July 18, 2013
To: Invitees, Attendees of the Subject meeting, and others Interested
From: George E. Laverick
Subject: Report of the Meeting to Discuss the Withdrawal of CAN/ULC S512 and the Plan to Cease Listing of Halon Extinguishers
This is to report on the subject meeting which was held at the ULC Office in Toronto, Ontario and online on July 17, 2013. A copy of the meeting agenda is attached as Appendix A.
Those in attendance are shown in Appendix B. Representatives from the US Government agencies did not attend.
To bring the group to the present status, the history of this issue was reviewed which included the Montreal Protocol, the Bi-national harmonization of fire extinguisher standards that did not include Halon extinguishers, the withdrawal of UL 1093, the anticipated dates to discontinue UL Listing of Halon extinguishers, and the proposal to withdraw CAN/ULC S512.
Status of the Proposal to Withdraw of ULC S512
Mark Ramlochan updated the group of the status of the current proposal that began during the initial ballot that was circulated 1/14/13 and closed on 4/4/13. Consensus has been achieved to withdraw, however the negative ballots and comments need to be addressed and the responses circulated.
UL indicated the reasons for withdrawal, including the disparity of Class A wood crib fire test requirements between Halon extinguishers and all other extinguishers having Class A Fire ratings and the limitations for discharging Halon extinguishers during routine production testing.
Plan to discontinue Listing of Halon extinguishers
The current status for UL to discontinue UL Listing of Halon extinguishers in October 2014 was discussed. It was also indicated that the plan to discontinue ULC Listing of Halon extinguishers was also proposed to be October 2014.
Extension of Date to Discontinue Listing of Halon Extinguishers
Discussion of the date to discontinue Listing of Halon extinguishers resulted in generating a list of reasons why the October 2014 date should be extended. They included:
1) Abundance of Halon 1211;
2) Extensive recycling of Halon 1211;
3) Current use of Halon extinguishers is not adaptable to other extinguishing agents at this time;
4) Limited serviceability and the need to replace the extinguisher with a like extinguisher, specifically on aircraft;
5) Current aircraft life of 30 years, wherein Halon extinguishers need to be routinely replaced;
6) Few extinguishers are effected by the disparity of the Class A rating, and;
7) Routine production testing disparity of not discharging extinguishers may be able to be resolved with the extinguisher manufacturers.
Extended dates discussed included December 31, 2016, which coincides with the current date to cease installation of Halon extinguishers on aircraft by the International Civil Aviation Organization (ICAO). It was indicated that this date may not be practical since the ICAO requirements only cover new production aircraft and do not impact the continued use of Halon extinguishers on the existing aircraft.
The European Union has proposed a date to cease installation which includes the retrofit of all Halon extinguishers on aircraft by 2025.
Alternate solutions were discussed including other current extinguishing agents, new “drop-in” replacement agents, and limited application for Listing Halon 1211 extinguishers. Drop-in replacements are currently not ready for use in extinguishers, since the toxicity studies required by the US EPA and REACH registration for this extinguishing agent have not been completed. Further development work with this agent is pending results of these studies.
Straw Poll of Attendees
During a summary of the discussions at the conclusion of the meeting, a poll was requested to obtain the sense of the group. Three items were polled as follows and UL representatives did not voice an opinion:
1) Those in favor of delaying the withdrawal of all Listings of Halon extinguishers to 2025; all were in favor, since it was not an option to delay withdrawal indefinitely.
2) Those in favor of withdrawing S512 assuming the date to cease production was extended to December 31, 2016 and assuming UL would not agree to the 2025 withdrawal date; all were in favor.
3) Those in favor of limiting the Listing of Halon extinguishers to replacing extinguishers in existing applications, i.e. replacement of extinguishers on aircraft; no support.
It was stated that UL would consider the information and input discussed at this meeting to determine further action on the withdrawal of the Standard S512 and consider extending the date to discontinue Listing of Halon extinguishers.
Extinguisher manufacturers indicated willingness to the following, if the date to discontinue production was extended:
1) Propose a modification to the routine production testing to address the disparity issue for discharging Halon extinguishers and to confirm proper extinguisher operation and;
2) Analyze the data on the Class A rating and adjust the rating to accommodate the new requirements.
Meeting to Discuss the Withdrawal of the Standard for Halogen Agent Hand and Wheeled Extinguishers, CAN/ULC S512 and Continued UL and ULC Listings of Halon Portable Fire Extinguishers
Date: Wednesday, July 17, 2013
Time: 9:00 – 3:00 PM
Place: TRT Ottawa Room; TRT Vancouver Room ULC Toronto, Ontario, Canada
Objective: Gathering additional information and input from stakeholders to assist UL in determining the appropriate action for the withdrawal of the Standard for Halogen Agent Hand and Wheeled Extinguishers (CAN/ULC S512) and the plan to discontinue the UL LLC Listing of Halon extinguishers.
I. Call to Order- G. Laverick
II. Introduction of attendees- All
III. Review of objective – UL/ ULC
IV. Discussion of the withdrawal of CAN/ULC S512
a. Status of proposal to withdraw- UL/ULC
i. Initial ballot circulated 1/14/13
ii. Closing date for comments 3/29
iii. Ballot closing date 4/4
iv. Indicated consensus was achieved to withdraw S512
b. Considered action by UL- UL/ULC
i. Proceed to withdraw
c. Other options- All
V. Discussion of the plan to discontinue Listing of Halon extinguishers
a. UL’s current date to cease Listing UL/ULC
i. ULC’s proposal was to withdraw S512 and follow UL’s time for discontinue Listing of Halon extinguishers.
b. ULC Listings of Halon Extinguishers- UL/ULC
i. UL’s current withdrawal date is October 2014.
c. Other options –All
VI. Other relevant topics – All
VII. Adjourn, by 3 PM
Name – Affiliation
George Laverick – UL LLC (Chair)
Martin Gravel – Canada Department of Defense
Chris Dieter – H3R Aviation
Tom Cortina – HRC
Joe diFilippo – Kidde Canada
Ian Shearer – Strike First Corp.
Mike Madden – Boeing
Mark Ramlochan – ULC
Sandi Moser – Environment Canada
Alex Famira – CASP Aerospace
Kevin Hartwig – Gulfstream
Fred Goodnight – Amerex