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U.S. EPA Actions on HFCs Spark Fire Suppression Implications

Implications for the Fire Suppression Sector

The Obama Administration’s 2013 Climate Action Plan (CAP) recognizes HFCs as potent greenhouse gases and that their use and emissions continues to grow. As a result, the Administration directed the U.S. Environmental Protection Agency (EPA) to use existing authority under the Clean Air Act, specifically the Significant New Alternatives Policy (SNAP) Program, to approve climate-friendly chemicals and prohibit some uses of the most harmful HFCs. U.S. EPA has been holding stakeholder meetings with industry to meet the objectives of the President’s plan and recently announced two separate rulemakings.

1. A new SNAP Listing Rule would propose adding new low GWP refrigerants as acceptable subject to use conditions.

2. A SNAP Status Change Rule would propose changing the status of certain high GWP HFCs, restricting or prohibiting use of HFCs in some sectors.

Section 612 of the Clean Air Act directs EPA to list unacceptable substitutes where there are other substitutes currently or potentially available that reduce overall risk to human health and the environment.

EPA's review of the fire suppression sector will reveal multiple substitutes for HFCs in fire suppression, including inert gases and 3M™ Novec™ 1230 Fire Protection Fluid

In fact, U.S. EPA acknowledges that Novec 1230 fluid:

[…] provides an improvement over use of Halon 1301, hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) in fire protection. We find that C6- perfluoroketone is acceptable because it reduces overall risk to public health and the environment in the end use listed. (U.S. EPA, Federal Register, December 20, 2002)

EPA plans to prioritize proposals to change the status of high-GWP HFCs. EPA has already indicated that one of the first possible status changes would be directed at HFC-227ea and HFC-125 (GWPs>3000) in consumer aerosols, while retaining the use of HFC-152a (GWP<150) in that sector.

U.S. EPA is sending a clear signal to the market regarding the future of high GWP HFCs where sustainable alternatives already exist. When choosing a fire suppression system intended to pass the test of time, end-users of clean agent fire suppression need to consider that HFCs are following the path of halon and that sustainable alternatives are available to protect their valuable assets.

Global HFC Consumption chart
Global HFC Consumption chart from SNAP Stakeholder Meeting presentation, August 22, 2013.

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