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AAU and COGR Comment on Chemical Facility Anti-Terrorism Standards (CFATS)

As you have duly noted in the past that a “one-size-fits-all approach may not be optimal for such a diverse regulated community”, we ask that you reconsider exempting research and teaching laboratories with similar chemical use patterns at non-commercial, non-profit research organizations, and institutes from the CFATS.   This exemption should also include laboratories in a variety of settings including universities, colleges, research-oriented hospitals and academic medical center laboratories, and independent research institutes. Because limited quantities of these chemicals are dispersed in various laboratories in different buildings and often multiple campuses of the same organization, the risk and possibility that these chemicals could be stolen in the masses required to produce a national security threat are low. 

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