that are not damaged by corrosive substances. The floor of the warehouse must be flat and surrounded by an edge protruding at least 0.1 m from the ground or a layer of sand that is 0.2 - 0.3 m thick. | 9.1.4. Warehouse of corrosive chemicals must be made of corrosion-resistant materials or anti-corrosion coating. |
10.1.3. The danger of machinery, equipment, and special stages of manufacture must be warned using the signs. | 10.1.3. Areas for production and storage of toxic chemicals in liquid and gas form must have appropriate leak and spill warning equipment. For toxic chemicals in solid form, surveillance cameras must be installed. |
10.1.7. Areas where toxic chemicals are stored must have a system of collection banks and trenches; the minimum storage capacity of the collection system must be 110% of the total volume of goods | 10.1.7. Areas containing toxic chemicals must have a collection system. The minimum capacity is equal to 110% of the larget container capacity. |
11.2. The storage capacity of the bunding system must be greater than or equal to 110% of the capacity of the storage tank or group of storage tanks in the dike system. | 11.2. The capacity of the disk system must have a minimum storage capacity of 10% of the capacity of the storage facilities or the capacity of the largest storage facility, whichever is greater. |
