The engineering controls as stipulated represent and extreme overreach of the regulatory process since it is impractical for Owners of existing buildings, absent of any pending major renovations, to comply with standards that preceded the time when the facilities were designed and constructed.  Equipment originally installed and appropriate to the building occupancy should be required to function as intended and was inspected during construction or last significant renovation.

Building HVAC systems in use have been designed, constructed, and commissioned in accordance strict building code requirements in effect at the time of issuing the Certificate of Occupancy.  The engineering controls should only require systems to be maintained and operated in accordance with their system design and related manufacturer requirements such that the mandatory minimum level of protection of the workforce is ensured.  Engineering controls in part B should be revised and limited to the ASHRAE 62.1 edition in effect at the time of building design or last significant renovation. 

It is still yet to be determined by the industry trade groups as to the most effective design performance requirements for existing and new HVAC systems and any permanent regulations should follow existing processes contained in the Virginia Uniform Statewide Building Code (USBC).