Page 43 - MGPI_Case_Study

12.0 RECOMMENDATIONS
For chemical distribution companies:
TO THE AMERICAN SOCIETY OF HEATING REFRIGERATION
10. Ensure drivers are fully aware of the location and use AND AIR CONDITIONING ENGINEERS (ASHRAE):
of all CTMV emergency shutoff mechanisms. The CSB reiterates the following recommendation
11. Evaluate the need to train drivers to don appropriate originally issued to ASHRAE in 2005 as part of the
PPE and respond to chemical spills or releases Honeywell International chlorine release investigation:
during unloading operations. Where mitigating
incidents is feasible, chemical distributors should 2003-13-I-LA-R22:

provide the appropriate PPE for doing so on CTMVs. Develop guidance on the effective design and maintenance
Where mitigating incidents is not feasible, chemical of HVAC systems and other necessary control room
distributors should ensure that drivers have access to, components designed to protect employees and equipment
and are properly trained to wear, emergency escape in the event of a release of hazardous materials.
respirators on CTMVs to safely evacuate in the event
of an incident. As a result of its investigation, the CSB makes
the following safety recommendations:
11.0 CONCLUSION

According to the National Association of Chemical Distributors TO MGPI PROCESSING, INC.:
(NACD), whose membership represents more than 85% of 2017-01-I-KS-R1:
U.S. chemical distributors, in 2016, more than 39.9 million Commission an independent engineering evaluation of the
tons of product were delivered to customers every 8.4 Mod B building and ventilation system and, based on the results
seconds. The incident at MGPI highlights that, even though of that evaluation, implement design changes and controls
unloading operations are relatively simple, the consequences to protect occupants from a chemical release. At a minimum,
can greatly impact workers and surrounding communities the evaluation should assess the effectiveness of the building
due to the large amount of chemicals transferred during ventilation system, indoor and outdoor sources of chemicals,

deliveries. Because chemical deliveries are so common air intake locations, contaminant control methods such as
at fixed facilities, the CSB urges facilities and chemical filtration and removal, contaminant monitoring devices, and
distributors to adopt the Key Lessons and Recommended automation. The engineering evaluation of the ventilation
Practices from this Case Study and work collaboratively to system should consider airborne contaminants during normal
implement controls and practices that prevent or reduce operations as well as spills, releases, and chemicals produced
the opportunity for inadvertent mixing incidents. Following from unintended reactions and inadvertent mixing.
the issuance of this Case Study, the CSB will work with the

Chlorine Institute, NACD, and unions representing chemical 2017-01-I-KS-R2:
facility and chemical transport workers to communicate the Key Conduct an evaluation of the Mod B chemical transfer equipment
Lessons and Recommended Practices to their membership. (e.g., fill lines, transfer valves, transfer piping, tanks and other
associated equipment) and install appropriate engineering
safeguards to prevent and mitigate an unintended reaction,
chemical release, or spill during bulk unloading. Where feasible,
install safeguards, such as alarms and interlocks, to prevent
personnel from opening the incorrect chemical transfer valves
during deliveries. In addition, install mitigation measures to

automatically shut down the transfer of chemicals into the
facility based on process deviations or abnormal conditions (e.g.,

CSB MGPI Processing Case Study 43