Members of the American Chemistry Council (ACC) and the Department of Home Security (DHS) have clarified the North American Hydrogen Peroxide Panel’s interpretation of the rule stating:
“as long as the delivering carrier is present and the bulk transportation container is under control of that carrier, the facility does not count for purposes of the Top-Screen, any peroxide in the transportation container.”
With the above information and to be consistent with policies of USP hydrogen peroxide manufacturer partners, the following clarifications are provided by USP regarding DHS registration of hydrogen peroxide:
- DHS classified H2O2 as a Chemical of Interest (COI) due to being a candidate for “theft and diversion”.
- Theft and Diversion calculations for Screening Threshold Quantities (STQ) of H2O2 is noted in 6 CFR 27.203(c) and is 35%/400 lbs and is hydrogen peroxide concentrations >34.5% in quantities > 400 lbs.
- A facility that stores H2O2 (≥35%) and has 400 lbs (less than one drum) must complete the DHS Top-Screen (DHS http://www.dhs.gov/csat-top-screen).
- A facility that receives dropped trailers, ISO’s or BISO’s must complete the Top-Screen since a dropped container is not considered to be “in transportation”.
- A facility that receives railcars of H2O2 must do the Top-Screen since a railcar on their site is considered a dropped DOT container.
- As long as the trailer is attended by the driver chemical inside the trailer is not counted towards a facility STQ. If the driver drops a trailer and leaves then the trailer becomes an unattended DOT vessel and subject to the Top-Screen registration.
- For customers currently using 35% or 50% H2O2, USP Technologies can assist by explaining the DHS Top-Screen registration process as well as evaluating site security and current equipment handling systems to ensure each site meets both the DHS requirements and industry standards.
For more information please contact Rico Bova, USP Technologies, Health, Safety and Environmental Manager, 312-404-4262, email@example.com