18 The Hayes facility had a standard practice of requiring personnel to wear all natural fiber clothing (as opposed to
synthetics such as nylon and polyester.) Injured employees were wearing cotton clothing at the time of the
incident. Employees wore fire retardant aprons during drossing and fluxing activities, but not during routine
maintenance or operations tasks.
19 The contractors were testing the furnace stack emissions as part of the Hayes air emissions permit requirements.