A food pantry, 50% Hydrogen Peroxide, and DHS’s CFATS

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IMG 2446Today 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…

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