Correction of TCE flammability statement in earlier HAZWOPER letter

June 5, 1991

Dr. Richard F. Boggs
Vice President
Organization Resources Counselors, Inc.
[Recipient address omitted]
Dear Dr. Boggs:

It has come to our attention that there exists a factual inaccuracy in our letter to you dated September 4, 1990. On page three in the last paragraph we incorrectly stated that "there is no fire hazard [associated with TCE]". Although TCE burns with difficulty, it has a lower explosive level of 8% and an upper explosive level of 10.5%, a flash point of 90 degrees F and is considered and IC flammable liquid (NIOSH Pocket Guide to Chemical Hazards).

Because the PEL is well below the lower explosive level, there would be little potential of a fire hazard. Therefore the answer to the question remains correct although for different reasons i.e., not because TCE is not flammable, but rather because it is not a fire hazard at the concentrations described in the example.

We hope this inaccuracy has not caused your organization undo confusion in interpreting 1910.120.

I hope this information is helpful. If you have any further questions please feel free to contact MaryAnn Garrahan at (202) 523-8036.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

[The September 4, 1990 OSHA letter and related correspondence reproduced on the OSHA page are omitted here.]