As part of a prepublication version of the Significant New Alternatives Policy (SNAP) program's Rule 21, the U.S. Environmental Protection Agency (EPA) has formally requested advance comments from the fire protection industry. The U.S. EPA is requesting updated information on continuing the use of hydrofluorocarbons (HFCs), such as FM-200™, in fire extinguishing applications and the availability of substitutes or alternative technologies or processes that would obviate their continued use. The U.S. EPA has already proposed to change the status of perfluorocarbons (PFCs) sold into fire suppression to unacceptable because their high global warming potentials (GWPs) are significantly higher than other available alternatives and that risks, other than GWP, are not significantly different. Now they are assessing whether the same conclusion could be made about HFCs used for total flooding and streaming fire protection applications.
On March 29, 2015, the U.S. Environmental Protection Agency (EPA) released a prepublication version of the Significant New Alternatives Policy (SNAP) program Rule 21 (PDF, 951.93 KB), which, among other initiatives, changes the status of a number of substitutes that were previously listed as acceptable. Coming on the heels of the SNAP Fire Suppression Stakeholder Workshop, SNAP Rule 21 (PDF, 951.93 KB) notes high GWP HFCs represent a substantial portion of the products in the fire protection market. The HFCs most commonly sold into fire suppression, such as FM-200™, have a GWP that is more than 3000 times that of CO2.
Take a look at the GWP content of HFCs commonly used in fire suppression:¹
Compare that to low GWP offerings currently used in fire suppression:
The U.S. EPA wants your comments!
Specifically, the U.S. EPA is requesting comments on total flooding fire suppression uses of SF6, HFC-23 (FE-13™), and HFC-125 (ECARO-25™/FE-25™), and on both total flooding and streaming fire suppression uses of HFC-227ea (FM-200™). They are requesting comments and updated information on the continuing use of these alternatives and the availability of substitutes or alternative technologies or processes that would obviate their continued use. The U.S. EPA's action supports the President's Climate Action Plan to prohibit the use of some harmful chemicals, while encouraging the purchase and use of safe, more sustainable alternatives.
3M encourages fire protection industry stakeholders to submit comments on the Federal eRulemaking Portal (Docket ID No. EPA-HQ-OAR-2015-0663).
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¹IPCC 5th Assessment Report, 2013 100 year, ITH, CO2 = 1 (www.ipcc.ch)
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