Assess the potential impacts on HFCs in fire suppression
On July 2, 2015, the final rule for the Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the Significant New Alternatives Policy (SNAP) Program was signed by the U.S. EPA Administrator Gina McCarthy. In support of the President’s Climate Action Plan (PDF, 310.94 KB), this final rule under EPA’s SNAP program changes the status of a number of substitutes that were previously listed as acceptable, based on information showing that other substitutes are available for the same uses that pose lower risk overall to human health and/or the environment. Specifically, this action changes the listings from acceptable to unacceptable for certain hydrofluorocarbons (HFCs) and HFC-blends in various end-uses in the aerosols, refrigeration and air conditioning, and foam blowing sectors.
To be clear, this rule making did not impact the use of HFCs in fire suppression, either positively or negatively. Careful analysis of EPA’s comments, however, may be helpful in assessing whether or not a future rule making is likely to impact HFCs sold into fire suppression. The aerosol sector, for which the SNAP status of HFC-227ea and HFC 125 was changed from acceptable to unacceptable, is a good place to gauge potential future SNAP rule makings.
Look closely at the “Guiding Principles of the SNAP Program” below.
U.S. EPA’s guiding principles for SNAP emphasize that substitutes are evaluated within a framework of comparative risk, by end use, and that substitutes that present significantly higher risk will be restricted. On the basis of these principles the SNAP status of HFC227ea and HFC125 in aerosols was changed. The EPA concluded that “both HFC227ea and HFC125 have significantly higher GWPs than HFC134a.” The GWP of HFC134a is 1300, which results in an approximate 60 percent reduction in climate impact relative to HFC227ea and HFC125. In the fire suppression sector, substitution of the very same HFCs with 3M™ Novec™ 1230 Fire Protection Fluid or other sustainable substitutes results in more than a 99 percent (PDF, 1.06 MB) reduction in climate impact.
In response to comments, the EPA disagreed that they should not change the status for HFCs in aerosols because emissions from the sector are small. The EPA explains, “We note that any given end-use within the 50-some SNAP end-uses may be relatively small compared to the whole […] Thus, we make our decision by considering the overall risk to human health and the environment posed by the available or potentially available substitutes within each end-use, rather than comparing risks in different end-uses to each other.”
U.S. EPA: Novec 1230 fluid provides an improvement over HFCs
Comparative risk, as referred to in the guiding principles and reflected in the EPA’s decision within the aerosol sector, was clearly articulated in EPA’s original approval of Novec 1230 fluid.
“C6-perfluoroketone [FK-5-1-12, 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.”
While this EPA ruling did not specifically address the fire suppression sector, the ruling is foretelling with regard to how the EPA will be applying the SNAP guiding principles in future rulemaking. The fire suppression sector has sustainable clean agents and within a framework of comparative risk, the HFCs sold into fire suppression have significantly worse climate impact. Claims that HFC emissions from the fire sector are small will not be a compelling reason for EPA to not restrict HFCs in fire suppression. Careful consideration and communication of SNAP’s guiding principles to customers of clean agent fire suppression will help to ensure agent selection that will be sustainable over the life of the system.
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