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Alternatives to Halon Fire Extinguishers
Questions and Answers on Halons and Their Substitutes
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This page provides a series of questions and answers on the regulations
governing the production and use of halons and the development of
substitute agents for fire suppression and explosion protection.
If you have questions beyond those in this fact sheet, or would like
paper copies of the lists, please call the Stratospheric Ozone Protection
Hotline toll-free at 1 (800) 296-1996 or direct dial 1 (202) 564-1613.
General Questions about Halon
A. The Phaseout of Halons
- When was the production of halons banned?
- Must I now dismantle my halon fire extinguishers / protection
system?
- Are there any federal laws on emissions of
halons?
B. Halon Recycling and Banking
- Where can I purchase recycled halon?
- What is the HRC?
- Who set up the HRC?
- What do you mean by the term "critical use"?
- How is a halon use designated as critical?
- Why do these distinctions matter?
- What are the terms of the contract if I want to buy
or sell halons through the HRC?
- How can I contact the HRC?
- Are there standards for recycled halon?
- Is halon recycling equipment available?
- Can I import halon?
C. Halon Disposal
- I am removing halon from my systems. I don't want to
use it again. What can I do with it?
- Will the HRC come to take my halon?
- What if I can't find anyone to buy my halon because I
have too little for it to be of interest or because I have Halon 1211 or
Halon 2402?
- Tell me more about the DoD halon bank.
- How can I contact the DoD halon Bank?
- Are there any federal laws on the disposal of halons
and halon-containing equipment?
D. SNAP Status and Review Process
- What does SNAP stand for?
- What is EPA doing under the SNAP program?
- When were the SNAP lists published in the Federal
Register?
- What is the difference between a 'Notice,' a
'Proposed Rule' (Proposal), and a 'Final Rule' (Rule)?
- Will there be other agents available in the
future?
- How does EPA decide whether a halon substitute is
acceptable or unacceptable?
- What are the most significant criteria for evaluating
a halocarbon halon substitute?
- Are there any restrictions on the use of these
agents?
- I heard that HCFCs are not acceptable halon
substitutes.
- What are the SNAP limitations on using a PFC (either
C4F10, C6F14 or C3F8) in the U.S.?
- Do I have to obtain EPA approval to use a PFC?
- What is the SNAP status of alternative technologies to halon
such as inert gases, water mist, and powdered aerosols?
- What are the SNAP conditions on the use of inert
gases, which work by lowering the oxygen level?
- Are there conditions on using water mist or water
fog systems?
- Can I use a powdered aerosol in a total flooding
system in an occupied area?
- What halon alternatives are suitable for my particular end
use?
- How can I contact the vendors of these
substitutes?
- How can I obtain copies of the SNAP rules and
notices?
- Are the rules and notices available
electronically?
- What other government regulations or industry
standards concerning halons should I be aware of?
- Where can I obtain additional information about the
SNAP program and likely alternatives for halon?
A. The Phaseout of Halons
- When was the production of halons banned?
Under the Clean
Air Act (CAA), the U.S. banned the production of halon and import of virgin
halons 1211, 1301, and 2402 beginning January 1, 1994 in compliance with
the Montreal Protocol On Substances That Deplete The Ozone Layer.
Recycled halon and halon inventories produced before January 1, 1994, are now
the only sources of supply.
EPA's final rule
published March 5, 1998 (63 FR 11084), bans the formulation of any blend
of two or more of these halons with one exception. An exemption is
provided for halon blends formulated using recycled halon solely for the
purpose of aviation fire protection, provided that halon blends produced under
this exemption are recycled to meet the relevant purity standards for
each individual halon. A fact sheet summarizing
this rule is also available from the Stratospheric Ozone Protection
Hotline. Return to list of questions
- Must I now dismantle my halon fire protection system?
No.
It is legal to continue to use your existing halon system. It is even
legal to purchase recycled halon and halon produced before the phaseout
to recharge your system.
However, due to the fact that halons deplete the ozone layer, halon users
are encouraged to consider replacing their halon system and making their halon
stock available for users with more critical needs. Return to list of questions
- Are there any federal laws on emissions of halons?
EPA's
final rule published
March 5, 1998 (63 FR 11084) prohibits the intentional release of Halon
1211, Halon 1301, and Halon 2402 during the testing, repairing,
maintaining, servicing or disposal of halon-containing equipment or
during the use of halon equipment for technician training. The rule also
requires appropriate training of technicians regarding halon emissions
reduction and proper disposal of halon and halon-containing equipment
(see the guidance
document for more information). The rule became effective April 6,
1998. Return to list of questions
B. Halon Recycling and Banking
- Where can I purchase recycled halon?
Recycled halon can be
purchased from many halon and fire protection equipment distributors or
directly from owners who are decommissioning their halon systems. In
addition, the Halon Recycling Corporation (HRC) may be able to provide
information on such sellers. Return to list of
questions
- What is the HRC?
The HRC is a non-profit information
clearinghouse established to assist sellers wishing to dispose of halon
in a responsible manner, and to help buyers with "critical uses" locate
supplies of Halon 1301 and Halon 1211 for recharging their existing
systems. Return to list of questions
- Who set up the HRC?
The HRC was established by members of
the fire protection community and by the Halon Alternatives Research
Corporation (HARC), an industry consortium that promotes the research,
development, and use of alternatives to halons for fire
protection. Return to list of questions
- What do you mean by the term "critical use"?
The term
"critical use" is used by HRC to identify priority uses of recycled
halon. A halon use is considered "critical" when a need exists "to minimize
damage due to fires, explosions, or other extinguishing agents, which
would otherwise result in serious impairment of an essential service to
society or pose an unacceptable threat to life, the environment, or
national security even though all other appropriate fire protection
measures have been taken." Return to list of
questions
- How is a halon use designated as critical?
The HRC has
established two ways to make this determination. To be "registered," a
buyer must sign a self-evaluation form. To be "certified," a buyer must
submit an application that will be reviewed by an independent review
committee. The committee certifies that the user has a legitimate need
to continue using halon, taking into account technological, economic,
and legal considerations. Return to list of
questions
- Why do these distinctions matter?
The HRC facilitates the
trade of recycled halon. However, some sellers may want to ensure that
their halon is sold only to users with the most critical value to
society. The halon "certified" rating, which is granted by HRC's independent
review committee, will provide this assurance. Return to list of questions
- What are the terms of the contract if I want to buy or sell
halons through the HRC?
The terms of all halon transactions are
completely between the buyer and the seller. HRC merely acts as a
clearinghouse by putting buyers and sellers together. However, HRC will
not facilitate transfers of recycled halon from (1) halon-producing
countries (developing countries) or from (2) countries that import halon
from halon-producing countries. HRC has stated its belief that exporting
recycled ozone-depleting substances (ODSs) to developed countries by
countries that still produce these ODSs goes against the spirit of the
Montreal Protocol. EPA has prepared a "Sample Agreement for the Sale of
Halon 1301" which may be helpful to those writing such agreements. This
document is available on either hard copy or electronic diskette by
contacting the Stratospheric Ozone Protection Hotline or HRC. Return to list of questions
- How can I contact the HRC?
You can phone the HRC at (800)
258-1283, at (703) 524-6636, or fax (703) 243-2874. You can E-mail the
HRC at hrc97@aol.com. Return to list of
questions
- Are there standards for recycled halon?
The military
specification for Halon 1211 has been revised to allow the use of
recycled halon. ASTM has developed D5632-95 (Standard Specification for
Halon 1301) and D5631-94 (Standard Practice for Handling Transportation
and Storage of Halon 1301). ISO 7201 contains standards for halon 1211
and halon 1301. Return to list of questions
- Is recycling equipment available?
Yes. Several
manufacturers have developed recycling equipment for both Halon 1301 and
Halon 1211 that recovers 98-99% of the halon and some units can reclaim
it to meet certain specifications. Contact HRC for the list of vendors
of recycling equipment. Return to list of
questions
- Can I import halon?
It is legal under the Montreal
Protocol and the US CAA to import recycled halon, that is, halon that
has been recovered from a fire suppression system. Each individual
shipment of recycled halon requires prior EPA approval. Approved imports
that enter the U.S. must be reported to EPA on a quarterly basis. Newly
produced halon or halon never installed in a fire suppression system may
not be imported into the U.S. Further information about importing
recycled halon may be obtained by calling the Stratospheric Ozone
Protection Hotline. The Internal Revenue Service imposes a tax on
certain ozone-depleting chemicals. Contact the IRS at (202) 622-3130 to
determine whether there is a tax on imported recycled halon. Return to list of questions
C. Halon Disposal
- I am removing halon from my systems. I don't want to use it
again. What can I do with it?
You can: (1) make it available to
critical users through the HRC; (2) donate it to the Department of
Defense Ozone Depleting Substances Reserve (DoD bank); (3) return it to
your distributor for resale; or (4) send it to a halon recycler. The federal law on the
disposal of halons or halon-containing equipment is discussed in
question C.6 below. Return to list of questions
- Will the HRC come to take my halon?
No. The HRC is not a
physical "bank," but is an information clearinghouse that will help you
locate a user with a critical need for your halon. The HRC is discussed
in Part B above. Return to list of questions
- What if I can't find anyone to buy my halon because I have too
little for it to be of interest or because I have Halon 1211 or Halon
2402?
HRC and Friends of the Earth (FOE) can help you locate a
regional organization that will take your halon as a service. FOE's
Healing the Atmosphere Campaign has a grassroots initiative working in
communities throughout the U.S. Middle Atlantic and New England states
to promote the recovery of halons. Contact Jessica Vallette of FOE at
(202) 783-7400 (ext. 227) or e-Mail jvallette@foe.org. Return to list of questions
- Tell me more about the DoD bank.
The Defense Logistics
Agency (DLA) manages the DoD bank for the U.S. military in order to
maintain a reserve of halons 1202, 1211, and 1301 to support "mission
critical" requirements when commercial sources are not available. DLA
has a policy to rely primarily on DoD turn-ins of recovered halons for
future use. Return to list of questions
- How can I contact the DoD Bank?
Phone DLA at (804)
279-5203 or (804) 279-4525. Return to list of
questions
- Are there any federal laws on the disposal of halons and
halon-containing equipment?
EPA's final rule published March
5, 1998 (63 FR 11084) establishes that halon-containing equipment must
be properly disposed of at the end of its useful life. That is, such
equipment must be sent for halon recovery to a facility operating in
accordance with National Fire Protection Association standards (NFPA 10
and NFPA 12A). The halon itself must be sent for halon recycling to a
facility operating in accordance with NFPA 10 and NFPA 12A, or for
destruction using one of several controlled processes identified in the
regulation. For more details, see the full text of the regulation. Return to list of questions
D. SNAP Status and Review Process
- What does SNAP stand for?
SNAP stands for Significant New
Alternatives Policy program. EPA set up the SNAP program under Section
612 of Title VI of the CAA, as amended in 1990. Return to list of questions
- What is EPA doing under the SNAP program?
Under SNAP, EPA
is evaluating substitute chemicals and alternative technologies that
companies want to use in place of the ozone-depleting substances, to
ensure that they won't cause greater damage to human health and the
environment than the ozone depleters that are being replaced or other
alternatives that are available. Based on this evaluation, EPA maintains
a list of acceptable substitutes and a list of unacceptable
substitutes. Return to list of questions
- When were the SNAP lists published in the Federal
Register?
The SNAP Chronology
includes links to all SNAP rulemakings. Complete list of Fire Suppression and
Explosion Protection Substitutes Return to
list of questions
- What is the difference between a 'Notice,' a 'Proposed Rule'
(Proposal), and a 'Final Rule' (Rule)?
A 'Notice' contains no
regulatory controls and thus does not need to go through the
notice-and-comment rulemaking process. It may contain technical
corrections to earlier rules as well as listings of new agents which are
'Acceptable' without restrictions. It enters into force upon publication
in the Federal Register.
A 'Proposed Rule' (Proposal) contains proposed lists of agents deemed
'Acceptable' (but subject to use restrictions or conditions) or
'Unacceptable'. There is usually a 60-day public comment period
beginning with the date of publication in the Federal Register.
After the public has an opportunity to comment on EPA's proposed
rules, EPA considers the comments, prepares a final rule, and a 'Final
Rule' (Rule) is published enacting the provisions into law. Return to list of questions
- Will there be other agents available in the future?
Yes.
Manufacturers are continuing to develop new agents and technologies
which EPA will review and which will be included on future SNAP lists.
These updated lists will be published periodically in the Federal
Register. Return to list of questions
- How does EPA decide whether a substitute is acceptable or
unacceptable?
EPA's decision on the acceptability of new
substitutes proposed by manufacturers is based primarily on the
potential human health and environmental risks posed by the substitutes
as compared to (in the case of halons) the halon being replaced, as well
as to other substitute fire-control agents. The screening of new
substitutes is done separately for each specific application, such as
for a total flooding agent or for use as a streaming agent. A listing of
‘acceptable' does not imply that the agent is necessarily effective for
a particular fire hazard or site, and users are advised to consult with
a fire protection professional for selection of appropriate
agents. Return to list of questions
- What are the most significant criteria for evaluating a
halocarbon halon substitute?
The key factor in assessing the
safety of a halocarbon flooding agent is cardiac sensitization. The
amount of flooding agent to extinguish a fire is compared to results of
a standard protocol to determine an agent's cardiosensitization levels.
This is known as comparing the design concentration to the No Observed
Adverse Effect Level (NOAEL) and the Lowest Observed Adverse Effect
Level (LOAEL). Return to list of questions
- Are there any restrictions on the use of these
agents?
These halocarbon substitutes are generally subject to use
restrictions under the SNAP program. Please see the SNAP rules for
complete details of the use restrictions for each agent.
When using halocarbon substitutes as total flooding agents the
following conditions, which were adopted from an OSHA safety and health
standard (29 CFR 1910 Subpart L), generally apply:
- Where egress from a normally occupied area cannot be accomplished
within one minute, the employer shall not use the agent in
concentrations exceeding its "No Observed Adverse Effect Level"
(NOAEL).
- Where egress from a normally occupied area takes longer than 30
seconds but less than one minute, the employer shall not use the agent
in a concentration greater than its cardiotoxic "Lowest Observable
Adverse Effect Level" (LOAEL).
- Agent concentrations greater than the LOAEL are only permitted in
areas not normally occupied by employees provided that any employee in
the area can escape within 30 seconds. The employer shall assure that
no unprotected employees enter the area during agent discharge.
Halocarbon substitutes being used as streaming agents are restricted
to non-residential uses. Return to list of
questions
- I heard that HCFCs are not acceptable halon
substitutes.
Under section 610(d) of the CAA, Congress requires
EPA to ban the use of a class of substances including HCFCs in all
`pressurized dispensers,' but allows EPA to grant exceptions from this
ban in certain circumstances. Portable fire extinguishers fall under the
definition of pressurized dispensers. In a final rule published by EPA
on December 4, 1996 (61 FR 64424) EPA provided an exemption to the ban
at CAA 610(d) for portable non-residential fire extinguishers; thus, EPA
allows the sale and distribution of HCFCs for this use.
In addition, HCFCs in total flooding systems and fixed streaming
systems are not subject to the ban at CAA 610(d) because these systems
don't fall under the definition of pressurized dispensers.
For more specific guidance, contact the Stratospheric Ozone
Protection Hotline or the Nonessential Products Ban Program Coordinator
at (202) 564-9729. Return to list of questions
- What are the SNAP limitations on using a PFC (either C4F10, C6F14
or C3F8) in the U.S.?
PFCs may only be used where no other agent
is technically feasible due to performance or safety requirements. The
user must conduct an evaluation of the other alternatives and must
determine that they either will not perform properly or that they will
pose a risk to human health. In addition, PFC use must meet the
conditions discussed in question D.8 above. Return
to list of questions
- Do I have to obtain EPA approval to use a PFC?
No
approval is required from EPA. However, the user must maintain
documentation of the evaluation. Return to list of
questions
- What is the SNAP status of alternative technologies such as inert
gases, water mist, and powdered aerosols?
Non-halocarbon systems
are considered "alternative technologies" and are subject to EPA SNAP
review on the basis of ozone depletion potential, global warming
potential, toxicity, flammability, and exposure potential. Several
alternative technologies have been listed acceptable, and some are
subject to use conditions or restrictions. Return
to list of questions
- What are the SNAP conditions on the use of inert gases, which
work by lowering the oxygen level?
Inert gas systems work by
lowering the oxygen in a room to a level that will not sustain
combustion, while remaining high enough to sustain human life.
SNAP requires that the oxygen level must not fall below 10% if
employees can egress the area within one minute; the oxygen level must
be designed to the 12% level if it takes longer than one minute to
egress the area. The CO2 level must not exceed 5%.
Three inert gases are listed acceptable by SNAP: IG-01, IG-55, and
IG-541. A fourth inert gas, IG-100, was proposed as an acceptable halon
substitute (with use restrictions) on Feb. 18, 1999; final action on
this agent is pending. Return to list of
questions
- Are there conditions on using water mist or water fog
systems?
EPA has listed water mist systems using potable water or
natural sea water as acceptable without use restrictions or conditions.
However, any system with an additive must be reviewed by EPA on a
case-by-case basis. Return to list of
questions
- Can I use a powdered aerosol in a total flooding system in an
occupied area? Powdered aerosol in total flooding systems have
not undergone a medical panel peer review for physiological effects, and
thus they have only been listed as acceptable in normally unoccupied
areas.
Return to list of questions
- What alternatives are suitable for my particular end
use?
EPA maintains a list of acceptable substitutes, but it is up
to manufacturers and users to assess their suitability for particular
uses. Return to list of questions
- How can I contact the vendors of these substitutes?
A list of representatives of makers of halon
substitutes who submitted notices to SNAP is available. HARC maintains a
list of equipment manufacturers (http://www.harc.org). Return to list of questions
- How can I obtain copies of the SNAP rules and notices?
The
SNAP rules and notices can be ordered from the Stratospheric Ozone
Protection Hotline at (800) 296-1996 or 202-564-1613. They can also be
ordered for a nominal fee from the Government Printing Office, (202)
512-1800 or fax (202) 512-2250. You must provide them with the date of
publication of the rule or notice you want (see question D.3). Return to list of questions
- Are the rules and notices available electronically?
All SNAP rulemakings, notices, fact sheets and other
publications are available electronically.
- What other government regulations or industry standards
concerning halons should I be aware of?
The National Fire
Protection Association (NFPA) has published a standards document for
halon alternative agents used in total flooding systems. "NFPA 2001 -
Standard on Clean Agent Extinguishing Systems" contains design,
installation, inspection, test, and use information on halocarbon and
inert gas alternatives. The NFPA has also published a standard on water
mist systems: "NFPA 750 - Standard for the Installation of Water Mist
Fire Protecting System." In addition, manufacturers of systems
containing the new alternative agents often obtain Underwriters
Laboratories (UL) or Factory Mutual (FM) certification, which means
certain standards may apply to the products. Return to list of questions
- Where can I obtain additional information about the SNAP program
and likely alternatives for halon?
EPA's Stratospheric Ozone
Protection Hotline (800) 296-1996 (202) 564-1613
or
SNAP Coordinator Stratospheric Protection Division U.S. EPA
6205J Washington, DC 20460 (202) 564-9163 FAX (202) 565-2155
Return to complete list of questions
Important Phone Numbers For More Information
- EPA Stratospheric Ozone Protection Hotline
toll-free (800)
296-1996 direct dial (301) 614-3390
- EPA SNAP Coordinator
(202) 564-9163
- EPA Import and Production Regulation
(202) 564-9295
- EPA Nonessential Products Ban Program Coordinator
(202) 564-9729
- Halon Alternatives Research Corporation (HARC)
(703)
524-6636 (800) 258-1283 FAX (703) 243-2874
- Halon Recycling Corporation (HRC)
(703) 524-6636 (800)
258-1283 FAX (703) 243-2874
- DoD Bank (Dept. Of Defense Ozone Depleting Substances
Reserve)
(804) 279-5203 (804) 279-4525
- Friends of the Earth (FOE)
(202) 783-7400 (ext. 227) FAX (202)
783-0444
- Internal Revenue Service (IRS)
(202) 622-3130
- National Fire Protection Association (NFPA)
(617)
770-3000 FAX (617) 770-0700
- National Association of Fire Equipment Distributors (NAFED)
(312)
923-8500 FAX (312) 923-8509
- Fire Suppression Systems Association (FSSA)
(410)
931-8100 FAX (410) 931-8111
- Fire Equipment Manufacturers Association (FEMA)
(216)
241-7333 FAX (216) 241-0105
- Underwriters Laboratories (UL)
(847) 272-8800 FAX (847)
272-8129
- Factory Mutual (FM)
(781) 762-4300 FAX (781) 762-9375
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Additional Articles on this Site:
Fire Suppression Systems - Types of Fires and Suppression Systems
Fire Protection Systems - Options to Prospective Owners of Fixed Protection Systems
Fire Prevention Systems - The Transition to Alternatives for Essential Electronics
Fire Control Systems - Use in other Industries
Fire Protection Engineering - Fire Protection for TelCom and E-Commerce
Halon Fire Extinguishers - FAQ on Alternatives
Status of Industry Efforts to Replace Halon Fire Extinguishing Agents - A 57 Page .PDF Report
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Industry Efforts to Replace Halon
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