Regulatory Background

To protect life and property, the mandatory national standard GB 3836.16-2024, Explosive Atmospheres — Part 16: Electrical Installations Inspection and Maintenance Specification, jointly issued by the State Administration for Market Regulation (SAMR) and the Standardization Administration of China (SAC), has officially come into effect, replacing the previous GB/T 3836.16-2022 edition.

The standard applies to locations where explosive gas or dust mixtures with air, or layers of combustible dust, may create hazardous conditions under atmospheric conditions. It establishes systematic and mandatory requirements for the inspection and maintenance of electrical installations in explosive atmospheres, providing clear technical and compliance requirements for enterprises engaged in operations within hazardous areas.

As critical communication equipment used in petroleum and petrochemical facilities, gas stations, dust-intensive workshops, and other hazardous locations, intrinsically safe radios fall within the applicable scope of these inspection and maintenance requirements. Equipment that does not meet applicable explosion-protection and inspection requirements should not be used in hazardous locations.

Key Changes Introduced by the New Inspection Requirements

1. Mandatory Compliance Requirements

The standard has changed from a recommended national standard (GB/T) to a mandatory national standard (GB), strengthening its regulatory significance and compliance requirements.

Intrinsically safe radios used in hazardous locations are required to meet applicable inspection, maintenance, and explosion-protection requirements. Failure to comply may expose enterprises to regulatory enforcement measures. Where non-compliant equipment contributes to a safety incident, the enterprise and responsible personnel may also bear corresponding legal responsibilities.

2. Enhanced Safety Risk Management

In hazardous environments such as petroleum and petrochemical facilities, gas stations, and dust-intensive workshops, deterioration in the explosion-protection characteristics of intrinsically safe radios may create potential ignition or explosion risks.

The standard emphasizes maintaining the integrity of explosion-protection characteristics throughout the service life of an installation. Standardized inspection and maintenance are therefore essential to identifying deterioration, managing potential risks, and maintaining the intended safety performance of equipment throughout its lifecycle.

3. Enhanced Technical Requirements

Compared with the 2022 edition, the updated standard introduces more stringent requirements for inspection planning, professional competency, and verification.

• Inspection programs should be developed with reference to relevant manufacturer documentation and certification records, providing a more structured basis for inspection and maintenance activities.
• Initial inspections are required to be carried out by appropriately competent personnel or organizations in accordance with applicable requirements.
• The updated compliance framework places greater emphasis on professional inspection and verification, requiring enterprises to ensure that inspection activities, personnel competency, and records satisfy the applicable provisions of the mandatory standard.

Key Regulatory Requirements Relevant to Two-Way Radio Equipment

1. Personnel Competency Requirements — Clause 4.2

To support safe operations in explosive atmospheres, the standard establishes requirements regarding the competency and qualifications of personnel involved in inspection and maintenance activities.

• Role-Based Competency and Appropriate Authorization
  Personnel are generally divided into two categories: responsible persons or technical personnel with management responsibilities, and skilled personnel carrying out professional work.

  Personnel must possess appropriate evidence of competency corresponding to their responsibilities and the types of explosion-protected equipment on which they work. Inspection and maintenance activities should not be performed by personnel whose competency or authorization does not correspond to the work being undertaken.

• Comprehensive Competency Requirements
  Evidence of competency involves more than theoretical knowledge. Personnel should possess the knowledge, skills, and practical experience required by the applicable standard.

  Professional personnel should be able to understand and apply relevant safety documentation and possess the practical experience necessary to perform field inspection and maintenance activities correctly.

• Periodic Assessment and Ongoing Competency Management
  Personnel competency is not treated as a permanent qualification without further review. Competency should be periodically assessed at intervals not exceeding three years to confirm that personnel continue to possess the necessary knowledge and skills and remain aligned with technological and standards-related developments.

  For enterprises, this means establishing an appropriate personnel competency management framework covering training, assessment, authorization, documentation, and periodic reassessment. Effective personnel management is an important part of maintaining compliant inspection and maintenance practices.

2. Defined Types and Grades of Inspection — Clauses 5.1, 5.3 and 5.4

• Initial Inspection
  An inspection conducted on electrical equipment, systems, and installations before they are placed into service.
• Periodic Inspection
  Routine inspection of electrical equipment, systems, and installations conducted at defined intervals. In general, the interval should not exceed three years, subject to the applicable conditions and requirements.
• Continuous Supervision
  Frequent care, inspection, servicing, monitoring, and maintenance of electrical installations carried out by experienced personnel familiar with the specific installation and its operating environment, with the objective of maintaining the explosion-protection characteristics of the installation in satisfactory condition.
• Visual Inspection
  An inspection that identifies readily apparent defects, such as missing bolts, through direct observation without the use of access equipment or tools.
• Close Inspection
  An inspection that incorporates the requirements of a visual inspection and additionally identifies defects, such as loose bolts, that become apparent only through the use of access equipment or closer examination.
• Detailed Inspection
  An inspection that incorporates the requirements of a close inspection and additionally identifies defects that become apparent only after opening the enclosure and/or using tools and test equipment where necessary, such as loose terminals or other internal abnormalities.

3. Inspection Intervals — Clause 5.4.3

The standard adopts a graded inspection approach comprising visual, close, and detailed inspections. These inspection grades address different aspects of equipment condition, from externally visible defects to structural and internal conditions, helping ensure that inspection activities are appropriate to the equipment and operating environment.

• Fixed Equipment
  For fixed equipment, the interval between periodic inspections should generally not exceed three years.
• Portable and Movable Equipment
  For portable and movable equipment, inspection requirements are more frequent due to the greater likelihood of handling, movement, impact, and environmental exposure during everyday use.

  Before each use:
  The user should conduct a visual inspection to identify readily apparent defects or abnormalities.

  At least every 12 months:
  A close inspection should be conducted to evaluate equipment condition in greater detail.

  At least every three years:
  A detailed inspection should be conducted to evaluate the equipment more comprehensively, including internal conditions where required.

  Critical components:
  Relevant critical components should be subject to dedicated inspection at appropriate intervals, including six-month inspection requirements where applicable under the relevant provisions and equipment conditions.

  Establishing inspection intervals according to equipment type, operating conditions, manufacturer information, and applicable standard requirements helps enterprises identify deterioration before it develops into a more significant equipment or safety issue.

Legal and Compliance Considerations

• The use of equipment that does not meet applicable explosion-protection requirements, or failure to carry out required inspection and maintenance activities, may expose enterprises to significant safety and compliance risks.

  Where non-compliant equipment or inadequate inspection and maintenance contributes to an incident, the enterprise and responsible personnel may bear corresponding responsibilities in accordance with applicable laws and regulations.
  During routine safety supervision and regulatory inspections, the compliance status of explosion-protected equipment and the completeness of relevant inspection, maintenance, and traceability records may form an important part of the review.

• Enterprises should therefore establish a systematic lifecycle management framework for intrinsically safe communication equipment, covering equipment selection, commissioning, inspection, maintenance, repair, personnel competency, and recordkeeping.

  For intrinsically safe radios used in hazardous environments, compliance is not limited to the condition of the equipment at the time of purchase. Maintaining the intended explosion-protection characteristics throughout the equipment lifecycle requires qualified personnel, appropriate inspection methods, defined inspection intervals, professional maintenance, and complete records.