摘要：Recently, Shanghai Emergency Management Bureau and Shanghai Fire and Rescue Bureau formed four task forces and raided locations th

Joint raids to eliminate hazards in rented factories, Warehouses

Recently, Shanghai Emergency Management Bureau and Shanghai Fire and Rescue Bureau formed four task forces and raided locations that were identified in previous undercover inspections for suspectedly undertaking illegal contracting and outsourcing operations or illegally storing hazardous chemical materials. The unannounced raids were aimed at eliminating work safety and fire hazards. By the end of August, these enforcement operations have uncovered 23 hazards in 22 companies at eight locations. Among them, four were major safety hazards and 19 were general safety hazards. Thirty-five investigation cases have been initiated, involving 22 companies and 13 individuals.

Case 1

Hazardous Chemical Materials in ‘Temporary Warehouse’

The No.1 Task Force arrived at a small industrial park in Fengcheng Town, Fengxian District. The three factory plants had been leased to more than 10 companies operating under various formats. Inside one of the buildings, officers noticed a a “temporary warehouse” partitioned with color steel sheets that immediately drew their attention.

The landlord said，“This warehouse is always locked up. The tenant said it is used to store ordinary goods. There shouldn't be any problem.”

Upon detecting a strong smell of diluent, the officers demanded that the landlord open the door without delay.

However, the landlord hesitated, claiming he did not possess the key. The officers demanded that the “warehouse” be opened immediately, citing suspicions of illegal storage of flammable and explosive hazardous chemicals. They further emphasized that, as the management company of the industrial park, the landlord was obligated to maintain spare keys for all leased warehouses. The officers reiterated the severe risks associated with unauthorized storage of hazardous substances and the critical need for immediate access.

Once the door was opened, officers were shocked to discover that the so-called “temporary warehouse” contained a large volume of chemicals stored in barrels. Several bore safety labels indicating Class 3 flammable liquids, while others had their labels deliberately removed. The space lacked even the most basic fire safety equipment and had no ventilation system in place. Electrical wiring had been haphazardly installed and connected, further compounding the risk of ignition and potential disaster.

The officers told the landlord that, under the high temperature of this summer, these so-called “ordinary goods” could leak or ignite, posing a serious fire hazard. They immediately ordered the evacuation of nearby personnel and instructed that the area be cordoned off. A subsequent third-party analysis confirmed that all materials stored in the “warehouse” were listed in the Catalog of Hazardous Chemicals (2015 Edition).

Legal Provisions

The Regulations on the Safety Management of Hazardous Chemicals, Article 24, Paragraph 1: Hazardous chemicals shall be stored in dedicated warehouses, dedicated sites, or dedicated storage rooms, and shall be managed by designated personnel...

The Regulations on the Safety Management of Hazardous Chemicals, Article 80, Paragraph 1: Those entities who produce, store, or use hazardous chemicals, under any of the following circumstances, shall be ordered to make corrections by the work safety supervision and administration department, and be fined between 50,000 yuan and 100,000 yuan; if they refuse to make corrections, they shall be ordered to suspend production or operations for rectification, and may face further action up to and including the revocation of their relevant licenses by the original issuing authority, with the industry and commerce administration ordering them to amend their business scope registration or revoke their business license; if the responsible personnel involved constitute a crime, they shall be held criminally liable in accordance with the law: … (4) Failing to store dangerous chemicals in dedicated warehouses…

Case 2

Hidden Danger of Unsafe Wiring

The No.2 Task Force arrived at a factory in Tinglin Town, Jinshan District, which has been leased to several machining companies through several rounds of sub-lease contracts. In the first workshop inspected, the officers noticed a machine was directly connected to a wall-mounted panelboard via a black electrical cable which stretched across the floor for dozens of meters. Numerous machined products coated in butter and other flammable substances were scattered throughout the workshop. Critically, no safety supervisor was present on site.

When officers requested to speak with the electrical safety supervisor, the workers responded that the wiring was only temporary and admitted that no certified electrician was present on site because the electrician “is taking the day off”. They insisted the setup had been used many times without incident.

The officers firmly stated that if temporary electrical wiring was in use, a qualified safety supervisor must always be present on site. They also criticized the hazardous practice of connecting machinery directly to panelboards without proper safeguards and immediately ordered the workers to cease operations. All machines must be connected to the power source through a cascaded power distribution system, which can ensure that faults in one machine do not affect the entire production system or cause fire. Dedicated motor control and protection units must also be installed. Additionally, electric cables must be wired neatly and correctly to prevent short circuits, overloads, and electric shock.

“The direct connection to the panelboard, the absence of a safety supervisor, the haphazard wiring, and the chaotic environment – these are all serious hazards that can lead to short circuits, electrical overloads or fatal shock accidents. You're playing with your life!” an officer said. “Whoever connected these cables must be held accountable for this reckless and unsafe wiring!”

The officers uncovered similar safety hazards in the second workshop that they inspected. A workshop leader explained that the site had been rented temporarily and that they were rushing to fulfill orders under tight deadlines. Their machine was positioned far from the fixed power outlets, so they resorted to using extended electrical cables.

The officers firmly emphasized that “expediting orders” is no justification for violating safety protocols. “Carrying out hazardous operations without proper supervision or safety management is a blatant disregard for your workers’ lives!” an officer said sternly.

The Work Safety Law of the People’s Republic of China, Article 43：Production and business operation entities that conduct blasting, hoisting, hot work, temporary electricity use, or other hazardous operations specified by the emergency management department under the State Council in conjunction with other relevant departments under the State Council shall arrange dedicated personnel to conduct on-site safety management to ensure compliance with operational procedures and the implementation of safety measures.

The Work Safety Law of the People’s Republic of China, Article 101: Production and business operation entities that engage in any of the following acts shall be ordered to make corrections within a specified time limit and be fined up to 100,000 yuan; if they fail to make corrections within the specified time limit, they shall be ordered to suspend production or operations for rectification and be fined between 100,000 yuan and 200,000 yuan, with the directly responsible supervisors and other directly responsible personnel fined between 20,000 yuan and 50,000 yuan; if such acts constitute a crime, they shall be held criminally liable in accordance with the relevant provisions of the Criminal Law: … (3) Failing to arrange dedicated personnel to conduct on-site safety management for blasting, hoisting, hot work, temporary electricity use, or other hazardous operations specified by the emergency management department under the State Council in conjunction with other relevant departments under the State Council...

Case 3

Intentionally Forged Chemical Safety Documentations

The No.3 Task Force came to a seemingly “abandoned” industrial park located in a remote part of Huating Town, Jiading District. The park consisted of three large warehouses and a two-story office building. Its perimeter fences were heavily rusted, with many sections broken. After entering the premises by climbing through the broken fencing, the officers observed that the door to Warehouse was partially open, and several intermediate bulk containers had been stacked inside. There was a strong and pungent odor in the air.

The officers requested the warehouse leader, who claimed the goods were ordinary materials and had been properly registered, to provide the chemical safety documentation. Upon reviewing the files that the leader handed in, the officers noticed that the fonts used for the text “Flash point: 111 °C” are different from surrounding characters. Key information regarding the chemical’s safe handling and storage was missing, and the Material Safety Data Sheet consisted of only three pages. When questioned, the leader was unable to provide an explanation and instead slipped away to make phone calls.

Subsequently, the task force engaged a third-party laboratory to test the materials, which revealed that the actual closed-cup flash point was -11 °C.

During the subsequent investigation, officers discovered that the company had leased the warehouse for chemical packaging operations. In accordance with legal requirements, entities engaged in such a business must obtain a Permit for Trading in Hazardous Chemicals. However, in an apparent attempt to evade supervision oversight, the company deliberately falsified safety documentations to misrepresent the materials as ordinary chemicals.

“You failed to install even the most basic safety equipment. When decanting Class 1 flammable liquids, volatile vapors can accumulate and ignite from a single electrostatic spark - triggering a flash fire in seconds!” the officers reprimanded sharply during the investigation. “This isn’t just negligence; you are gambling your lives!”

The Regulations on the Safety Management of Hazardous Chemicals, Article 33, Paragraph 1: The State implements a licensing system for businesses involving hazardous chemicals. Without a permit, those who trade hazardous chemicals, including any entities or individuals, are prohibited from engaging in such businesses.

The Regulations on the Safety Management of Hazardous Chemicals, Article 77, Paragraph 3: Those who violate these Regulations by engaging in the business involving hazardous chemicals without obtaining a hazardous chemicals operating permit shall be ordered by the department of work safety supervision and administration to cease operating activities, with the hazardous chemicals involved in the illegal operation and illegal gains confiscated, and be fined between 100,000 yuan and 200,000 yuan; if such acts constitute a crime, the same shall be held criminally liable in accordance with the law.

Shanghai Work Safety Regulations, Article 56: Production and business operation entities, the relevant responsible persons thereof, or other personnel shall not: … (4) Forge or intentionally use fake process documents, hazardous chemical material safety technical data sheets, safety management ledgers, or other materials that significantly affect work safety…

Shanghai Work Safety Regulations, Article 88: Production and business operation entities, the relevant responsible persons thereof, or other personnel who violate Items 1 through 5 of Article 56 of these Regulations by engaging in prohibited acts shall be ordered to make corrections by the department of work safety supervision and administration. The entity shall be fined between 10,000 yuan and 50,000 yuan, and their relevant responsible supervisors and other directly responsible personnel shall be fined between 1,000 yuan and 10,000 yuan.

Case 4

Blocked Escape Routes to Safety

The No.4 Task Force arrived at a hybrid industrial park in Xinqiao Town, Songjiang District, comprising of a main factory building, a multi-story dormitory and various supporting facilities. Upon inspection, officers discovered that the first floor of the dormitory had been repurposed into a warehouse, where large quantities of goods were being stored. Alarmingly, most of the safety exits on the floor had been locked or blocked, posing serious risks to personnel and emergency response.

The officers entered the building through the only door that remained open and discovered a substantial quantity of board, plates and bubble wraps stored inside. All other designated safety exits had been completely obstructed.

They also heard the sharp sound of metal-cutting coming from behind a closed roller shutter door and ordered it to be opened from the inside.

Once the door was raised, they found a small warehouse where two workers were operating a cutting machine amid lots of aluminum scraps scattered across the floor.

The warehouse manager who heard of the inspection quickly arrived at the scene and asserted that normally no one was living in the dormitories above, insisting that there was no safety concern.

“Given that dormitories are located on the upper floors and you are conducting hot work operations, blocking the exits on the first floor is absolutely unacceptable. If a fire breaks out, the consequences could be catastrophic,” the officers warned the manager sternly.

“Please clear the goods from the first floor immediately and ensure all exits remain unobstructed at all times,” the officers demanded, instructing the tenant of the first floor to take corrective actions without delay.

The Work Safety Law of the People’s Republic of China, Article 42, Paragraph 2: Production and business premises and employee dormitories shall have exits and evacuation passages that meet emergency evacuation requirements, are clearly marked, and remain unobstructed. It is prohibited to occupy, lock, or block such exits or evacuation passages.

The Work Safety Law of the People’s Republic of China, Article 105: Production and business operation entities that engage in any of the following acts shall be ordered to make corrections within a specified time limit and be fined up to 50,000 yuan, with the directly responsible supervisors and other directly responsible personnel fined up to 10,000 yuan; those who fail to make corrections within the specified time limit shall be ordered to suspend production or operations for rectification; if such acts constitute a crime, the same shall be held criminally liable in accordance with the Criminal Law: … (2) Failing to provide exits and evacuation passages that meet emergency evacuation requirements, are clearly marked, and remain unobstructed in production and business premises or employee dormitories, or occupying, locking, or blocking such exits or evacuation passages...

Friendly Reminder

In the above cases, the landlords failed to effectively fulfill their centrally coordinating and management duties of work safety, which was the root cause of numerous safety hazards existing among tenants.

The Work Safety Law of the People’s Republic of China, Article 49, Paragraph 2 explicitly provides that when production and business projects or premises are contracted or leased to other entities, the business and operation entity issuing the contract or the lessor shall sign specific work safety management agreements with the contractors or lessees, or stipulate the respective work safety management responsibilities thereof in the contract or lease agreement; the party issuing the contract or the lessor shall coordinate in an integrated manner and manage the work safety of the contractors or lessees, conduct regular safety inspections, and promptly urge rectification upon discovering safety issues.

Meanwhile, Article 103, Paragraph 2 stipulates the penalty provisions: those that fail to sign specific work safety management agreements with contractors or lessees, or fail to stipulate the respective work safety management responsibilities in the contract or lease agreement as required, or fail to centrally coordinate and manage the work safety of contractors or lessees, shall be ordered to make corrections within a specified time limit, be fined up to 50,000 yuan, and their directly responsible supervisors and other directly responsible personnel be fined up to 10,000 yuan; if they fail to make corrections within the specified time limit, their production or operations shall be suspended for rectification.

▌来源：协作发展处

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来源：上海应急守护