Industrial Safety Declarations for Hazardous Production Facilities

An industrial safety declaration helps an enterprise answer three questions: how hazardous the facility is, which accidents could occur there, and whether existing measures are sufficient to prevent them and limit their consequences. Whether a declaration is required, and what it contains, depends on the characteristics of the particular facility — its process, equipment, hazardous substances and type of work — rather than on the industry it belongs to.

This article is written for managing directors, chief engineers and industrial safety specialists at enterprises in Almaty. It explains what information to collect, who takes part in preparation and what happens before registration. Development of an industrial safety declaration relies on the design documentation and actual production processes: if the document departs from the real process, its conclusions lose their meaning.

When an industrial safety declaration is required

Not every hazardous production facility (HPF) is subject to declaration. Under the laws of the Republic of Kazakhstan, identification comes first — establishing whether the facility is a hazardous production facility at all — followed by a check against the criteria for declarable facilities. Declaration is governed by Article 76 of the Law of the Republic of Kazakhstan “On Civil Protection”, and the criteria were approved by Order No. 240 of the Minister for Emergency Situations dated 26 May 2021. Declarations are developed for both operating and planned facilities; for a planned facility, the design solutions form the basis of the document.

How to check a facility against the declaration criteria

The review starts with the types of activity and the processes, then moves to hazardous substances and their maximum quantities on site, after which the data are compared with the criteria. The criteria contain not only threshold quantities of hazardous substances but also a list of activities, including mining, geological exploration, drilling and blasting, extraction of minerals and processing of mineral raw materials (excluding extraction of common minerals), and underground work. A check based on substance quantities alone may therefore lead to the wrong conclusion.

A hypothetical example. An enterprise operates a building-stone quarry with a crushing and screening plant. Extraction of common minerals is excluded from the relevant line of the criteria, so the conclusion depends on other characteristics: the types of work, the presence of explosives or other hazardous substances, and their quantities relative to the thresholds. An underground gold mine is a different case: underground work and extraction of metallic minerals are expressly listed among the activities. In both cases the conclusion is documented rather than inferred by analogy with a neighbouring enterprise.

Who develops and approves the declaration

Under Article 76, the declaration is developed by the organisation operating the hazardous production facility itself and approved by the head of that organisation, who is also responsible for the timeliness, completeness and accuracy of the information. External specialists may assist with analysis and calculations, but responsibility for the document remains with the operating organisation.

Working group and the role of consultants

A working group is established by order of the head of the organisation. Under the Rules for Developing the Declaration approved by Order No. 341 of the Minister for Investment and Development dated 30 December 2014, it comprises at least three specialists with higher technical education, at least five years of practical experience at the declared facility in the relevant industry and a passed test of industrial safety knowledge. The group prepares the draft declaration and, if it reaches a positive decision, submits it to the head of the organisation for approval.

In this arrangement, Minerals Operating acts as an external consultant to the working group, not as a substitute for it. Its involvement may include analysis of design and process data, verification of facility characteristics, methodological support in building accident scenarios and selecting assessment methods, and preparation of individual materials such as descriptions of the process and equipment. The scope is fixed by contract.

Input data required

The more complete the input data, the fewer clarifications are needed and the more reliable the calculations. The main groups of documents are:

• information on the organisation and the facility — location, purpose and production units, needed for the general section;
• design documentation and process flow diagrams, showing where and under what conditions hazardous substances are handled;
• a list of process equipment with specifications, the basis for identifying potential points of loss of containment or failure;
• types and maximum quantities of hazardous substances, which determine whether the criteria apply and the scale of consequences;
• layout plans of buildings and equipment, needed to assess impact zones;
• information on protection systems — interlocks, alarms, fire protection and warning systems.

Operational information is added: personnel training, accident and incident records, accident prevention measures and arrangements for emergency rescue support. For a planned facility, most information comes from the design — process solutions, equipment specifications, the site master plan and designed safety systems; accident analysis may draw on records from comparable facilities. The list is not exhaustive and is refined for each facility.

Gaps are identified before calculations begin: missing documents are listed and a responsible person is assigned. A typical situation: the design specifies a fuel store of one capacity, but additional tanks were installed during reconstruction. A calculation based on the design figure would understate the quantity of substance and the impact zones, and the declaration would not reflect the real facility.

What an industrial safety declaration contains

The template under Rules No. 341 has four sections: general information, nature and scale of hazards, safety and public protection measures, and appendices.

General information about the facility

This section covers location, climatic conditions, the purpose of the facility, particularly hazardous operations, the population within the sanitary protection zone, and general safety measures: industrial safety control, injury and accident records and personnel training. These data determine who could be exposed and how realistic the measures are.

Hazard and accident analysis

This section links substances, process and equipment with accident scenarios. The specialist considers initiating events — loss of containment, equipment failure, human error and external impact — analyses how accidents may develop, and assesses risk and effects on people and the environment. The Rules permit the use of risk-assessment software.

A hypothetical chain: a diesel tank on the mine's industrial site → loss of containment, spill into the bund and ignition → thermal impact on personnel and nearby equipment → bunding, level control, fire-fighting equipment, warning and evacuation. For this scenario, a pool-fire calculation method is applied; the example gives no numerical values, as these can only come from facility data.

Readiness to contain accidents and mitigate their consequences

This section covers warning systems, protection of people, fire protection, resource reserves, medical support and the procedure for informing the public and authorities. The review examines personnel actions, warning coverage, resources and interaction with emergency rescue services. Measures must respond to the identified scenarios: if a pool fire at the fuel store is possible, the section should make clear who contains it and with what means.

Appendices and supporting materials

The appendices required by Rules No. 341 are a site plan, a process flow diagram, an equipment layout plan, regulatory documents and an information sheet. They allow the text to be checked against drawings: the site plan, for example, is used to verify distances from the hazardous area to buildings, roads and places where people are present.

How the declaration is prepared

Facility review and work organisation

Work begins by confirming whether declaration is required. The head of the organisation establishes the working group, and its members, together with any consultants, agree the input data and schedule. The result is a list of tasks, responsible persons and missing materials.

Hazard analysis and calculations

Hazard sources are identified from the input data, scenarios are developed and consequences assessed. Methods are selected to suit the substance, equipment and scenario, and assumptions are recorded so that they can be checked. The result is a substantiated conclusion on the facility's hazards.

Review of protective measures and preparation of sections

Scenarios are compared with existing measures, and proposals are prepared for any gaps. Decisions on changes at the facility are made by the management of the operating organisation; the consultant prepares the justification. Sections and appendices are drafted in parallel.

Completeness check and approval

Substance quantities, equipment, diagrams and plans are reconciled across all sections. The working group reviews the draft and submits it to the head of the organisation for approval. The result is an approved package ready for registration; registration itself is a separate state procedure.

Registration and amendment of the declaration

Approval is an internal decision of the organisation; registration is a state procedure. The registration code is assigned by the authorised industrial safety body, the Industrial Safety Committee of the Ministry for Emergency Situations; operation of an HPF without a registered declaration is prohibited. The application and an electronic copy of the declaration are submitted via egov.kz, and the result — registration with a code or a reasoned refusal — is delivered to the applicant's personal account.

Under the current Rules, the public service takes 3 working days. This is the period for reviewing the package, not for preparing the declaration. Grounds for refusal are set out in the Rules and include inaccurate documents or information and non-compliance of materials with regulatory requirements. Eliminating typical preparation errors — inconsistencies between sections, outdated plans, scenarios unrelated to the equipment — reduces the risk of refusal but does not guarantee registration.

When updating and re-registration are required

Where conditions affecting industrial safety change, including modernisation or repurposing of the HPF, the declaration must be amended or deregistered. An amended declaration is re-registered no later than three months after the amendments are made (Article 76). Revision is triggered by changed conditions, not by a calendar cycle.

Example: a processing plant rebuilds its reagent section, changing the reagent, the store capacity and the dosing scheme. The list and quantities of hazardous substances, the process and equipment description, scenarios, calculations, protective measures and appendices are all reviewed. The effect of each change on the document is assessed individually.

What determines timing and cost

The workload depends on the number of process units, the hazardous substances involved, scenario complexity, the volume of calculations and the quality of documentation. A preliminary estimate requires the facility type, types of work, a list of hazardous substances with approximate quantities, and information on design documentation and any previous declaration.

The proposal is prepared after reviewing the facility and sets out the consultant's scope, the materials to be prepared and the stages. Work outside the declaration itself, such as a site survey or updating outdated plans and diagrams, is estimated separately.

Support with declaration preparation in Almaty

As part of its technical support, Minerals Operating helps the working group move from the applicability check to a package ready for approval: it analyses design data, compiles the list of input information, takes part in developing scenarios and reconciles sections with appendices. At mining and processing enterprises, development of an industrial safety declaration for hazardous facilities relies heavily on the mining plan and other design documentation describing the process and equipment.

The company's website lists mining plans for the Dalabai, Ayat, Kentobe, Atansor and other deposits. This is design experience, not declaration experience, but it helps the team work quickly with a mine's documentation. Minerals Operating supports projects in Almaty Region and elsewhere in Kazakhstan: the client's office may be in Almaty while the facility lies outside the city, so documents are reviewed remotely and site visits are planned around specific tasks.

For a preliminary assessment, please provide the facility type, location, main process and a list of available documentation. At this stage a description is sufficient; technical documents are shared by agreement.

Frequently asked questions

Does every hazardous production facility need a declaration?

No. Declaration applies to facilities that meet the criteria of Order No. 240, either by type of activity or by quantity of hazardous substances. Without a list of processes, types of work and maximum substance quantities, no conclusion can be reached for a specific facility.

Can a ready-made declaration template be used?

A template based on the structure of Rules No. 341 helps organise the document but does not replace analysis: the information, scenarios and calculations are specific to the facility.

How long do preparation and registration take?

The time comprises data collection, calculations, internal reviews and the public service, which takes 3 working days. The early stages depend on the facility and its documentation, so the overall timeline is set after an assessment.

Must the declaration be changed after modernisation?

If modernisation changes the conditions for ensuring industrial safety, yes, followed by re-registration. The effect of the changes on the information and conclusions is assessed first, and the required actions are then determined under the current requirements.