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China’s Risk Criteria
Posted on October 26th, 2017 by Mike Schmidt in Chemical Manufacturing Excellence
“Who can hope to be safe? Who sufficiently cautious?” Horace
When I first began working in China, I was astonished to be told how different the attitude about risk in China was from that in the West. For instance, I was told that an incident of workplace fatalities did not need to be reported to the government unless there were at least 10 killed. I remember a heated discussion—all in Chinese—following my description of the U.K. risk criteria and the levels associated with their As Low As Reasonably Practicable (ALARP) principal. When I asked what had just been said, someone simply explained that they had been told that their suggested design guidance was the same as in the West. From me, they had just learned that the Chinese risk tolerance criteria were really two orders of magnitude worse.
A Short List of Countries with Risk Tolerance Criteria
When I first began helping companies in the chemical process industries to establish their own risk tolerance criteria, there were only a handful of countries that mandated risk criteria for their industries. Notable among them were the U.K. with its ALARP principal and the Netherlands, which established criteria two orders of magnitude lower but with a different approach to enforcement. The United States was not among the countries that were willing to tell companies how low their risk tolerance criteria must be, and just as importantly, how low was low enough.
When the Center for Chemical Process Safety published its Guidelines for Developing Quantitative Safety Risk Criteria in 2009, it was only able to describe criteria for jurisdictions in eleven countries. Some were national criteria. Some—notably, Australia and Brazil—had criteria established by certain states, but not national criteria. In the United States, only Santa Barbara County in California was listed as having mandated enforceable risk tolerance criteria.
China has Joined the Short List
I just returned to the U.S. from working on another project in China. While I was there, I had a chance to sit down with a safety professional at a Chinese chemical company to go over the draft criteria that the Chinese government is about to issue. The document, Acceptable Risk Criteria for Hazardous Chemical Production and Storage Installations, ICS 13 100 C65, will replace the interim criteria that were published in 2014. It is an 8-page document that addresses both individual and societal risk, making no distinction between the public and employees.
The Chinese Risk Tolerance Criteria
The Chinese risk tolerance criteria that are about to be issued have two interesting features. First, there is a distinction between existing facilities and new facilities. New facilities will have to meet a stricter criteria than the criteria mandated for existing facilities. Second, the criteria mandated for facilities depends on character of the neighboring area.
Neighboring areas are divided into one of three classes. Class 1 is an area that can generally be thought of as having a high population density. Class 2 is an area with a medium population density and Class 3 is an area with a low population density. The higher the population density, the lower the criteria for acceptable risk. This means that while the document refers to risk, there is a large component of consequence avoidance in the criteria.
The document gives several measures to use when determining population density Class. For instance, there is the number of residential neighbors:
- Class 1 – More than 30 households or more than 100 neighboring residents
- Class 2 – Between 10 and 30 households or between 30 and 100 neighboring residents
- Class 3 – Fewer than 10 households and fewer than 30 neighboring residents
The measures also address shopping, workers, entertainment venues, and other population categories.
Given these three classifications of population density, risk criteria are mandated in terms of fatalities per year:
Aspirational or Serious Mandates?
It remains to be seen whether China’s risk criteria are aspirational or serious mandates. It also remains to be seen whether these risk criteria will be enforced on all chemical facilities in China, or just those built and operated by western companies. Regardless, the chemical facilities in China with which I work are taking them seriously. In some cases, their corporate criteria are more conservative; in those cases, they are obliged to follow their own internal risk criteria. Unfortunately, we may still see terrible disasters like Tianjin warehouse explosion in 2015 as these requirements take root.
The Need for Risk Tolerance Criteria
Whether or not you are in a country that has mandated risk tolerance criteria, you need them. Risk tolerance criteria are the basis for determining whether your process risks are too high and require additional risk reduction measures, or that the existing risk reduction measures are sufficient to adequately protect your workers, your community, and your environment. While risk can never be zero, it can be low enough. In the absence of external risk criteria, like those developed by the Chinese government, you are left to develop them on your own, a position that leaves many companies feeling vulnerable. Considering the string of chemical disasters that have rocked China, the Chinese government is to be congratulated for taking this head on.
All opinions shared in this post are the author’s own.
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Principal, Bluefield Process Safety, LLC
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