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materials.” In 2015 the CSB updated the Recommendations Status references. Other sections provide guidance on, among other
103
to “Open—Acceptable Response or Alternate Response.” At that topics, applicable hazardous substances, sources of hazards in
time, ASHRAE had expressed support for the recommendation relation to work spaces, principles of protection, and equipment
and provided the CSB with an outline of a new guidance selection and installation. Of note, under sources of hazards in
document, “Heating, Ventilation & Air Conditioning of Hazardous relation to work spaces, ASHRAE distinguishes among external
Spaces,” proposed as either an ASHRAE handbook chapter or sources, internal sources, and combined sources. MGPI protected
standard or design guide. ASHRAE also indicated that it planned the occupants of the Mod B building from internal sources
to begin drafting the guidance document in February 2016. that were in the processing area inside the Mod B building;

however, the toxic cloud that entered the Mod B building was
ASHRAE is a global, nonprofit organization that develops the result of external sources and, more specifically, combined
and publishes voluntary consensus standards for the HVAC sources. Additionally, the section on hazards covers hazardous
industry. The standards define minimum values for acceptable conditions normally and abnormally present (e.g., as the
104
performance, whereas its other documents encourage enhanced result of a release from an inadvertent chemical reaction).
105
performance. ASHRAE is accredited by the American National
Standards Institute (ANSI) and follows ANSI requirements for The section on equipment selection proposes to cover,

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due process and standards development. OSHA recognizes among other things and in conjunction with other standards,
both ANSI and ASHRAE standards as national consensus ventilation equipment, pressurization equipment, and filtration.
standards for purposes of identifying recognized hazards Ventilation is further outlined under the principles of protection
that do not have a specific OSHA standard and thus fall under section, which distinguishes between positive and negative
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the General Duty Clause. In addition, model building and ventilation. It also covers other principles of protection such
energy codes have adopted some ASHRAE standards and are as pressurization, containment, isolation and removal, and
required to be strictly adhered to in some jurisdictions. filtration. The rest of the standard or chapter will help facilities
108
select and install the correct equipment to protect occupants.
In 2014, ASHRAE provided the CSB a proposed draft outline

for a chapter or standard titled “Heating, Ventilation & Air ASHRAE has not yet provided the CSB with a draft of the
Conditioning of Hazardous Spaces.” The outline is broken standard or chapter nor a timetable for its completion. The
into eleven sections; the first few cover the purpose, scope, incident at MGPI highlights the need for ASHRAE to continue
definitions, and applicable standards and the eleventh provides developing the dedicated guidance as proposed to the CSB in
2014. The CSB found that existing standards and guidance for
103 An “Open--Acceptable Response or Alternate Response” designation means a
response by a recipient that indicates a planned action that would satisfy the addressing building ventilation at chemical facilities lack specific
objective of the recommendation when implemented, including a written timetable
for completion. information for designing and maintaining HVAC systems
104 ASHRAE. About ASHRAE. https://www.ashrae.org/about-ashrae (accessed September to control hazards from a variety of chemicals and sources. If
13, 2017).
ASHRAE issues this guidance, facilities can apply it to the design
105 ASHRAE. Standards and Guidelines. https://www.ashrae.org/standards-research--
technology/standards--guidelines (accessed September 13, 2017). or modification of occupied buildings and chemical processes, or
106 ASHRAE. Standards and Guidelines. https://www.ashrae.org/standards-research-- when evaluating the effectiveness of their engineering controls
technology/standards--guidelines (accessed September 13, 2017).
to handle contaminants from inside or outside sources.
107 Section 5(A)(1) of the Occupational Safety and Health Act requires that employers
provide employment and place of employment free from recognized hazards that
are causing or are likely to cause death or serious physical harm. This provision
affords OSHA the ability to issue citations when the four components of this provision 5.4 ACCESS TO EMERGENCY ESCAPE RESPIRATORS
are met: 1) the employer failed to keep his/her workplace free of a “hazard,” 2)
the hazard was “recognized” either by the cited employer individually or by the MGPI’s Emergency Response Plan calls for shutting off the source
employer’s industry generally, 3) the recognized hazard was causing or was likely to of a release if safe to do so and evacuating the area. As described
cause death or serious physical harm, and 4) there was a feasible means available
that would eliminate or materially reduce the hazard. in Section 5.2, operators could not stop the release by shutting
108 ASHRAE Standard 90.1 Energy Standard for Buildings Except Low-Rise Residential down the transfer from a safe location because the toxic cloud
Buildings; ASHRAE: Atlanta, GA, 2016.
CSB MGPI Processing Case Study 27