The Air Up There: In Search of Balance

March 2008

J. Demeter

Everyone, it seems, is looking for balance in life. A Google search of the phrase “Balance Life” turned up 18,500,000 hits, about half as much as “Sex Life”, a clear indication of how important this subject is to all of us. So we weren’t surprised when we learned that the Halon Technical Options Committee has taken up the problem of “Regional Imbalances” of halons in the world. In fact, we were downright giddy since this is exactly what we recommended HTOC do in a prior column.

We’d like to help HTOC cut to the chase. Regional imbalances are caused by regional regulations. Nothing more!  There is a shortage of halon 1211 in the United States and in Europe. Why? U.S. tax code places an import tax on halon 1211 of nearly $45 per pound. We doubt that the IRS has ever collected a penny of tax for imported halon 1211 since the tax alone is almost four times higher than the current market price!  In Europe, the European Commission, in their eternal wisdom, has banned the importation of halons from anywhere outside of the EU! (They want to make sure that nasty halon doesn’t get into the atmosphere over Brussels!)   Hence, none of the approximate 60,000 metric tons of halon 1211 residing outside of the U.S. and Europe will be sold into these markets. So it sits, in pressurized fire extinguishers, rusting, seals drying and corroding, waiting to self-vent into the atmosphere (at best) or injure or kill someone unaware of its pressurized contents. (But at least it won’t happen in Europe!)

(By the way, we can understand a country not wanting to export halons, in an effort to maintain a supply for local industries and essential users, but why would a country not allow an import? If it’s used, well then it served its purpose, if not – well, what difference does it make? Is it being imported just for kicks?)

The U.S. requires EPA authorization prior to the importation of any ozone depletion substance (a good thing), but bases that authorization on the importer having to provide the name of the company from which it came, a contact person at that company including his/her phone, fax and email address. (This is in addition to approval by the exporting countries environmental authority.) The purpose of this is to allow the EPA to independently verify that the halon in question was truly reclaimed and not newly manufactured – which would be a violation of the Montreal protocol as well as the U.S. Clean Air Act. The problem is that there are no more manufacturing companies making halon 1301 or 1211 anymore. The last of the Chinese factories were shut down last summer. Another problem is that many of these halon containing cylinders were manufactured decades ago, installed decades ago and, in some cases, removed a decade ago!! What are the chances of finding that person who can attest to the installation and removal of a halon system ten years ago? In many cases the answer is slim to none.

So, the halon sits waiting, cylinders rusting, seals drying — 50,000 metric tons of halon 1301 and 91,000 metric tons of halon 1211.  Anyone still wondering why there are regional imbalances?

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