FSSA Encourages Member Companies to Review, Comment on EPA’s Proposed Changes on SNAP

June 16 Deadline

The Environmental Protection Agency (EPA) chose to extend the public comment period by two additional weeks for its proposed rule (81 FR 22810; Apr. 18, 2016) that would list new alternatives under the Significant New Alternatives Policy (SNAP) program and change the current SNAP status of other alternatives. The public comment period will now close on Jun. 16, 2016 versus the original close date of Jun. 2, 2016. This two-week extension will provide the public, which includes our member companies, to review and comment on all of the information available, including the proposed rule and other materials in the docket.

The EPA’s proposed rule addresses several sectors that impact the fire suppression systems industry, including refrigeration, air conditioning, foam blowing and fire protection.

In addition to the Pre-Publication Version of the Proposed Rule, which may be accessed here, a summary fact sheet from the EPA may also be viewed here.

With respect to fire protection applications:

• The proposed rule would accept a new agent 2-BTP for total flood fire extinguishing in engine nacelles and APU on aircraft and as a streaming agent for hand held extinguishing on aircraft. (Discussion of 2-BTP begins on Page 246. The discussion leads one through the process EPA uses in assessing the SNAP listing of substances.)
• The proposed rule would change the SNAP status of perfluorocarbons (PFC-410 and PFC-218) to unacceptable as of one year after publication of the rule. (Discussion begins on page 261.)
• On Page 268 the EPA states “EPA is also interested in advance comments on whether to take similar action with respect to certain additional fire suppression agents. Specifically, EPA requests advance comments and updated information on total flooding uses of SF6, HFC-23, and HFC-125, and on both total flooding and streaming uses of HFC-227ea.”

After reviewing the proposed rules, the FSSA submitted a letter, which you download here, to the EPA in regard the proposed rule. We are encouraging all of our member companies that could be impacted by this proposed rule to submit their remarks before the public comment period comes to a close on Jun. 16, 2016.

Fire Suppression Systems Association
3601 East Joppa Road | Baltimore, Maryland 21234
Phone: (410) 931-8100 | Fax: (410) 931-8111
Website: www.fssa.net