This fact sheet provides an overview of regulations governing the production and use of halon and the development of substitute agents for fire suppression and explosion protection.
A: Under the Clean Air Act, the U.S. has banned the production and import of halons 1211, 1301, and 2402 beginning January 1, 1994 in compliance with the Montreal Protocol On Substances That Deplete The Ozone Layer.
A: No. It is legal to continue to use your existing halon system. It is even legal to purchase recycled halon to recharge your system.
A: The Montreal Protocol does allow production exemptions for what are called "essential uses." Production allowed under the essential use exemption is likely to be very small, however. This issue is discussed below.
A: Currently there are no laws prohibiting halon emissions. However, EPA, the National Fire Protection Association (NFPA), the National Association of Fire Equipment Distributors (NAFED), the Fire Suppression Systems Association (FSSA), and the Fire Equipment Manufacturers Association (FEMA) all discourage discharge testing of halon. Proper conservation of halon includes improving leak detection, preventing accidental discharge, and avoiding testing and training.
A: The U.S. owns 40 percent of the world's supply of Halon 1301. Fire protection consultants and EPA believe that there will be enough of the chemical to service existing critical needs for several years. EPA is working with halon users to ensure that these needs are met with recycled halon.
A: 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.
A: The HRC is a non-profit information clearinghouse established to assist sellers wishing to dispose of Halon 1301 in a responsible manner, and to help buyers with critical uses locate supplies of Halon 1301 for recharging their existing systems.
A: 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 promotion of alternatives to halons for fire protection
A: The term "critical use" is used by HRC to identify priority uses of recycled halon. A 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."
A: 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.
A: The HRC wishes to facilitate 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 "certified" rating, which is granted by HRC's independent review committee, will provide this assurance.
A: The terms of all transactions are completely between the buyer and the seller. HRC merely acts as a clearinghouse by putting buyers and sellers together. However, 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 Information Hotline or HRC.
A: You can phone the HRC at (800) 258-1283 or (202) 223-6166.
A: The military specification for Halon 1211 has been revised to allow the use of recycled halon. Also, ASTM has developed ES 24-93, an emergency specification for Halon 1301 for both commercial and military use.
A: Yes. Several manufacturers have developed recycling equipment for both Halon 1301 and Halon 1211 that recovers almost 100% of the halon and reclaims it to meet specifications. Contact HRC for the list of vendors.
A: It is legal under the Montreal Protocol and the US Clean Air Act to import recycled halon, that is, halon that has been recovered from a fire suppression system. Unused or newly produced halon may not be traded across international borders.
A: Your halon is valuable to society and has a market value. You can make it available to critical users through the HRC, you can sell or give it to the Department of Defense (DoD) halon bank, or you can return it to your halon distributor for resale.
A: No. The HRC is not a physical "bank," but is an information clearinghouse that will help you locate a buyer for your halon.
A: HRC and EPA can help you locate a regional organization that will take your halon as a service.
A: The Defense Logistics Agency (DLA) is coordinating the DoD bank for the U.S. military in order to maintain a reserve of ozone-depleting substances (ODSs) for supporting Mission Critical Requirements. DLA has a policy to rely on reclamation and recovery whenever possible. DLA is willing to purchase recycled ODSs from the public, particularly Halon 1301, CFC-11, CFC-12, and CFC-114.
A: Phone DLA at (804) 279-4525.
A: No. The term "critical use" is being used by HRC as a broad screen to help channel stocks of halons to users with applications requiring halons at least for the near term. The term "essential use" has a specific meaning under the terms of the Montreal Protocol. Under the Montreal Protocol, it is possible for a national government to represent a particular use as essential to society and obtain permission to continue manufacturing new halon for that use.
A: The Montreal Protocol requires that:
A: To have your use designated as essential, you must submit a detailed application to EPA describing the use, why you consider it essential to society, why no alternatives are feasible, and what you have done to locate stocks of banked or recycled halon. If EPA accepts your application, EPA will nominate your use to the Parties to the Protocol. EPA believes, however, that it will be very difficult to obtain this designation.
A: EPA, working with the State Department, must submit the nomination to the United Nations Environment Programme (UNEP) six months before the Parties to the Protocol meet. UNEP's Technical Options Committee will evaluate the technical merits of the nomination and pass its recommendation to the Technology and Economics Panel, which in turn will make a recommendation to the Working Group of the Parties. Once a decision has been made by the Parties, EPA must review the decision to ensure that it complies with the Clean Air Act.
A: While the Clean Air Act requires the phase-out of Halons 1211, 1301, and 2402, only Halon 1301 is likely to be considered for an essential use nomination. There is an oversupply of Halon 1211 in the U.S. and it is unlikely that new production will be necessary. Halon 2402 is rarely used.
A: Nominations for essential uses can be made annually for consideration by the Parties to the Montreal Protocol. EPA recommends that you research alternatives thoroughly, search for recycled halon from both your internal stores of halon in non-essential systems and from other sources, and implement new risk management and conservation schemes to minimize halon emissions. If you still believe you need an essential use exemption, EPA would like to work with you as you develop your application in order to fully represent U.S. interests before the Parties.
A: No. Exemptions will only be granted to individual users. Therefore, each company within an industry must submit a separate application.
A: EPA typically issues a Federal Register notice in the fall calling for nominations to be considered at the meeting of the Parties in the summer or fall of the following year. Call EPA for the current schedule.
A: The Parties will be considering time-limited permission for new production under the "essential use" exemption. New production is still subject to the U.S. tax on newly produced halons ($43.50 per pound for Halon 1301 in 1994), and it may be very costly to manufacture halon in small quantities. After the year 2000, there may be no company in the world still producing halons.
A: EPA's Significant New Alternatives Policy program. The Agency set up the SNAP program under Section 612 of Title VI of the Clean Air Act Amendments (CAA) of 1990.
A: 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. Based on this evaluation, EPA maintains a list of acceptable substitutes and a list of unacceptable substitutes.
A: The final SNAP rule was published in the Federal Register on March 18, 1994. A summary of acceptable substitutes is detailed below in Exhibit 1.
A: 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 quarterly in the Federal Register. Exhibit 1 lists agents which are listed as pending because the evaluation of the product has not yet been completed.
A: 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 flood 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.
A: The key factor in assessing the safety of a halocarbon fire agent is cardiotoxicity. The results of a standard protocol to determine an agent's cardiosensitization level is compared to the amount of agent required to extinguish a fire. We call this comparing the design concentration to the No Observed Adverse Effect Level (NOAEL) and the Lowest Observed Adverse Effect Level (LOAEL).
A: Substitutes being used as total flooding agents have conditions which must be observed. These conditions include:
Please see the SNAP rule for complete details of the use conditions for each agent.
A: Under section 610 of the CAA, Congress requires EPA to ban HCFCs in all "pressurized dispensers." Portable extinguishers fall under the definition of a pressurized dispenser, but total flooding systems and fixed streaming systems do not. However, EPA will allow the sale and distribution of HCFCs in portable extinguishers to commercial users and owners of marine vessels and aircraft, for uses where the HCFC is the most suitable agent for fire safety. The Final Rulemaking for the section 610 "nonessential products ban" for class II substances was published December 30, 1993. For more specific guidance, contact the Stratospheric Ozone Information Hotline or the `Nonessential Products Ban' program coordinator at (202) 233-9729.
A: 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 E7 above.
A: No approval is required from EPA. However, the user must maintain documentation of the evaluation.
A: IG-541 is an inert gas blend which lowers the oxygen level and raises the CO2 level. The design concentration of this agent must result in an oxygen level of at least 10%, and a maximum CO2 level of 5%.
A: EPA is currently evaluating other inert gases to ensure that they are safely used. These gases will be included in the June update of SNAP.
A: Non-halocarbon systems are considered "alternative technologies" and are also subject to EPA SNAP review. Water mist, powdered aerosols and inert gases will all be included in future SNAP updates.
A: EPA maintains a list of acceptable substitutes, but it is up to manufacturers and users to assess their suitability for particular uses.
A: Exhibit 2 is a list of vendors of halon substitutes.
A: The SNAP rule can be ordered for a nominal fee from the Government Printing Office, (202) 783-3238. Ask for the Federal Register published on March 18, 1994.
A: Yes, the rule can be downloaded from the EPA OAQPS bulletin board service (Office of Air Quality Planning and Standards, Technology Transfer Network). The BBS modem number is (919) 541-5742, with modem settings of N, 8, 1, Full Duplex. For assistance in accessing this service, call (919) 541-5384 during normal business hours, EST.
A: The National Fire Protection Association (NFPA) has issued NFPA 2001 to address alternative total flooding agents and further work is underway to address water mist and other alternative systems. In addition, manufacturers of systems containing the new alternative agents typically obtain Underwriters Laboratories (UL) or Factory Mutual (FM) certification.
A: Please contact:
EPA's Stratospheric Ozone Information Hotline
(800) 296-1996
(202) 775-6677
or
Karen Metchis
Halon Program Manager
Stratospheric Protection Division
U.S. EPA 6205J
Washington, DC 20460
(202) 233-9193
FAX (202) 233-9577
Internet: Metchis.Karen@epamail.epa.gov
A: Important phone numbers:
| EPA Stratospheric Ozone Information Hotline | (800) 296-1996 or (202) 775-6677 |
| EPA Halon Program Manager | (202) 233-9193 |
| EPA Nonessential Products Ban Program Coordinator | (202) 233-9729 |
| Halon Alternatives Research Corporation (HARC) | (202) 223-6166 |
| Halon Recycling Corporation | (800) 258-1283 or (202) 223-6166 |
| DLA/DoD Bank | (804) 279-45250 |
| National Fire Protection Association (NFPA) | (800) 344-3555 |
| National Association of Fire Equipment Distributors (NAFED) | (312) 644-6610 |
| Fire Suppression Systems Association (FSSA) | (410) 931-8100 |
| Fire Equipment Manufacturers Association | (216) 241-7333 |
| Underwriters Laboratories (UL) | (708) 272-8800 |
| Factory Mutual (FM) | (617) 255-4773 |
| Internal Revenue Service (IRS) | (202) 622-313 |
Last Updated: January 16, 1996