HTOC Issues 2010 Assessment

Executive Summary

E.1 Introduction

The following sector summaries show that despite the introduction of new halon alternatives and the remarkable progress in switching to them, there is still an on-going need for halons. As such, halon recycling is becoming even more important to ensure that adequate stocks of halons are available to meet the future needs of the Parties.

E.2 Global Production and Consumption Phase-out of Halons

As of January 1, 2010, halon production and consumption, as defined by the Montreal Protocol, for fire protection ceased. Additionally, there has been no essential use halon production since 2000 (as authorised by Decision VIII/9). However, halon 1301 (CF3Br) continues to be produced in China and France for use as a feedstock in the manufacture of the pesticide Fipronil. The current total halon feedstock production quantities in these countries are not known to the HTOC, but have been increasing annually in China since 2005.

Since 2006, nine Parties have reported a negative production of halons for fire protection, indicating that they have been destroying halons. In addition, the last two producers of halons for fire protection, China and South Korea, reported no exports in 2008 or 2009. However, some halons may have been exported as fire extinguishers and or fire extinguishing systems. Only eight Parties operating under Article 5 reported importing newly produced halons in 2008, down from sixteen in 2006. The global trade in recycled halons is robust, but as would be expected, the trade in recycled halons by Article 5 Parties has been limited, since they were allowed to import newly produced halons through 2009.

Now that there is no global production of halons for fire protection uses, management of the remaining stock becomes crucial for ensuring sufficient halons for applications that need them.

E.3 Fire Protection Alternatives to Halon

Since the 2006 Assessment, there have been some changes made to national and international fire protection standards that affect some of the measures of performance and guidelines for use of the alternative agents. Some harmonisation has taken place, new minimum concentrations recommended for certain re-ignition risks, and new procedures developed for determining safe personnel exposure to the alternatives.

Alternatives based on hydrofluorocarbons (HFCs) continue to dominate the in-kind gaseous alternatives market for flooding applications, whereas alternatives based on hydrochlorofluorocarbon (HCFC)-123 are dominant for the much smaller in-kind streaming market. As yet, an alternative with all of the beneficial characteristics of the halon it is attempting to replace has not yet been developed. Nevertheless, new agents and technologies continue to appear on the market for specific applications. Most recent are pyrotechnic products that generate nitrogen or mixtures of nitrogen and water vapour, and unsaturated hydrobromofluorocarbons (HBFCs).

The selection of the best fire protection method in the absence of halons is often a complex process. Either alternative gaseous fire extinguishing agents, so called in-kind alternatives, or not-in-kind alternatives may replace halon but the decision is driven by the details of the hazard being protected, the characteristics of the gaseous agent or alternative method, and the risk management philosophy of the user.

E.4 Climate Considerations for Halons and Alternatives

HFCs, HCFCs, and to a much lesser extent perfluorocarbons (PFCs) have been commercialised as replacements for halons. The development of these chemicals for use in fire and explosion suppression applications was instrumental in achieving the halon production phase-out mandated by the Montreal Protocol. In some applications, HFC based agents are the only alternatives for halons.

The Technology and Economic Assessment Panel (TEAP) update of the Intergovernmental Panel on Climate Change (IPCC) / TEAP Special Report on Ozone and Climate concludes that the greenhouse gas (GHG) reduction potential from fire protection is small due in part to the relatively low emission level and the significant shift to not-in-kind alternatives. Nevertheless, in 2009 and again in 2010 amendments have been proposed that would add HFCs to the Montreal Protocol and slowly phase down their production. The Parties may wish to consider that any future HFC amendments or adjustments include provisions for fire protection uses that have no alternatives other than ozone depleting substances (ODSs) or the high global warming potential (GWP) HFCs.

There are a few important fire protection applications such as crew bays of armoured vehicles where the only current options are to use recycled halon or a high GWP HFC. From a total environmental impact perspective, is it better to reuse an already produced, recycled halon or produce a high GWP HFC for the application? This is a challenge that the Parties may wish to consider.

E.5 Global Halon 1211 and 1301 Banking

Halon banking is a critical part of the management of halons. Halon Bank Programmes must be accessible to all halon users or the risk of accelerated atmospheric emissions will escalate as users find themselves with redundant stock.

There has been an unanticipated lag in the establishment of halon banking and management programmes in Article 5 Parties globally. Halon banking operations can play a significant role in ensuring the quality and availability of recycled halon, in managing the halon use down to zero, and in assisting with emission data by providing regional estimates that should be more accurate than global estimates. National or regional banking schemes that maintain good records offer the opportunity to minimise the uncertainty in stored inventory and stock availability. Parties may wish to encourage such national halon banking schemes in order to ensure that needs considered critical by a Party are met.

Numerous Parties have not implemented halon bank management programmes or are experiencing significant challenges with their programmes. Some of the impediments include lack of a focal point for halon management, insufficient infrastructure, segmentation of halon users such as the military and industry with no sharing of information or resources, users’ lack of awareness regarding environmental concerns, and lack of supportive policies. There are companies available globally that will purchase and “clean” cross-contaminated halons; however, in some Parties, because of a prohibition on halon exports, cross-contaminated halons are a financial liability and are reported to be vented to the atmosphere.

E.6 Global Halon 2402 Banking

Halon 2402 had been produced nearly exclusively in the former USSR, and at the time of production phase-out the bank of halon 2402 was very small and insufficient to support existing applications. As a consequence, the Parties allowed the Russian Federation to continue to produce limited quantities of halon 2402 from 1996 until the end of 2000 under the essential use process.

The applications of halon 2402 are a special case because the equipment that uses it was almost exclusively manufactured in the former USSR until its dissolution and in the Russia Federation and the Ukraine afterwards. This equipment mainly comprises military equipment and civil aircraft that was sold within the former USSR, Eastern Europe, and South-East and East Asia.

The Russian Federation and Ukraine, traditionally recognised as potential sources of halon 2402 for other Parties, still own a large installed capacity of halon 2402, but their markets are estimated as currently well balanced with no surplus available for outside customers. This is a problem for Parties whose installed base is very small and consequently bank of halon 2402 limited. Some of these Parties have managed to establish recycling and banking facilities with assistance from the GEF. It is also a problem for larger users, e.g., India, who traditionally relied on supplies from the Russian Federation and never established their own bank. Where possible such Parties are switching to other halons or alternatives.

Emissions, transformation and consumption of halon 2402 by the Russian chemical industry as a process agent has substantially reduced the total bank of halon 2402, and new uses in non-traditional applications are a cause for concern to the HTOC. While there is no apparent shortage of recycled halon 2402 on a global basis, there are regional shortages today that Parties may wish to address.

E.7 Global/Regional Supply and Demand Balance

Based on a review of the situation in a large number of the Parties, with the exception of aviation, it has been concluded that generally halons have been replaced by substitutes for all new applications where halons were traditionally used. However, the demand for recycled halons remains high for existing applications in some Parties. Nevertheless, to date the Parties have not indicated to the Ozone Secretariat that they are unable to obtain halons to satisfy their needs, although some Parties have expressed cost concerns to HTOC members. The HTOC therefore concludes that current demand is being satisfied by the available supply, although the extent of continued needs indicates there may be global or regional problems in the future.

E.8 Continued Reliance on Halons

Halon production for fire protection purposes ceased at the end of 1993 in non-Article 5 Parties and at the end of 2009 in all Parties. However, many Parties have allowed recycled halons to be used to maintain and service existing equipment. This has permitted users to retain their initial equipment investment and allowed halons to continue to be used in applications where alternatives are not yet technically and/or economically viable. In particular, these include civil aviation, military uses, and legacy systems in oil and gas production in cold climates, aerosol fill rooms, grain silos, paper production and milk powder processing plants.

Aviation applications of halon are among the most demanding uses of all three halons, and require every one of their beneficial characteristics, including dispersion and suppression at low temperatures, minimal toxic hazards to passengers and flight crew, and ground maintenance staff, and low weight and space requirements for the hardware. While alternative methods of fire suppression for ground-based situations have been implemented, the status of halon in the civil aircraft sector must be viewed in three different contexts: existing aircraft, newly produced aircraft of existing models, and new models of aircraft. All of them continue to depend on halon for the majority of their fire protection applications. Given the anticipated 25–30 year lifespan of civil aircraft, this dependency is likely to continue well beyond the time when recycled halon is readily available, and the time available for making the transition to halon alternatives may be much less than many in the civil aviation industry realise.

Another critical development since the last assessment report is the finding of contaminated halons making their way into the civil aviation industry as reported by the UK Civil Aviation Authority (CAA) to the European Aviation Safety Agency (EASA) in 2009, raising concerns about the acceptability of the remaining banks of halons.

The halon alternatives available for mainline civil aviation are essentially the same as those reported in the 2006 HTOC Assessment, with the exception that a “low GWP” unsaturated HBFC, known as 3,3,3-trifluoro-2-bromo-prop-1-ene or 2-BTP is currently undergoing tests for suitability in hand-held extinguishers.

As a follow on from the HTOC’s work with the International Civil Aviation Organisation (ICAO) – reference Decision XXI/7 – the HTOC has continued its cooperation with ICAO in the development of a revised resolution, containing amended halon replacement dates agreed to by industry that was adopted at the ICAO 37th Assembly in September 2010 as Resolution A37/9. In addition to the ICAO halon replacement dates, the European Union introduced legislation in 2010 that has “cut-off dates” and “end dates” when all halon systems or extinguishers in a particular application – including civil aviation – must be decommissioned.

Halons continue to be used worldwide by military organisations in many frontline applications where alternatives are not technically or economically feasible at this time. These include existing systems in crew and engine compartments of armoured fighting vehicles; engine nacelles, auxiliary power units, portable extinguishers, cargo bays, dry bays, and the fuel tank vapour space of certain military aircraft; and machinery spaces, fuel pump rooms, flammable liquid storage rooms, operational rooms, command centres and on flight decks of certain naval vessels. Nevertheless, the militaries of many Parties have devoted considerable effort and resources to reduce and eventually eliminate the use of halons wherever technically and economically feasible. Extensive research, development and testing have all but eliminated the need for halons in new equipment designs in armoured fighting vehicles, military aircraft, and naval vessels. For applications where an acceptable alternative has not yet been implemented, operational and maintenance procedures and training can and have been improved to minimise emissions and conserve the limited supplies of recyclable materials that are available. Supplies of halons from converted and decommissioned systems and extinguishers, both from within military organisations and from the open market, have been banked by many Parties to support their on-going military needs.

Existing oil and gas pipelines and production facilities in inhospitable climates continue to use halons for fire suppression and explosion prevention. For new facilities, companies are now adopting an inherently safe design approach to avoid or minimise hazards such as the release of hydrocarbons. Where an inerting agent is still required in occupied spaces, halon has been replaced by HFC-23 or Fluoroketone (FK)-5-1-12, if temperatures permit, as part of the facility protection design. As HFC-23 is the only alternative where very low temperatures are encountered, the question mentioned in E.4 is relevant, i.e., should such a high GWP agent be diverted from destruction to replace an existing, recycled halon?

For other commercial/industrial applications, halons are no longer necessary and systems are gradually being decommissioned and replaced by systems agents using alternative agents. However, the cost to re-engineer systems to replace some legacy systems can be expensive and, in many cases, unless industry is mandated to do so, they rely on recycled halon from the halon bank to maintain the system.

In its 2006 Assessment, the HTOC detailed the status of the use of halon and their alternatives on board Merchant ships. Essentially the situation now is unchanged other than less ships are dependent upon halon owing to decommissioning of ships in the intervening period. For those remaining ships that still require halons, the industry appears to have concluded that this problem, if not solved, is certainly manageable for the near future.

E.9 Estimated Global Inventories of Halons 1211, 1301 and 2402

The HTOC 2010 Assessment indicates that at the end of 2010 the global bank of halon 1301 is estimated at approximately 42,500 MT, halon 1211 at approximately 65,000 MT and halon 2402 at approximately 2,300 MT. From this assessment, the HTOC remains of the opinion that adequate global stocks of halon 1211 and halon 1301 currently exist to meet the future needs of all existing halon fire equipment until the end of their useful life. However, there remains concern about the availability of halon 2402 outside of the Russian Federation and the Ukraine to support existing uses in aircraft, military vehicles, and ships. Much of the bank of halon 2402, which was intended to service fire protection needs for existing applications, was consumed within the Russian Federation as a process agent several years ago. In addition, a new product that encapsulates halon 2402 in a paint matrix is being commercialised in the Russian Federation that would further deplete supplies of halon 2402 to support existing uses. The HTOC is concerned that long-term, important users of halon 2402 will not have enough halon 2402 to support their needs if the bank continues to get depleted through use in non-fire protection uses and/or in new products.

Owners of existing halon fire equipment that would be considered as meeting the needs of one or more of the preceding categories would be prudent to ensure that their future needs will be met from their own secure stocks. Current and proposed regulatory programmes that require the recovery and destruction of halons will obviously eliminate future availability of halons as a source of supply for many needs. As adequate global supplies presently exist it would be unlikely that inadequate planning would serve as a reasonable basis for a future essential use nomination by a Party on behalf of an owner of a particularly important application for halons 1211, 1301 or halon 2402.

E.10 Practices to Ensure Recycled Halon Purity

The recent experience within Europe, where it was found that contaminated halons were making their way into the civil aviation industry, has highlighted the need for end users to be aware of the purity of any reclaimed or recycled halon that they purchase. With an impure halon the performance can range from poor or no fire extinguishing effectiveness to one where the impure agent may actually intensify the fire in the case where the impurity is a flammable material. Generally speaking, end users have to rely on the aftermarket supply chain to collect, process, test and certify that the halon agent is of acceptable purity, and it is this last step, relying on a supplier’s certification alone that can introduce risk with respect to agent purity. Thus it is important that a written purity certification is obtained from an internationally or nationally recognised testing laboratory that has tested the halon to internationally recognised standards, such as ISO, ASTM or GOST.

E.11 Halon Emission Reduction Strategies

Releasing halon into the atmosphere is fundamental to the process of flame extinction and enclosed space inertion. However, these necessary emissions only use a small proportion of the available supply of halon in any year. Most countries have discontinued system discharge testing and discharge of extinguishers for training purposes resulting in emission reductions in some cases of up to 90%. Additional and significant reductions of halon emissions can be realised by improving maintenance procedures, detection and control devices, etc., and through non-technical steps such as the development of Codes of Conduct, implementing Awareness Campaigns, workshops, and training, policies, and legislating regulations and ensuring enforcement. Halon emissions reduction strategies are a combination of “responsible use” and political regulatory action.

Good engineering practice dictates that, where possible, hazards should be designed out of facilities rather than simply providing protection against them. A combination of prevention, inherently safe design, minimisation of personnel exposure, passive protection, equipment duplication, detection, and manual intervention should be considered as well. Also, attention to maintenance programs and personnel training can add years to a halon bank by reduced emissions.

Emission reductions can be achieved by implementing a comprehensive Awareness Campaign. This should address a description of halons and their uses, environmental concerns related to the ozone layer, key goals and deadlines in the Montreal Protocol, country-specific policy and regulations on ODS, recycling requirements, alternatives and options, points of contact in government and fire protection community, and answers to Frequently Asked Questions such as “what do I do with my halon 1211 extinguisher?”

Avoidable halon releases account for greater halon emissions than those needed for fire protection and explosion prevention. Clearly such releases can be minimised.

E.12 Destruction

Since the 2006 Assessment, considerable interest has focused on the potential ozone and climate benefits from the avoided emissions of ODS still remaining in equipment, products, and stockpiles. The recent introduction of carbon credits for ODS destruction creates a limited window of opportunity to increase ODS recovery at equipment end of life and to avoid potential emissions altogether by destroying unwanted material. Halons, more than some of the other ODS, are readily accessible for collection, storage, and disposal, making them very attractive for potential ODS destruction projects under a carbon credit protocol. However, owing to the continued global demand for halons in applications such as aviation, the HTOC has recommended that destruction as a final disposition option should be considered only if the halons are cross-contaminated and cannot be reclaimed to an acceptable purity. The global phase-out of halons has been planned based upon halons being reclaimed and reused until the end of the useful life of the systems they are employed in and until there are no longer any important uses. Early destruction of halons undermines the long-range plan set by the Parties, imposes significant financial burdens on users who invested in their halon systems, and puts at risk uses that generally have the potential for preventing significant loss of life in a fire scenario.

There are also concerns that the availability of carbon credits for halon destruction may inadvertently lead to the wrong incentives – to actions that actually lead to more environmental harm and, worse, to potentially illegal activities, e.g., production simply for destruction credits since newly produced halon is technically indistinguishable from recycled halon. The Parties may wish to consider asking TEAP/HTOC to investigate the issues related to halon destruction further in order to better understand the full implications to the halon phase out under the Protocol, and the impacts to ozone layer recovery and climate protection.

Click here to download a PDF of the full Assessment.

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