HFC-Based Clean Agents
Sustainable Fire Protection Solutions
Since their introduction in the early 1990s, hydrofluorocarbon (HFC) based clean agents have been
the most widely specified clean agents for fire protection of sensitive, valuable and mission critical equipment and assets. No other issues related to these agents are perhaps more misunderstood or misrepresented than their environmental impact and the implications of regulations on their use in fire extinguishing applications.
Environmental impact: the scientific facts.
Ozone Depletion: Since HFCs do not contain chlorine or bromine, they do not contribute to the destruction of stratospheric ozone; as a result, HFCs are not subject to the provisions of the Montreal Protocol, which pertains only to ozone depleting substances (ODSs).
Global Warming: The impact of HFCs in fire protection on global warming/climate change is often misunderstood and misrepresented. In particular, there are several oft-encountered myths that require addressing.
The first myth is that the emissions of HFCs in fire protection applications have a significant impact on climate change due to the GWP values of the agents
It is important to understand that the impact of a gas on climate change is a function of both the GWP of the gas and the amount of the gas emitted. For example, carbon dioxide (CO2) has one of the lowest GWP values of all GHGs (GWP=1), yet emissions of CO2 account for approximately 85 percent of the impact of all GHG emissions, due to the massive amounts of CO2 released into the atmosphere from numerous sources. Clearly the GWP value by itself cannot be employed to evaluate the environmental sustainability of a particular compound. Emissions of HFCs from fire suppression applications are extremely low, hence the impact of these emissions on climate change is negligible.
Factual information related to the environmental impact of HFCs in fire protection is available from several independent sources including the US EPA and the European Environment Agency (EEA), and indicate that the contribution to global warming of HFCs in fire protection is negligible. For example, in the U.S. the impact on global warming of HFCs in fire protection represents 0.015 percent of the impact of all greenhouse gases on global warming. For the EU-15 countries, the impact on global warming of HFCs in fire protection represents 0.05 percent of the impact of all greenhouse gases on global warming.
That the environmental impact of HFCs in fire protection is rapidly increasing.
Looking to the same independent sources of information, it can be seen that the contribution of HFCs in fire protection to global warming has remained essentially constant for almost a decade (Table 1). Estimates from the HFC Emissions Estimating Program (HEEP) also indicate that the impact of HFCs in fire protection is not increasing but has remained essentially steady for the past decade.
That HFCs in fire protection are subject to the same environmental regulations as HFCs in other applications.
It is a fact that with regard to regulations, HFCs in fire suppression applications are being treated differently than HFCs employed in other applications. Emissions of HFCs from fire suppression applications are dwarfed by HFC emissions from other applications such as refrigeration. Regulatory bodies understand this, and to date HFCs in fire suppression applications have been subject to different sets of regulations. Examples include the recent regulatory decisions of the US EPA and the revised F-Gas Regulations.
US EPA Proposed Rule
On July 9, 2014 the US EPA announced proposed rules that would change the status under the Significant New Alternatives Policy (SNAP) Program of certain HFCs in mobile, stationary, foam and aerosol applications. Consistent with its science-based pragmatic approach of controlling HFC use by application, the US EPA is proposing no SNAP changes to any HFCs when employed in a fire protection application.
What does this mean? HFC-based clean agents continue to be considered sustainable fire protection solutions. In addition, no alternatives are currently available that match the overall combination of proven performance, safety in use and cost effectiveness offered by the HFC clean agents.
European Union F-Gas II Regulation
On May 20, 2014 the European “F-Gas II Regulation” (Regulation (EU) No. 517/2014) was published. Consistent with the US EPA proposed ruling, the EU F-Gas II Regulation also recognises the value and sustainability of the HFC clean agent fire protection technologies. Since HFCs in fire protection have a negligible impact on global warming, restricting HFC use in fire protection applications would not provide any significant reduction in global warming. For this reason the F-Gas II Regulation does not call for specific restrictions on the HFCs most widely employed in fire protection (HFC-227ea, HFC-125, HFC-236fa).
The allocation scheme of the EU F-Gas II Regulation represents an overall “cap and reduction” of HFCs on a GWP-weighted basis over a specific time period – a “phase-down,” not a “phase-out” of HFCs. Figure 3 depicts the effects with time of the EU F-Gas II allocation scheme on the quantity of HFCs available for placing on the market in the EU. The HFC phase-down stipulated by the EU F-Gas II Regulation is unlikely to affect the supply of HFCs for fire protection in the EU market as fire protection represents only 1 percent of the EU HFC market on a mass basis and 3 percent of the total EU HFC market on a GWP-weighted basis [EEA Technical Report No. 15/2013].
Additional regulatory constraints on specific HFCs in refrigeration and other non-fire protection applications, along with the shrinking of the HFC refrigeration market as alternatives such as the hydrofluoroolefins (HFOs) replace HFCs in refrigeration, will result in the further release of allowances, providing more than enough rights for HFCs used in fire protection.
The EU F-Gas II Regulation combines Articles from the original EU F-Gas Regulation related to containment, recovery and training As a result, the requirements of Articles 3 through 10 of the EU F-Gas II Regulation are already being complied with by the fire protection industry. Requirements related to containment including leakage prevention, repair and inspection schedule are satisfied by the existing inspection regimes established by the ISO 14520, EN 15004 or NFPA 2001 standards.
Recovery related requirements are currently being met by the numerous commercial entities already actively involved in the recovery and reclamation of HFC-based clean fire extinguishing agents. Training and certification programs for personnel involved in the handling of fluorinated GHGs have been in place for more than a decade within the fire protection sector. In summary, the requirements of Articles 3 through 10 of the F-Gas II Regulation involve activities already part of any responsible product stewardship program and impose no restrictions on the use of HFC clean agents.
Asia Pacific Region
HFC-based clean agents are currently employed throughout the entire Asia Pacific region; as a result of the July 2014 repeal by the Australian government of its carbon tax, the tax on HFCs was removed and there are now no restrictions or taxes on the use of the HFC-based clean agents within the Asia Pacific region. Furthermore, there is no legislation, either current or proposed, to limit, retract or ban the use of HFCs in fire protection anywhere in the Asia Pacific region. The recent US EPA decisions apply only to the United States and the EU F-Gas II Regulation applies only to the member states of the EU, and has no effect on the use of HFCs in the Asia Pacific region.
Importantly, these recent regulatory decisions are based on sound science and recognise the value and non-emissivity of HFC clean agents in fire suppression. Regulators outside of the USA or the EU, when empowered with the facts, are likely to reach similar conclusions: (1) the use of HFCs in fire protection has negligible impact on global warming, and (2) reducing HFC emissions from fire protection applications does not provide any significant reduction in global warming, and increases the risk of fire and loss to people and property.
The emissions of HFCs in fire protection are extremely low, hence their impact on global warming is negligible. As a result, restricting HFC use in fire protection applications would not provide any significant reduction in global warming and efforts beneficial to the environment are more productively focused on other sectors with much larger impacts. Regulators clearly understand this and HFCs in fire protection are being treated differently than HFCs in other more emissive applications, as evidenced by the recent regulatory decisions of the US EPA and the revised F-Gas II Regulation.
To date no product or technology has been found which satisfies all of the criteria of the ideal Halon 1301 replacement. Each class of clean fire extinguishing agent (HFCs, inert gases and perfluoroketones) has strengths and weaknesses, and clean agent selection must be based on the physical and chemical characteristics of the agent along with detailed knowledge of the specific project requirements. As seen from Table 2, no agent satisfies all of the requirements of the ideal Halon replacement; however, Table 2 shows that the HFC-based clean fire extinguishing agents provide the best overall combination of the desired properties.
The recent regulatory decisions of the US EPA and the EEA are based on sound science and recognise the value, importance, and non-emissivity of HFC clean agents in fire protection, and as regulators outside of the USA or the EU are empowered with the facts, they too are likely to reach similar conclusions: the environmental impact of HFCs in fire protection is negligible and the HFC based clean agents are viable and sustainable fire protection choices for the foreseeable future.
With the recent major regulatory decisions in the USA and Europe, 2014 marks the year in which the sustainability of HFCs in fire protection has been established.
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