The most in-depth and practical analysis to date of the Xiangshui “March 21” explosion accident (Part 2)

At present, government agencies are deeply concerned about safety management—so much so that they would even like to take over all aspects of safety on behalf of enterprises. While their intentions and motivations are commendable, it is still essential to grant businesses greater autonomy in this area. So, what should the government do? Although I am hardly qualified to weigh in on this issue, I would venture to suggest that, in matters of safety management, the government’s primary responsibilities should be to establish regulatory frameworks and standards, implement evidence‑based oversight, provide guidance to enterprises, and steer social resources toward supporting safety‑related services.

The current situation is pressing, and the government’s top priority is to address several key areas—these observations are offered for reference only: first, to refine safety‑related laws and standards; second, to explore and implement evidence‑based regulatory approaches; third, to foster the development of a skilled workforce; and fourth, to make effective use of and properly regulate societal resources while resolutely eliminating formalism.

    1. Improve safety-related regulations and standards

Our country has numerous laws and regulations related to safety, but many of them remain ambiguous. It is essential for businesses and practitioners to clearly understand the regulatory requirements; at the national level, the government should systematically review existing safety‑related statutes, refining and standardizing them to facilitate more effective legislative planning.

At present, when regulations and standards are applied at the grassroots level, there are many ambiguities, and experts often debate in WeChat groups about how to ensure compliance—making it even more difficult for those within enterprises to strike the right balance. Why does this happen? Because some provisions in the codes and standards lack sufficient specificity. Given our current stage of development, clear and detailed rules are sometimes essential. The state could refine these codes and standards by making them more comprehensive and by issuing supplementary interpretive guidelines, which would greatly facilitate their implementation at the local level.

Many of our standards consist of just a few pages, whereas the standards issued in Europe and the United States often resemble entire textbooks. We do not necessarily need to turn our standards into textbook‑like documents, but they should be as detailed as possible to facilitate effective implementation and enforcement. There is still considerable room for improvement in both the content and quality of our safety‑related regulations and standards. The government can leverage societal resources to refine these laws and standards. Notably, in addition to experts within the institutional framework, many specialists also work at multinational chemical companies operating in China. They are well‑versed in international best practices and possess extensive hands‑on experience; they represent valuable national talent, and engaging them would help elevate the quality of safety‑standard development.

Regulations and standards serve, on the one hand, as a reference for enterprises and, on the other, as the basis for regulatory oversight. Their continuous refinement is a long-term, ongoing process that underpins the development of the entire industry and constitutes an indispensable step along the way.

In addition to regulations and standards, the state can also convene experts to develop implementation guidelines that closely align with these requirements. Today, many enterprises are gradually recognizing the importance of safety but remain unsure how to take concrete steps—particularly small and medium-sized businesses, which often lack sufficient expertise in safety engineering. In some SMEs in the chemical industry, a significant number of mid-level managers responsible for production and safety operations lack adequate experience and technical knowledge in safety management. For example, they may struggle to distinguish between different types of electrostatic discharge and their corresponding control measures, have limited understanding of the mechanisms behind dust explosions and the associated preventive strategies, and many are unfamiliar with concepts such as permit‑to‑work procedures. Relevant guidance would provide substantial assistance to these professionals.

    2. Explore and implement scientific regulation

How can effective regulation be achieved? This requires further study and deliberation by the government. However, we must recognize that ad hoc, superficial safety inspections should not be the dominant approach to oversight.

We might explore and study the compliance‑regulation experiences of Europe and the United States. The indirect regulatory model involving “government–insurance companies–enterprises” is also worthy of further investigation.

Regulation is an exceedingly complex issue, and given the lack of experience in this area, I will refrain from elaborating further.

    3. Promote the cultivation of professional talent

A shortage of specialized professionals is one of the key factors hindering progress in safety management within the chemical industry, and it is a critical gap that is difficult to address in the short term. Both government regulatory agencies and enterprises alike face a lack of qualified personnel in safety management and safety‑related technical fields—while some competent experts do exist, their numbers remain far too limited. At present, the government is seeking to engage external experts to support safety oversight and regulation; however, if such expertise is likewise scarce in the broader workforce, we must invest heavily in talent development, with national policies in place to provide clear guidance.

How can we rapidly develop a cohort of competent professionals in safety management and technical fields?

In the long term, at the national level, it is necessary to establish a talent-development program in this area, beginning with university education; I will address the issue of higher education in Part 2.

In the short term, to address pressing needs, national or provincial authorities could organize expert training programs, providing grassroots professionals with structured learning opportunities to help them enhance their expertise. The state could fund the development of a series of training courses and recruit seasoned, high‑caliber experts from the broader community to serve as instructors. If each province were to support 100 experts in upgrading their skills annually, the resulting boost to the industry would be substantial.

Participants in expert training programs may come from government regulatory agencies, professional service firms, or enterprises. Such training should be systematic and not merely a perfunctory 2–3‑day session aimed at obtaining a certificate; accumulating around 20 days of instruction is more likely to yield meaningful results.

Instructors must be grounded in practical realities and possess hands-on management experience. When recruiting instructors, we should not limit ourselves to talent within the public sector. After decades of opening up, some large state-owned enterprises have performed admirably, and many multinational corporations operating joint ventures or wholly owned subsidiaries in China have also cultivated a wealth of seasoned safety‑management professionals—assets that are highly valuable. Yet these talents remain underutilized; they tend to stay within their own circles, failing to integrate into the broader industry. As a result, China’s safety‑management landscape is characterized by two markedly different approaches: one adopted by state‑affiliated enterprises, and the other by multinational firms.

The state can, through policy guidance, enable these “outsiders” from multinational corporations to play a more significant role; they can act as catalysts, providing leadership and driving progress. A promising trend is that some private enterprises are now hiring professionals with experience in safety management at multinational firms to oversee their own safety operations.

    4. Make effective and standardized use of social resources, and resolutely eliminate formalism.

Formalism is extremely harmful, and when it infiltrates the safety management process, it can even cost lives.

For example, if the government’s safety standardization system is implemented with each component properly executed and put into practice, the overall level of safety management will undoubtedly improve. However, in reality, it is all too common for companies to focus on preparing paperwork while experts conduct superficial reviews of those documents, leaving the actual management on the shop floor far removed from the written procedures. No matter how meticulously the documentation is crafted, if there is no corresponding change on the ground, it does nothing to prevent accidents—and incidents will continue to occur. This situation runs counter to the original intent of safety standardization.

For another example, the government mandates that hazardous process units undergo a Hazard and Operability Study (HAZOP analysis). HAZOP analysis is an extremely important tool, critical to achieving process safety in the chemical industry. Western chemical companies have demonstrated this through decades of experience and application; yet many Chinese enterprises still fail to grasp its significance. Some service providers are either unprofessional or irresponsible: what should take two to three weeks is completed in just two or three days. Even worse, certain firms—hopefully a minority—conduct HAZOP studies without holding any meaningful meetings with the plant’s technical staff, instead simply taking the available documentation back to their offices and producing a perfunctory report. As a result, the company satisfies the regulatory requirements, the service provider pockets the fee, and everyone involved appears to be “winning.” This superficial approach is tantamount to leaving a time bomb inside the process system; under such circumstances, an accident is only a matter of time. It is truly regrettable for these companies, which have missed a valuable opportunity to prevent accidents at minimal cost. Meanwhile, the few unscrupulous firms, though they may profit, effectively become accomplices to future incidents.

I’m sure many people are well aware of, or can relate to, the situations I’ve just described. At first, I didn’t even feel like dwelling on them, but the Yingshui accident—where dozens of precious lives were lost—has struck a chord deep within each of us, awakening our collective sense of conscience. We must confront these issues head-on if we are to find solutions.

Safety management is a science; formalism is self-deception, and failing to act in accordance with scientific principles will inevitably lead to accidents—only a matter of time. It is hoped that the government will resolve to eliminate formalism once and for all.

At present, the government is gradually delegating certain functions to civil society—such as industry associations, research institutions, and consulting firms. Leveraging societal resources has become a growing trend; however, high-quality resources remain relatively scarce, and many non‑governmental professional and technical advisory organizations continue to operate on the margins. The government can play a pivotal role in channeling these societal resources into the field of chemical safety.

In the United States, the Center for Chemical Process Safety (CCPS) under the American Institute of Chemical Engineers, the National Fire Protection Association (NFPA), the American Petroleum Institute (API), and the myriad specialized consulting firms all play a crucial role in chemical safety. While U.S. chemical plants do experience accidents, overall they perform better than ours.

At present, many domestic associations related to chemical safety are quite active; some are doing their utmost to provide enterprises with high-quality services and support—for example, the EHS Management Association of the Pharmaceutical Industry Association and the Zhejiang Provincial Chemical Safety Association. Nevertheless, there remains considerable room for these associations to play a more robust role, and there are also instances of opportunistic actors seeking to exploit the system. The government can support industry associations in assuming a leading role, enabling them to serve as an important pillar of support. At the same time, it is essential to strengthen guidance and regulation to prevent the emergence of practices that use association status for personal gain.

The government possesses its own top-down design and administrative expertise. This piece is merely a personal reflection—intended to spark further discussion…

This is the second installment, focusing on third-party organizations.

Around the operations of chemical enterprises, the government, businesses, and third-party organizations are interconnected, forming a tightly integrated ecosystem. The government establishes the underlying logic of this system—defining its basic structure through regulations, standards, and oversight mechanisms—while enterprises serve as the primary actors, and third-party entities provide support. Among the many types of third-party organizations, this paper focuses on industry associations, engineering firms (design institutes), safety‑assessment agencies, and universities that offer chemistry‑related academic programs.

These third-party organizations typically maintain only weak ties with enterprises; however, once a business relationship is established, that bond becomes strong. Consequently, they can play a critical role in helping chemical companies prevent catastrophic accidents* [Note]. Here, I would like to examine, at the micro level, the specific actions these third-party entities can take to assist chemical firms in achieving safer operations.

Note: To date, there is no universally accepted definition of a catastrophic accident. In these three articles, any accident resulting in one or more fatalities is classified as a catastrophic accident. When a single person dies in an accident, it may mean that a child has lost a father or a mother, or that an elderly parent has lost a son or a daughter—experiences that, for those affected, constitute a true catastrophe.

Today, industry associations have transitioned from their former government‑related functions to a role as social service providers. Their new mission should be to serve enterprises—namely, their members. Industry associations, particularly at the national and provincial levels, can undertake numerous constructive initiatives to help chemical companies enhance their safety management practices, such as:

1. Enhance communication between enterprises and the government. The association can collect and synthesize ideas and suggestions from businesses at the grassroots level regarding production safety, promptly relay them to the relevant government departments, and provide valuable input for the formulation of laws and standards. On the other hand, associations typically conduct industry‑specific research, giving them a deeper understanding of the latest trends and development directions than individual enterprises. This enables them to guide companies in taking appropriate measures in a timely manner—for example, proactively incorporating into new projects the safety requirements that future regulations or standards are likely to mandate.

2. Conduct statistical analysis and research on the characteristics of industrial safety accidents, produce corresponding research reports, and share them with enterprises. National-level associations, in particular, should undertake such efforts. Enterprises can use these reports to enhance their safety management, while the reports can also be submitted to relevant government agencies as a reference for policy-making.

3. Organize experts to develop guidelines related to safety management and safety technology for reference by enterprises. Many small and medium-sized chemical companies in China have limited engineering and technical capabilities and urgently need practical guidance to help them implement appropriate safety measures. Of course, such guidelines must be closely aligned with the actual needs of enterprises and easy to consult and apply; they should avoid being disconnected from real-world conditions. This work is highly challenging but well worth undertaking, and national-level associations may even consider it a strategic priority. A preliminary planning phase could be established, followed by the formation of expert working groups to draft the guidelines—drawing on expertise from both industry and academia to create several task forces, each responsible for developing one or two specific topics.

4. Organize high‑level security forums or seminars. In the past, when the Ministry of Chemical Industry existed, enterprises had a unified platform for exchange; today, a similar platform remains essential, and industry associations are best positioned to establish it. Annual forums and specialized symposia could be held, with topics solicited from both the public and businesses. Based on the current situation, in‑depth thematic workshops appear to offer greater practical benefits to enterprises.

5. Arrange high-quality professional training. Typically, such training is delivered by specialized consulting firms; however, at this stage, relevant resources are relatively scarce in the market. Industry associations can leverage their own resource advantages to organize specialized safety management and safety‑technology training sessions, inviting distinguished experts from both the broader community and within enterprises to deliver lectures. This helps enterprise managers and technical personnel enhance their safety awareness and improve their management capabilities, which is highly valuable—though training aimed solely at profit or certification purposes is a different matter.

Many industry associations have limited staff and are even less able to hire large numbers of full-time experts, making it quite challenging to carry out these tasks effectively. Therefore, it is essential to make good use of expert resources both within enterprises and in the broader community.

There are also some fake associations in society that engage in ranking, award‑giving, certification, and profiting from the public’s lack of awareness; these fall outside the scope of this discussion. Legitimate industry associations should focus their efforts on providing the valuable services mentioned above and should avoid becoming overly preoccupied with ranking, award‑making, or issuing certificates. In principle, industry associations are non‑profit organizations; if they pursue profit as their primary goal, it becomes all too easy for them to stray from their original mission of serving businesses. (To be continued)