As can be seen in the video below there is a drum that is clearly labeled FLAMMABLE with its red placard suspended over a plastic IBC (i.e. tote).  The Orange County Fire Investigation Unit has determined that "static electricity caused a flammable liquid to ignite" inside the cosmetic manufacturing facility on November 20, 2017. The cause was ruled 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.  The worker was merely the path to 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 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 Category 2 Flammable liquid which carries the following GHS Precautionary statements for 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 absolutely NOTHING to discharge the static that is being generated inside the plastic tote.  It will be interesting to see what OSHA will cite, but 1910.106 will certainly be their foundation.

NOTE: the worker in the video suffered ONLY minor injuries; it was another employee who died in the fire/explosions.

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