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Polyone since 7/11, S-Con, Inc since 7/11, Michels Corporation since 7/11, Fluor-B&W Portsmouth since 6/2011, and Suzlon since 2009

Items in this week's newsletter:


  •  RR883 - Vulnerability of oil contaminated fire retardant overalls
  •  What is a “Hybrid Mixture” when talking about flammable vapors and combustible dusts?
  •  Final Rules on HazCom, Confined Spaces Expected This Year
  •  The Department of Homeland Security has PROPOSED a security program for Ammonium Nitrate
  •  Cal/OSHA fines prominent pharmaceutical firm $371,000 for confined space safety violations leading to a worker fatality

Sidebar Items:

  • SAFTENG BlogSAFTENG LinkedIn Forum
  • Safety and Health Tip – Hazardous Locations
  • Civilian Fire Fatalities
  • Safety Recalls
  • EHS Events

RR883 - Vulnerability of oil contaminated fire retardant overalls

Overalls become oil-contaminated very rapidly in many work situations, particularly offshore, in some cases within one day. From time to time, there are significant hydrocarbon fires offshore (eg on the Rough Platform). There is evidence that frequent washing reduces the fire retardant properties of some materials, thereby increasing personal risk to persons and compromising their safety in a fire.  Secondly, there is a problem with fires in the laundries offshore. Because of the large potential for escalation of fires offshore, the reduction of fuel loading and the prevention of ignition sources must remain a high priority. The presence of possibly flammable, oil-contaminated overalls with potential for self-heating exacerbates this problem.  Therefore, an experimental trial has been commissioned to investigate the possible degradation of the fire performance of fire protective overalls. This began with, a review of national standards to identify a suitable measure of fire performance that can be used to measure possible loss of protection after laundering.  This in turn was used to establish a test procedure to allow the comparison of new fire retardant material with laundered material, both stained and clean.  This report and the work it describes were funded by the Health and Safety Executive (HSE). Its contents, including any opinions and/or conclusions expressed, are those of the authors alone and do not necessarily reflect HSE policy.  Click Here (pdf) for the Report.

What is a “Hybrid Mixture” when talking about flammable vapors and combustible dusts?

A lot of folks know about flammable liquids and their vapors.  A smaller group of folks know about combustible dusts.  Yet there is a even a smaller group that knows that when a flammable vapor/gas and a combustible dusts are mixed together, both the vapor and the dust will have a LOWER LEL than if they were in an atmosphere by themselves.  Here is what happens and why it is important to consider this phenomenon in your safety systems. We call these mixtures "Hybrids".  A "hybrid" is where two or more flammable materials of different phases (e.g., a dust and a vapor) are present in the same mixture. Tests have shown that adding a flammable gas to a dust suspension can greatly lower the ignition energy of the dust. This phenomenon is especially true where the gas is present at a concentration below its lower flammable limit (LFL) or the dust is below its Minimum Explosible Concentration (MEC). Such hybrid mixtures can sometimes be ignited even if both components are below their lower limits. A "hybrid" mixture can be formed by the following: 

  1. Vapor desorption from particulates (such as in resin product receivers) 
  2. Reaction of particulates with atmospheric moisture that produces a flammable gas 
  3. Introduction of a dust into a flammable vapor atmosphere (such as adding a dust or powder to a flammable liquid) 

The term "hybrid" applies to any mixture of suspended combustible dust and flammable gas or vapor where neither the dust itself nor the gas or vapor itself is present in sufficient quantity to support combustion but where the mixture of the two can support combustion. Hybrid mixtures pose particular problems because they combine the problems of the high charge densities of powder-handling operations with the low ignition energies of flammable vapors. The MIE of a hybrid mixture is difficult to assess, but a conservative estimate can be made by assuming that the MIE of the mixture is at or near the MIE of the gas alone. Because hybrid mixtures contain a flammable gas or vapor, they can be ignited by brush discharges.  It is ABSOLUTELY CRITICAL that this phenomenon be taken into consideration when designing safety systems such as "inerting" the head space of process vessels.  Engineers need to realize that when a combustible dusts are added to vessels in the presence of a flammable vapor or gas, that RISKS are INCREASED by a considerable amount.  Without the dust in the mixture, the atmosphere in the vessel may not reach the LEL of the flammable vapor; but when personnel begin to add the combustible dusts - the "hybrid mixture" will LOWER the LEL for the flammable vapor AND the combustible dust's Minimum Explosible Concentration (MEC) will also lower in this atmosphere, making ignition that much easier.  Coupled with the fact that the dust is a MAJOR source of static electricity, this is why adding powders to flammable liquids is the #1 cause of flammable liquid process explosions.  Keep in mind that most of the common hydrocarbons have Minimum Ignition Energies (MIE) well below 1 mj, just a fraction of the energy generated by the falling powder/dusts.  With a lowered LEL for the vapor and the combustible dust, this is just a recipe for disaster.


Final Rules on HazCom, Confined Spaces Expected This Year

On July 7, OSHA released its semiannual regulatory agenda, which is a listing of all the planned regulatory actions the agency expects to have under consideration for promulgation, proposal or review over the next 6 to 12 months. According to the agenda, OSHA’s effort to make the agency’s Hazard Communication standard consistent with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) will be finalized in September 2011. A final rule for confined spaces in construction is expected in November 2011.  Other planned final rules include updates to OSHA standards for acetylene and personal protective equipment (PPE) and completed action on the Standards Improvement Project (SIP III), which aims to improve and streamline OSHA standards.  Also on the agenda are proposed rules for occupational exposure to crystalline silica, occupational injury and illness recording and reporting requirements for modernizing OSHA’s reporting system, and adding a musculoskeletal disorders (MSD) column to the OSHA 300 Log.  Listed in the prerule stage are actions on bloodborne pathogens, combustible dust, infectious diseases, injury and illness prevention program (I2P2), and occupational exposure to beryllium and food flavorings containing diacetyl and diacetyl substitutes.  The Dept. of Labor (DOL) held live web chats on planned regulations. The OSHA chat was held Monday, July 11 and a replay of the chat is available on the DOL website.  To view a complete list of planned actions for OSHA and other DOL agencies, visit the website of the Office of Information and Regulatory Affairs.


The Department of Homeland Security has PROPOSED a security program for Ammonium Nitrate

DHS published a Notice of Proposed Rulemaking for the Ammonium Nitrate Security Program in the Federal Register on August 3, 2011. The proposed rule would regulate the sale and transfer of ammonium nitrate (AN) to help prevent the misappropriation or use of AN in the act of terrorism. CFATS facilities, regulated for possession of AN, are affected by this proposed rule. Click here for a copy of the proposal. Comments on the proposal are due on or before December 1, 2011; comments on the proposed collection of information is due on or before October 3, 2011.


Cal/OSHA fines prominent pharmaceutical firm $371,000 for confined space safety violations leading to a worker fatality 

Cal/OSHA issued eleven citations totaling $371,250 to a prominent pharmaceutical plant for deliberate and willful workplace safety violations which resulted in the death of one of their technicians and serious injury of two others. The violations included four willful citations, indicating intentional violation or knowledge of a violation.  On January 21, a technician, 33, collapsed when he entered a seven foot deep, 6,000 liter tank in which nitrogen gas was being bubbled through plasma as part of a protein extraction process. Air in the tank had been displaced by the nitrogen gas resulting in an oxygen deficient atmosphere in the tank. Cal/OSHA regulations require employers to have special protective procedures in place prior to the entrance by employees into these types of confined spaces. In this case, the employer had not tested the atmosphere prior to entrance to insure there was sufficient oxygen, which led to the technician’s death.  Cal OSHA’s investigation further revealed that when the technician was discovered, a supervisor ordered two other employees to enter the tank and retrieve him, without testing the atmosphere of the tank or providing proper equipment and other safeguards necessary for a safe rescue. As a result, the technician died and the two employees sent to retrieve him were seriously injured. One remains hospitalized since January. Cal/OSHA determined that the plant’s confined space program failed to comply with all requirements, including appropriate atmospheric testing, protective equipment as well as rescue equipment and procedures.  The plant is part of a multi-national pharmaceutical company. The facility is the largest of its kind in the nation, utilizing advanced technology to produce plasma proteins.  The citations Cal/OSHA issued included one classified as general and ten classified as serious, four of which were classified as willful. Willful classifications are issued when an employer either commits an intentional violation and is aware that it violates a safety law, or when an employer is aware that an unsafe or hazardous condition exists and makes no reasonable effort to eliminate the hazard. 


SAFTENG LinkedIn Forum 

Click Here to Join the Safety Engineering Network (SAFTENG) Forum on LinkedIn forum.  It's FREE! We now have 1,254 members

NOTE:  If you and I are not "Linked" send me an invitation and I will accept.  I accept ALL invitations from safety professionals.  Also, if you use LinkedIn PLEASE consider joining the Safety Engineering Network LinkedIn Forum.

Topics this week:

  •  Moratorium on new applications - extending appointments and temporary appointments
  •  Seaton gas fitter fined for work on gas boiler and fire
  •  Cardiff roof company fined after worker's crush injury
  •  SuzetteWoodward's sounds on SoundCloud - Create, record and share your sounds for free
  •  Infant CPR Anytime®
  •  CIH Study Guide Recommendations?
  •  Did you know the LEL of a vapor and the MEC for a combustible dust can be lower when mixed together?
  •  HeartCode® ACLS Part 1
  •  Cylinder Transport - FREE Shocker Photo from Safety Engineering Network (SAFTENG)
  •  Article on preventing noise-induced hearling loss
  •  Ladder Shocker @ MSHA Offices - FREE Shocker Photo from Safety Engineering Network
  •  Contractors and chemical process safety
  •  Saw this yesterday and it is still bugging me
  •  OSHA cites Jay-Bee Oil and Gas in West Virginia for repeat workplace safety violations
  •  OSHA cites Midland, Texas, drilling company following worker's death at Garden City
  •  Vulnerability of oil contaminated fire retardant overalls
  •  Burton brewery fined after man hit by forklift truck 

Jobs posted on SAFTENG LinkedIn Forum:

  •  Project Safety Manager in Atlanta with 7+ years field safety experience
  •  H&S Advisor - UK Wide travel, New Windfarm build projects
  •  HSE Leader in Des Plaines, IL - support a corporate campus
  •  Safety Specialist/Emergency Response Coordinator
  •  Regional Emergency Response Leader-Chemical Industry
  •  Safety Manager - Australia - LNG New Build - 3 years

Safety and Health Tip

Electrical Classification for Hazardous Locations

My line of work brings me into contact with a lot of hazardous locations.  Some weeks I feel I should just sleep in my FR coveralls!  But each month we find errors in hazardous location classifications that could have disastrous results.  This is an attempt to bring to light some of the common errors we have come across.  Click Here to read my article @


Civilian Fire Fatalities

On August 4, 2011, 6 residential fire fatalities were reported by news media throughout the United States. 

Safety Recalls 

Target Recalls Step Stools with Storage Due to Fall Hazard


Build-A-Bear Workshop Recalls Lapel Pins Due to Violation of Lead Paint Standard


NexTorch Recalls Flashlight Batteries Due to Fire Hazard


Cloud Engines Recalls Pogoplug Video File Sharing Device Due to Fire Hazard


Toy Keys with Remote Recalled by Battat Due to Choking Hazard 


Vehicles Recalls 


Tires Recalls


Child Safety Seat Recalls


EHS Events

2011 Georgia Safety, Health and Environmental Conference 

September 6-9, 2011

Savannah, GA



September 14, 2011

Sayreville, NJ


Mary Kay O'Connor Process Safety Center International Symposium

October 25-27, 2011

College Station, TX

If you have a conference or an outing for your safety organization, let me now and I can help spread the message.  And yes, posting is FREE!

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