As seen in the video below, a drum is clearly labeled FLAMMABLE with its red placard suspended over a plastic IBC (i.e., tote). The Orange County Fire Investigation Unit determined that “static electricity caused a flammable liquid to ignite” inside the cosmetic manufacturing facility on November 20, 2017. The cause was ruled as an accident. The explosion is said to have taken place during the manufacturing process when a “worker was wiping excess product in the batch room.” I would bet that the wiping was NOT the generator of the static (although it would generate it over time – the flash occurred as soon as the worker touched the tote); rather what appears to be “splash filling” seen in the video is a better candidate to generate the static in the plastic tote. Here is my analysis of this event…
The worker was merely the path to the ground for the static. This means the charge jumped from the plastic tote to the worker and this occurred right at the vent on the tote where the flammable vapors were discharging during the transfer from the suspended drum. The MIE of hexamethyldisiloxane is less than one (1) mJ, so it does not take much static – in fact, we would not even feel or see a static discharge of 1 mJ. Hexamethyldisiloxane is a Category 2 Flammable liquid that carries the following GHS Precautionary statements for a good reason:
P241 Use explosion-proof electrical/ ventilating/ lighting/ equipment.
P242 Use only non-sparking tools.
P243 Take precautionary measures against static discharge.
Bonding and Grounding, be damned, SPLASH FILLING a flammable liquid into a PLASTIC IBC is generating a LOT of static. I have seen this so many times! They will attach the ground clamp to the metal cage around the plastic tote, which does nothing to discharge the static generated inside the plastic tote. It will be interesting to see what OSHA will cite, but 1910.106 will undoubtedly be their foundation.
NOTE: the worker in the video suffered ONLY minor injuries; it was another employee who died in the fire/explosions.
| Violations/Penalties | Serious | Willful | Repeat | Other | Unclass | Total |
|---|---|---|---|---|---|---|
| Initial Violations | 6 | 2 | 8 | |||
| Current Violations | 6 | 2 | 8 | |||
| Initial Penalty | $58,388 | $0 | $200,473 | $0 | $0 | $258,861 |
| Current Penalty | $42,266 | $0 | $150,355 | $0 | $0 | $192,621 |
| FTA Penalty | $0 | $0 | $0 | $0 | $0 | $0 |
| # | Citation ID | Citaton Type | Standard Cited | Issuance Date | Abatement Due Date | Current Penalty | Initial Penalty | Contest | Latest Event |
|---|---|---|---|---|---|---|---|---|---|
| 1. | 01001A | Serious | 19100028 B01 I | 05/07/2018 | $6,098 | $8,130 | 06/05/2018 | F – Formal Settlement | |
| 2. | 01001B | Serious | 19100029 F04 | 05/07/2018 | $0 | $0 | 06/05/2018 | F – Formal Settlement | |
| 3. | 01002 | Serious |
19100106 E06 I – General. Adequate precautions shall be taken to prevent the ignition of flammable vapors. Sources of ignition include but are not limited to open flames; lightning; smoking; cutting and welding; hot surfaces; frictional heat; static, electrical, and mechanical sparks; spontaneous ignition, including heat-producing chemical reactions; and radiant heat. |
05/07/2018 | 05/11/2018 | $9,701 | $12,934 | 06/05/2018 | F – Formal Settlement |
| 4. | 01003 | Serious |
19100157 G02 – The employer shall provide the education required in paragraph (g)(1) of this section upon initial employment and at least annually thereafter. |
05/07/2018 | 06/22/2018 | $6,098 | $8,130 | 06/05/2018 | F – Formal Settlement |
| 5. | 01004 | Serious | 19100242 B | 05/07/2018 | $4,573 | $6,097 | 06/05/2018 | F – Formal Settlement | |
| 6. | 01005A | Serious | 19100303 F02 | 05/07/2018 | $6,098 | $10,163 | 06/05/2018 | F – Formal Settlement | |
| 7. | 01005B | Serious | 19100304 E01 I | 05/07/2018 | $0 | $0 | 06/05/2018 | F – Formal Settlement | |
| 8. | 01006 | Serious |
19100307 C – Electrical installations. Equipment, wiring methods, and installations of equipment in hazardous (classified) locations shall be intrinsically safe, approved for the hazardous (classified) location, or safe for the hazardous (classified) location. |
05/07/2018 | 05/11/2018 | $9,701 | $12,934 | 06/05/2018 | F – Formal Settlement |
| 9. | 02001 | Repeat |
19100106 E06 II – Grounding. Category 1 or 2 flammable liquids, or Category 3 flammable liquids with a flashpoint below 100 °F (37.8 °C), shall not be dispensed into containers unless the nozzle and container are electrically interconnected. Where the metallic floorplate on which the container stands while filling is electrically connected to the fill stem or where the fill stem is bonded to the container during filling operations by means of a bond wire, the provisions of this section shall be deemed to have been complied with. |
05/07/2018 | 05/11/2018 | $97,002 | $129,336 | 06/05/2018 | F – Formal Settlement |
| 10. | 02002 | Repeat |
19100106 E09 III – Waste and residue. Combustible waste material and residues in a building or unit operating area shall be kept to a minimum, stored in covered metal receptacles and disposed of daily. |
05/07/2018 | 05/11/2018 | $53,353 | $71,137 | 06/05/2018 | F – Formal Settlement |
NOTE: An employee is caught in fire and is killed
At 7:30 p.m. on November 20, 2017, an employee did not evacuate during an explosion and subsequent fire. The employee died from smoke inhalation and thermal injuries.
CLICK HERE for the OSHA Citations (pdf)
CLICK HERE for the Fire Marshal Report