In my work and travels, I have the chance to come across such interesting situations and this one stands to cause quite the stir in some food plants. The use of a “special solution” that is made up of Acetic Acid (64-19-7), Hydrogen Peroxide (7722-84-1), and Peracetic Acid (79-21-1) to “treat” poultry for food containment seems to be an “industry practice” these days. My client recognized that Peracetic Acid (79-21-1) is indeed a PSM covered chemical when it’s concentration exceeds 65%; however, EPA’s RMP rule does NOT provide a percentage for Peracetic Acid (79-21-1), thus their “1% Rule” applies to this EHS. In this article, I will use the SDS, 1910.119 Appendix A and Part 68.130 to demonstrate how this “1% Rule” could place a food plant “PAA” use into EPA’s RMP (and possibly OSHA’s PSM – but very unlikely). So let’s start with a review of this “mixture” from the SDS info…
