IN-SITU BURNING:
A New Technique For Oil Spill Responseby Alan A. Allen, Spiltec
Woodinville, Washington, USA

1. INTRODUCTION
Large oil spills in coastal waters always draw increased public and regulatory
attention to the difficulties of containing and recovering an oil spill on water.
Massive releases of oil spread rapidly over large areas; they are transported overgreat distances by wind and currents; and they are altered substantially by many
physical, chemical and biological processes. Changes in density and viscosity,
together with the formation of stable water-in-oil emulsions, for example, often
complicate the handling of the oil and increase the amount to be recovered andstored by as much as 2 to 3 times the original volume spilled. It is therefore
extremely difficult to access a major portion of the spill in a timely manner, andto recover and store even that which can be accessed.
The author's experiences during such spills as the Santa Barbara, California spill(1969), the Mizushima, Japan spill (1974), and the Exxon Valdez spill (1989)
provide lasting and humbling awareness of the speed with which large spills canescape man's control. As was observed in these three spills, millions of gallons(thousands of cubic meters) can easily spread over tens to hundreds of square
miles (2.59 square kilometers per square mile) within two to three days of
exposure on open water. Area increases necessitate many control systems withvery high oil encounter rates. Volume increases, because of water uptake,necessitate the availability of enormous oil/water temporary storage containers.
Such problems involved with the mechanical removal of spilled oil demonstrate
the need for immediate response to large oil spills with all available techniques,
including the application of chemical dispersants and the use of controlled
combustion in place (i.e., “in-situ burning”). As a relatively new response
technique, controlled in-situ burning has already been used to eliminate large
quantities of oil quickly and economically.
In 1998, 3M and SINTEF(Trondheim, Norway) conducted an open-water burn test off Spitsbergen
involving 500 gallons (1.9 cubic meters) of crude oil contained in 300 feet (91‑ 1 ‑meters) of 3M Fire Boom (now American Fireboom, made by American Marine,
Inc. in Cocoa, Florida, USA). The Fire Boom was towed in a U-configuration
while a Heli-torch (from Simplex in Portland, Oregon, USA) was used to ignite
the contained oil, 95% of which was eliminated in about 30 minutes.
On March 25, 1989, during the evening of the second day following the
grounding of the Exxon Valdez in Prince William Sound, Alaska, an estimated
15,000 to 30,000 US gallons (57 to 114 cubic meters) of North Slope crude oil
were burned (Allen, 1990). The oil was collected within 450 feet (136 meters)of 3M/American Fire Boom towed in a U-configuration through slightly
emulsified oil patches in the downwind region of the spill. The contained oil
was towed to a safe location away from the main slick, and a surface igniter wasallowed to drift back into the oil. After several minutes, sustained combustion
was achieved with a resulting intense burn of about 45 minutes and a removal
efficiency of approximately 98%.
Numerous other experimental burns have been conducted in the United States,
Norway, and Canada.
One of the most significant experimental burns(involving more than 25 agencies from Canada and the United States) was
conducted off Newfoundland, Canada in August, 1993. Working with morethan 20 vessels, 7 aircraft and 230 people, approximately 200 sensors or
samplers were employed during two separate burns with the 3M/American
Fireboom to monitor numerous physical parameters and combustion products.
Costing nearly $7 million (Canadian), the Newfoundland Offshore Burn
Experiment (NOBE) resulted in the combustion of more than 20,000 US gallons(or 77 cubic meters) of crude oil.
The controlled “in-situ” burning of spilled oil, used properly with due
consideration for safety and exposure to combustion by-products, can eliminate
large quantities of oil more quickly and cheaply than traditional mechanicalremoval methods. Furthermore, burning removes one of the weakest links inmechanical removal, the need to store and dispose of large quantities ofrecovered oil and water. This Paper examines how and why response planners
should consider the burning of spilled oil as one of a number of important tools
available to them.

‑ 2 ‑2. MODES OF RESPONSE
2.1

Mechanical and Non-Mechanical Response

Spill contingency planners have numerous equipment options in designing a
response package for a given facility, vessel, or operation, but these options fall
into the two broad categories of mechanical containment/recovery and nonmechanical removal (primarily in-situ burning and the application of chemical
dispersants). What is important for planners ---and for regulators and the
public as well--- to realize is that these two categories of response are notmutually exclusive. To provide the most effective response under the widest
range of conditions, the Incident Commander should have options from bothcategories.
Containment & Recovery: In the mechanical category, there are many different
types and sizes of oil containment booms, skimmers, pumps, and storage devices
that are used to mechanically deflect, corral and remove floating oil from water.
Containment booms are floating barriers typically towed by two vessels tocontain and thicken oil so that it can then be removed more effectively withskimming devices. Some booms are relatively small with shallow drafts of lessthan 1 to 2 feet (less than 1/2 meter) for use in calm harbor situations or in rivers
with low to moderate currents. Larger booms with drafts of 3 to 6 feet (orabout 1 to 2 meters) are often selected for use offshore in rougher waters.
Regardless of the size, however, most booms will begin to lose oil throughentrainment or splash-over as short-period, wind-waves approach wave heightsof 3 to 5 feet (about 1 1/2 meters). The skimmers available today range fromsmall portable devices to large dedicated, self-propelled, skimming vessels.
Whether operated from within the hull of a vessel or as an over-the-side
skimming system, most skimmers suffer significant reductions in efficiency as
wind-driven breaking waves build to wave heights of 1 to 1 1/2 meters.
Dispersants: As a non-mechanical response technique, dispersant application
involves the use of a variety of different chemicals designed to facilitate thebreakup of an oil slick so that it is dispersed into small droplets suspended within
the water column. In this form, the oil can be naturally broken down anddecomposed much more rapidly. The other advantage is that dispersed oil
tends not to stick to objects including animals and shoreline materials. Some ofthe early dispersants included relatively toxic hydrocarbon solvents, and were
‑ 3 ‑

used in massive doses. Dispersants today have relatively low toxicities and areused at dispersant-to-oil ratios of typically 1:20 to 1:50 or less. The use ofdispersants requires relatively fresh oil (preferably less than 12 hours and rarely
more than 24 to 48 hours after spillage), and sufficient surface energy (a light
wind-chop or more) to aid with the dispersion process. With adequate water
depth, good chemical/oil interaction, and adequate mixing, dispersants can help
to prevent a large oil slick from coming ashore in sensitive areas.
Burning: Response planners have known for some time that in-situ burning canbe an effective way of eliminating large quantities of oil quickly at sea while
minimizing the amount of recovered product that must be transferred, stored,
and disposed of elsewhere. In-situ burning can involve the combustion of
spilled oil that is uncontained on the water's surface or contained either naturally(e.g., by a shoreline or the side of a tanker) or by means of a fire-resistantcontainment boom. Such fire-resistant containment boom, of course, is subject
to the same environmental constraints (wind, waves and currents) that influence
the use of conventional booms. Numerous laboratory tests and several at-sea
trials have shown that relatively fresh oil on water (preferably less than a day or
two old) can be ignited if the oil is at least 0.1 inch (that is 2 to 3 millimeters)
thick. The more weathered or emulsified the oil, the greater the thickness
required for ignition and sustained combustion. Experience has shown that theHeli-torch (a helicopter-slung system involving the release of burning gelledfuel) is an excellent aerial ignition system for the burning of spilled oil. With
nearly 20 years of proven, safe use in several countries, the Heli-torch offers aneffective means of igniting even weathered and emulsified oils (Allen, 1992).
Once ignited, most tests have shown that a contained relatively thick oil slick can
be burned with removal efficiencies of from 95% to 98% or more (Allen
1991a,b).
The development of fire-resistant containment booms in the 1980s provided
response organizations with a means of effectively containing an oil slick toprovide the thickness needed for burning. Fire-resistant boom technology
started with the Dome Petroleum stainless steel boom in Canada in the l970’s
and has led to the development of a number of lighter & less expensive firecontainment booms. Among these products, only the American Fireboom (alsoknown as 3M Fire Boom) has had extensive large-scale tests with burning crude
oil at sea. The American/3M Fireboom makes use of stainless steel, 3Mpatented ceramic fibers and a unique high-temperature flotation core to form a‑ 4 ‑boom that looks and behaves like standard containment boom. This fireresistant boom, however, has survived the rigors of burning oil for up to 48
hours in a static test tank, and it has been used during four full-scale, open-water
burns at sea, including the Prince William Sound burn in 1989 (Allen, 1990, 1992
& 1994).
2.2

Advantages and Disadvantages

Containment & Recovery: As already noted, the performance of mechanicalcontainment and recovery systems strongly depends on wind and sea conditions,
whether or not ice or debris are present in the water, and how weathered the oil
is. In sea states of 3 to 4 (Beaufort Scale), most booms and skimmers begin to
lose effectiveness. Short-period wind-waves of 3 to 5 feet often lead tosignificant losses of oil from a boomed area. These losses may be substantial
during the time that would normally be required to physically recover thecontained oil.
An important limitation of mechanical removal is the fact that skimming systems
by their nature do not recover pure oil from the water’s surface. The amount ofwater recovered with the oil may easily range from 2 to 3 times the volume of oil
recovered. Some of this water may be entrained within the oil (as a water-inoil emulsion), while some may be recovered as “free” water which could be
decanted and possibly discharged. The result is the need for a large amount ofstorage capacity on scene. In fact, the availability of adequate on-scenestorage capacity is often cited as the primary limiting factor for a mechanicalrecovery operation.
While mechanical response techniques have their limitations, they have at least
one distinct advantage: they are the only mode of response with a broad time
window. Mechanical response can go on indefinitely, even after spilled oil has
weathered and come ashore on distant beaches. Of course, one must consider theenvironmental exposures that may occur over such a broad time window, as wellas the financial costs of such a prolonged cleanup operation.
Feworganizations have the resources to continue a spill response operationindefinitely.
Non-mechanical techniques offer an important alternative to mechanicalresponse; and while they may be limited to a relatively narrow “window of‑ 5 ‑opportunity,” they have the important advantage of being able to eliminate large
volumes of oil quickly where mechanical removal is very time consuming andvery expensive.
Dispersants: Effective dispersant application results in the dispersion of an oil
slick as very small droplets in the upper part of the water column. The
potential impacts of those elevated concentrations of oil (typically at significant
concentrations for only minutes to a few hours in open water) must be
considered by any regulators charged with authorizing dispersant application.
With successful dispersion, the need for storage of recovered oil is eliminated,
and the logistical support requirements for response to even a major spill are
kept to a minimum. For spills covering very large areas, the successful
application of dispersants will require the preplanning and staging of dispersant
and application equipment, one or more large fixed-wing aircraft, a spotter
aircraft, facilities for reloading and refueling the aircraft, and trained personnel
available on short notice to operate these equipment.
Any dispersant
application program will require good visibility, sufficient wave action for good
mixing, relatively fresh oil, and a dispersant that is known to be effective for theoil and water salinity involved. In addition, it may be necessary to satisfy
certain regulatory constraints regarding water depth and/or predesignated zones
for acceptable use.
Burning: In-situ burning using fire-resistant containment boom is subject to someof the same environmental constraints as mechanical removal. Since fire boom
behaves like standard containment boom, the same wind and sea limitations forthe containment of oil apply. However, the key differences between the two
methods are the speed with which burning can remove large quantities of oil andthe fact that the need for recovery and storage is nearly eliminated.
Contained relatively fresh crude oil on water burns at a rate of approximately
0.07 US gallons per minute per square foot (2.85 liters per minute per square
meter). At that rate, burning within a 500-foot (152-meter) length of fire boom
towed by two vessels can easily eliminate as much as 500 US gallons (1.9 cubic
meters) per minute, or more than 700 barrels of oil per hour (assuming aneffective containment area of approximately 7,000 square feet or 650 square
meters within the boom). The contained burn area selected for this example(double cross-hatched area of Figure 1) represents a very small region within theboom extending from the downstream apex of a U-configuration forward‑ 6 ‑approximately 1/3rd of the distance to the leading ends of the boom. By
reducing the towing speed, the oiled area within the boom (and therefore theburn area) could be allowed to increase by a factor of 2 to 3 or more. The rate
at which oil would then be consumed could also increase by the same factor.
Figure 1 also illustrates the approximate volume of oil (in barrels per inch of oil
depth) that could be captured at normal towing speeds for various boom lengths
and oil/boom configurations. Examination of Figure 1 reveals that a single
500-foot (152-meter) boom with oil averaging only 4 inches (about 10
centimeters) in depth within the area represented by “1/3d” in the figure, could
hold about 400 barrels (or 64 cubic meters) of oil. Note that a doubling of theboom length to 1000 feet (a little over 300 meters) would increase the oilholding capacity (and therefore the burn potential for a single boom load) by afactor of four.
Thus it is conceivable that a single 1000-foot-long Uconfiguration (all or only partly comprised of fire boom) could involve thecollection and combustion of at least 250 cubic meters of oil.
With removal efficiencies typically falling between 95% and 98%, the above
example could result in the elimination of approximately 240 cubic meters or
more, and very likely involve a completion of the burn in less than 1 hour (eachinch or 25 to 30 millimeters of oil would burn off in about 10 minutes). In
addition, the amount of residue that would need to be recovered (if at all) would
be very small compared to the large volumes of oil and water recovered during
typical skimming operations. The logistical requirements to support in-situ
burning are thus much simpler and the time needed to eliminate large quantitiesof oil is relatively short.
A comparison of the costs of mechanical removal, dispersant application, andin-situ burning reveals that burning is also the cheapest method. The following
costs (based on US dollars, 1993).

‑ 7 ‑Figure 1

Oil area and volume estimates for various U-boom
configurations at normal towing speeds of 1/2 to 2/3 knot
(0.93 to 1.23 kilometers/hour.

‑ 8 ‑were estimated using representative mechanical, dispersant, and burning
systems for the recovery/elimination of approximately 8,000 to 10,000
barrels (1,272 to 1,590 cubic meters) of oil in a 12-hour period:
mechanical, $100 to $150 per barrel of oil; dispersants, $50 to $100 per
barrel; and in-situ burning, $20 to $50 per barrel (Allen and Ferek, 1993).
2.3

Environmental Constraints

It is clear that in-situ burning is an attractive and cost-effective means of dealing
with spilled oil on water. However, the use of non-mechanical methods such asdispersants and in-situ burning is clearly inappropriate in some cases. For
example, dispersants applied to an oil slick in shallow, sensitive, nearshore
waters could be more damaging environmentally than allowing the oil to reachcertain types of shorelines. Similarly, wind and atmospheric conditions would
have to be considered carefully for the proper use of in-situ burning close to
shore. If a spill were near a coastal city and the wind could blow smoke
directly toward that population center, it may be inappropriate to consider
burning.
Since various products of combustion enter the atmosphere from in-situ burning,some opponents of burning suggest that air pollution is simply being substituted
for water pollution.
It is most important to realize, however, thatapproximately one-third or more of the volume of most crude oils consists ofvolatile hydrocarbons, many of which are considered toxic and which will
evaporate from an unburned oil slick anyway. These volatile hydrocarbons are
eliminated by burning.
The primary products of in-situ combustion of crude oil are carbon dioxide andwater vapor. About 90% to 95% of the carbon burned is released to theatmosphere as carbon dioxide, while particulates in the plume commonly accountfor approximately 10 percent of the original oil volume burned. During the
Newfoundland Offshore Burn Experiment (NOBE) all compounds measured at
ground level, including particulates, were found to be below health concern
levels beyond 500 feet (approximately I50 meters) from the fire. Minor
amounts of gaseous pollutants are emitted (carbon monoxide, sulfur dioxide,
nitrogen oxides, etc.), however these too are reduced to insignificant levels
rapidly and within a short distance downwind.

‑ 9 ‑Some polynuclear aromatic hydrocarbons (PAHs) are emitted; however, the mass
released is considerably less than the amount in the original oil since PAHs are
consumed during the combustion process.
A great advantage of burning is the fact that the products of combustion are
diluted in the air above and downwind of the burn, dispersing rapidly tobackground levels.
The relatively localized short-term impact on theatmosphere should be compared with the potential long-term impact of oilinggreat stretches of shoreline if the oil is not removed from the water’s surface.
Furthermore, the volatile toxic hydrocarbons that would have evaporated fromthe surface of the slick are burned instead (Allen and Ferek, in press).
2.4

Role In Contingency P1anning

Offshore spill response organizations should be prepared to respond with bothmechanical and non-mechanical equipment.
Many oil spill responseorganizations in the United States, including Alaska and Hawaii, already havedispersant application capabilities. Many of these same groups are also leading
the way in acquiring in-situ burn equipment and in training personnel for thecontrolled combustion of spilled oil on water. With some of the largest stateof-the-art response equipment inventories in the world, these organizations arepreparing for response to a major spill event in nearly any of the offshore watersof the United States using the latest technology for both mechanical and nonmechanical response. During the past few years, several other responseorganizations outside the United States (e.g., Europe & Asia), have also
expanded their capabilities to include in-situ burning.
Spill response planners are becoming increasingly aware that major offshore
spills can rarely be handled effectively with mechanical response techniquesalone. Equally important is the realization that chemical dispersant application,
while having a high oil encounter rate, may have some significant constraints
involving availability of equipment, water depth, mixing energy, and a relatively
short window of opportunity for successful use. To those who have examined
the full potential of in-situ burning, it is clear that deliberate, controlled burning
also has some significant shortcomings that will preclude its use for certain spill
scenarios. If wind and sea conditions are too severe for the use of conventional
containment booms, it is likely that fire-resistant booms will also have difficultyin containing oil for a burn. If spilled oil has weathered and emulsified to the‑ 1 0‑

point that certain mechanical systems can not be used effectively or that
dispersants would be ineffective, there is the likelihood that ignition of the oil
could be difficult to impossible.
In order to deal with major offshore/coastal spills, response planners need as
many tools as they can get. Mechanical removal, dispersant application, andin-situ burning are important response techniques that have unique advantages
and disadvantages. If these factors are understood and considered carefully byknowledgeable planners, then mechanical and non-mechanical tools can be used
to enhance and broaden response capabilities under a range of environmental
conditions.

3. POTENTIAL BURN SCENARIOS
There are numerous situations where in-situ burning could be considered a viable
response technique for the elimination of spilled oil from offshore explorationand production operations, marine pipelines and tankers, and from spills intorivers and streams. These burn scenarios can be covered under three broad
categories: containment and controlled burning of spilled oil, burning of
uncontained and/or naturally contained oil, and control and suppression of
accidental marine fires.
Fire boom and aerial ignition systems can be used to collect, contain and ignite
oil for controlled burning in a number of ways. Typical scenarios include:

●

●

●

●

●

Collection of oil with relocation for a controlled burn at a safe distancefrom an unignited spill source - Figure 2.
Containment and burning of oil downstream of a burning spill source(drifting, if necessary, with strong currents - Figure 3.
Immediate containment of burning oil at its source - Figure 4.
Collection, relocation, and burning of oil that has already spread overlarge areas - Figure 5.
Controlled burning of oil trapped at shoreline - Figure 6.

‑ 1 1‑

Figure 1

Containment, relocation and burning of oil away fromunignited spill source.

‑ 1 2‑

Figure 2

Containment and burning downstream of ignited spill
source.

‑ 1 3‑

Figure 3

Immediate containment of burning oil at its source.

‑ 1 4‑

Figure 4

Collection, relocation and burning of oil that has alreadyspread over large areas.

‑ 1 5‑

Figure 5

Controlled burning of oil trapped at shoreline.

‑ 1 6‑

In certain situations, spilled oil may remain relatively thick, for example if wind
herds oil against a barrier (e.g., shorelines, ice floes, etc.); if oil collects in thelee of large vessels, islands, etc.; or simply if so much oil is released noto
relatively calm water that a temporary “equilibrium thickness” of a few
millimeters or more is achieved (Figure 7). Once a slick is ignited, natural
thickening of the oil may be enhanced by the thermally induced wind that draws
the oil from the outer edges of the slick toward the burning main body of thespill.
It is sometimes safer to let spilled flammable material disperse naturally in orderto reduce the risk of fire and explosion at the spill site. On the other hand, theimmediate containment of the spill may pose the least overall risk, even though afire could result in the destruction of the nearest vessel(s), facilities, or
equipment. In such cases, secondary fires from spreading burning oil could
result in far greater losses if the source of spillage accidentally ignites and oil isallowed to flow freely away from the source.
Fire-resistant boom can be used as a floating fire-resistant barrier to limit the
spread of an already burning or a potentially ignited oil slick. Such boom canbe used to exclude burning oil from nearby boats, docks, and other facilities, andit can be used to contain burning oil for the application of fire-fighting foam.

4. SAFETY CONSIDERATIONS
As with all oil spill response techniques, the safety of personnel involved must be
given the highest priority in any burn program, and a site- and spill-specific burnplan and safety procedures must be developed. All planning and operational
personnel must thoroughly assess any potential exposure risks associated withthe proposed burn. This risk assessment should include as a minimum:●●

The expected size and duration of burn based on estimated oil volumes,
burn rates, burn-area control measures, etc.;
The location of the burn and any possible change in location due tocurrents, equipment failure, the towing of containment boom, etc. (thisshould include the possible movement of personnel, animals, boats, etc. toareas near the burn, resulting in possible exposure to excessive heat and/or
combustion products);‑ 1 7‑

Figure 1

Burning of thick uncontained oil spill.

‑ 1 8‑

●●The movement and duration of burn for any oil that might be released(accidentally or in response to an emergency) from within an area ofcontrolled burning; andThe location and type of fixed equipment/facilities (e.g., moored vessels,
docks, bridges, etc.) that could conceivably be exposed to burning oil orheavy concentrations of combustion products.

Each individual involved in any capacity with controlled burning should complete
classroom and hands-on training appropriate to his or her responsibilities.
Standard fire safety procedures must be followed. Such procedures would
include Heli-torch preparation and use guidelines, the provision of proper tow
line for fire boom, the use of spotter aircraft, the positioning of support vessels
upwind or sidewind to the burn, the monitoring of air quality where people arepresent, and the provision of adequate personal safety equipment.

5.

SUMMARY AND CONCLUSIONSFor years, the response to major open-water oil spills has proven less thanadequate because oil often spreads rapidly to enormous areas and is depositedover broad coastal regions. Even when containment and recovery systems canbe mobilized in time, they are usually insufficient to deal with the very large
volumes of recovered oil and water. Because of a general lack of preparedness
and the inadequacy of mechanical equipment alone, organizations throughout theworld are rethinking their contingency plans for major spill events. Increased
emphasis is being placed on the use of non-mechanical response methods such asdispersant application and in-situ burning. Chemical dispersants, particularly
when applied from aircraft, provide an effective means of accessing large spill
areas even at remote locations. Contained controlled burning, while subject tomany of the same constraints as contained mechanical recovery, can quickly andsafely eliminate large quantities of oil efficiently, with minimal logistics support,
and without the need for large temporary storage systems on location. Underthe right conditions, burning can also be conducted in very shallow waters (forexample, marshes and streams) where large recovery and storage systems could
not operate.
The concerns about the environmental impacts of in-situ burning are often put torest once it is realized that most of the oil being burned was originally intended‑ 1 9‑

for just that purpose (i.e., combustion in engines, furnaces, etc.) -- albeit in aless smoky manner. No net increase in the emission of carbon dioxide results,
other products of combustion are for the most part minor in amount and rapidly
dispersed, and a net benefit results from the destruction of many of the lighter
volatile hydrocarbons that would have entered the atmosphere throughevaporation had the slick been left on the water.
Neither burning, chemical dispersants nor mechanical cleanup, used individuallyor in concert with each other, will ever account for the removal of all oil spilled.
No one technique should ever be discounted, however, because it is (or may be)
only partially effective. In a major spill event every tool should be considered
and used, if safe to do so, for the removal of as much oil as possible. Even if eachof these response techniques only accounted for 10% to 15% of an offshore spill,
man and nature would likely keep more than 50% of the oil from reaching shore.

NOTE
As with any operation involving work offshore with vessels and heavy equipment,
in-situ burning can be dangerous if not properly conducted. This is particularly
true because of the added variable of fire. However, systems and methods areavailable to conduct in-situ burning operations safely and efficiently. The
reader is referred to a publication by the author for American Marine, Inc.
entitled In-Situ Burning Manual: An Economic Solution for Oil Spill Control formuch greater detail on in-situ burning as a spill response technique.

‑ 2 0‑

BIBLIOGRAPHY
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Allen, Alan A. 1991a. Oil spill response to blowouts at sea. Presented at theFirst Offshore Australia Conference, Melbourne, Australia, November 2527, 1991
Allen, Alan A. 1991b. In-situ burning of spilled oil. Presented at the Clean
Seas ’91 conference, Valletta, Malta, November 19-22, 1991.
Allen, Alan A. 1994. In-Situ Burning Manual: An Economical Solution for Oil
Spill Control.
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Buist, I.A., W.M. Pistruzak, S.G. Potter, N. Vanderkooy, and I.R. McAllister,
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