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U.S. EPA Finds C-7 Fluoroketone Acceptable Under SNAP

Ruling Disagrees with Concerns Related to Reactivity and Safety

On April 30, 2013, the U.S. Environmental Protection Agency ("EPA") issued a rule in which 3M's C-7 Fluoroketone was found to be an acceptable substitute for halon 1211 in fire protection streaming applications.

In this ruling, however, the U.S. EPA did more than rule on the acceptability of C-7 Fluoroketone. This ruling also provides a third party independent review and conclusions regarding the competitive misrepresentation in the market regarding fluoroketone technology used in fire suppression. 3M, using peer reviewed literature and sound science, has vigorously defended identical misrepresentation of 3M™ Novec™ 1230 Fire Protection Fluid (C-6 Fluoroketone) from competitive sources. Because Novec 1230 fluid and C-7 Fluoroketone are so close in structure and physical properties, this ruling is the first public statement from a third party to succinctly address competitive misrepresentation of the reactivity and safety of 3M's fluoroketones sold into fire suppression.

The EPA found C-7 Fluoroketone acceptable in September, 2012 and proposed a rule approving the use of C-7 Fluoroketone in streaming for non-residential fire suppression. However prior to the close of the public comment period the EPA received an adverse comment that closely resembled competitive claims on Novec 1230 fluid. Those claims are summarized as follows:

  1. Reaction with water in the environment poses significant potential risk
  2. Reaction with water in the lungs poses significant potential risk

In its April 30, 2013 ruling, the EPA provided direct responses to the claims made in the adverse comment. EPA disagreed with the commenter and detailed its responses as summarized below:

"C-7 Fluoroketone has very low solubility or reactivity in water and it is highly volatile... and will thus not have appreciable effects in any organisms that might be exposed to it."

EPA also explained, "Further, two inhalation studies performed for C-7 Fluoroketone… showed no inhalation portal-of-entry effects. No other observations were reported that might indicate any other adverse effects... The concern with potential toxicity of C-7 Fluoroketone is not supported by information available about its chemistry and current toxicity testing data on the compound."

EPA concluded that, "We have determined that the overall environmental and human health risk posed by C-7 Fluoroketone is lower than or comparable to the risks posed by other available substitutes in the same end use."

In summary, the EPA reviewed the adverse comment and 3M's response to that comment. The EPA agreed with 3M and concluded there were no references to support the competitive claims and that the concerns regarding safety are not supported by the chemistry or the safety testing data on the compound. Also recall that in the EPA's approval of Novec 1230 fluid, the EPA concluded Novec 1230 fluid "is acceptable because it reduces overall risk to public health and the environment in the end use listed."

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