Today a longtime friend and SAFTENG member shared an article in our FaceBook group regarding a food pantry in TN that accidentally gave out fifty-four (54) 1-gallon containers of 50% Hydrogen Peroxide (H2O2) in their food packages. Now I have no idea what a food pantry is doing with 50% Hydrogen Peroxide, much less that quantity. I write a lot about OSHA’s PSM and EPA’s RMP standards, but the one standard that I do not do much with these days is the Chemical Facility Anti-Terrorism Standards (CFATS) from the Department of Homeland Security (DHS). 50% H2O2 is a Chemical of Interest (COI) in CFATS and in fact the percentage starts at 35% for H2O2; so we most certainly have a COI. But would this food pantry be a “covered facility” with fifty-four (54) 1-gallon containers of 50% Hydrogen Peroxide (H2O2)? ABSOLUTELY, here why…
Hydrogen peroxide is an improvised explosive device precursor (IEDP) chemical that has been used to develop explosives used in recent terrorist attacks, including those in Colombo, Sri Lanka; Brussels, Belgium; and Manchester, United Kingdom. Hydrogen peroxide is classified as a theft/diversion COI in Appendix A of the CFATS regulation. Thus, ONLY hydrogen peroxide in transportation packaging, as defined in 49 CFR ยง 171.8, must be counted toward the STQ. For more information on transportation packaging, visit www.cisa.gov/publication/cfats-ao-2016-003.
The screening threshold quantity (STQ) for hydrogen peroxide in transportation packaging at a concentration of 35% or higher is 400 pounds.
The news article stated that the pantry accidentally gave out fifty-four (54) 1-gallon containers of 50% Hydrogen Peroxide (H2O2) in their food packages. Let’s break this down:
The containers were 1-gallon.
H2O2 weighs 9.98 pounds per gallon.
54 gallons of H2O2 would be 538.92 pounds that they gave away.
The 1-gallon containers were the “transportation packaging”.
The pantry falls under CFATS.
FYI – On July 22, 2020, President Trump signed into law Pub. L. No. 116-150 to extend the expiration date of the Protecting and Security Chemical Facilities from Terrorist Attacks Act of 2014, Pub. L. No. 113-254, to JULY 27, 2023.
For more information on hydrogen peroxide as a COI, visit www.cisa.gov/appendix-chemicals-interest. Federal law requires 400 lb or more of a chemical mixture in which the concentration of hydrogen peroxide is 35 percent or higher and is contained in transportation packaging be reported to CISA.