CLEAN AGENT UPDATE
Public Law 112-81 (HR 1540)
Effects on Halotron I
• Extends the time for new production of HCFC-123 for fire protection by five (5) years through January 1, 2020, as long as the Halotron™ I clean agent remains listed as acceptable under the EPA SNAP program, which has been the case since 1994.
• Confirms that the use of the Halotron™ I clean agent as a halon 1211 substitute is not restricted as long as the agent remains listed as acceptable under the EPA SNAP program. This change recognizes that for specific applications (such as, but not limited to, flight line protection and high-performance, wheeled fire extinguishers) there is no in-kind clean agent replacement for the Halotron™ I clean agent that has the same demonstrated effectiveness and reliability and that the continued use of the agent has minimal environmental impact.
The Halotron™ I Clean Fire Extinguishing Agent is based on HCFC-123 (2,2-dichloro-1,1,1-trifluoroethane). HCFC123 has a very low Ozone Depletion Potential (ODP) close to zero (0.0098, where CFC-11=1.0). Halotron™ I (referred to as “HCFC Blend B”) was first listed as acceptable by the US EPA as a halon 1211 substitute under its Significant New Alternatives Policy (SNAP) program in March 1994. The SNAP program, which is updated regularly, is EPA’s approach for screening CFC and halon substitutes as required under section 612 of the Clean Air Act Amendments of 1990.
House Resolution (HR) 1540 became a Public Law on December 31, 2011, when it was signed by President Obama. Section 320 of this new law affects the production of new hydrochlorofluorocarbon (HCFC) based agents to substitute for halons (Class I Ozone Depleting Substances) in fire protection and it also clarifies uncertainties in the interpretation of Section 605 of the Clean Air Act Amendments of 1990. The text of Section 320, Fire Suppression Agents, amends Section 605(a) of the Clean Air Act (42 U.S.C. 7671d(a)) as follows:
§7671d. Phase-out of production and consumption of class II substances
(a)Restriction of use of class II substances
Effective January 1, 2015, it shall be unlawful for any person to introduce into interstate commerce or use any class II substance unless such substance—
(1)has been used, recovered, and recycled;
(2)is used and entirely consumed (except for trace quantities) in the production of other chemicals;
(3)is used as a refrigerant in appliances manufactured prior to January 1, 2020; or
(4)is listed as acceptable for use as a fire suppression agent for nonresidential applications in accordance with section 612(c).
It is expected that recycled quantities of HCFC-123 will be used to continue production of new Halotron™ I for servicing and new fire extinguishers after January 1, 2020.
American Pacific Corporation
3883 Howard Hughes Parkway, Suite 700
Las Vegas, NV 89169
February 2012, Rev. B