Significant New Alternatives Policy Program

Fire Extinguishing and Explosion Prevention Sector

Risk Screen on Substitutes for Halon 1211 in Portable Fire Extinguishers

Substitute: Firebane® 1170 and Firebane® 1179

This risk screen does not contain Clean Air Act (CAA) Confidential
Business Information (CBI) and, therefore, may be disclosed to the
public.



Introduction

Ozone-depleting substances (ODS) are being phased out of production in
response to a series of diplomatic and legislative efforts that have
taken place over the past two decades, including the Montreal Protocol
and the Clean Air Act Amendments of 1990 (CAAA).  The U.S. Environmental
Protection Agency (EPA), as authorized by Section 612 of the CAAA,
administers the Significant New Alternatives Policy (SNAP) Program,
which identifies acceptable and unacceptable substitutes for ODS in
specific end-uses based on assessment of their health and environmental
impacts.

EPA’s decision on the acceptability of a substitute is based largely
on the findings of a screening assessment of potential human health and
environmental risks posed by the substitute in specific applications. 
EPA has already screened a large number of substitutes in many end-use
applications within all of the major ODS-using sectors, including
refrigeration and air conditioning, solvent cleaning, foam blowing,
aerosols, fire suppression, adhesives, coatings and inks, and
sterilization. The results of these risk screens are presented in a
series of Background Documents that are available in EPA's docket.

The purpose of this risk screen is to supplement EPA’s Background
Document on the fire suppression and explosion protection sector (EPA
1994) (hereinafter referred to as the Background Document). This risk
screen discusses the potential human health and environmental risks
posed by Firebane® 1170 or Firebane® 1179 when used as a streaming
agent in portable fire extinguishers as a replacement for Halon 1211.
The reader is referred to the Background Document for the methodologies
and assumptions used to conduct this risk screen. Table 1 presents the
composition of the proposed substitutes. 

Table   SEQ Table \* ARABIC  1 : Composition of Firebane® 1170 and
Firebane® 1179

Constituent	Chemical Formulaa	CAS No.	Formulation (by Weight Percent)



	Firebane® 1170	Firebane® 1179





a N/A = not available.

Because the formulations of Firebane® 1170 and Firebane® 1179 are very
similar and share the same human health and environmental risks, the
remaining sections of this risk screen address both  Firebane® 1170 and
Firebane® 1179  (hereinafter collectively referred to as “both
Firebane formulations”).

Section 2 of this risk screen summarizes the results of the risk screen
for the proposed substitutes listed in Table 1.  The remainder of the
risk screen is organized into the following sections:

Section 3: Atmospheric Assessment; 

Section 4: Occupational Exposure Assessment; 

Section 5: End-Use Exposure Assessment; 

Section 6: General Population Exposure Assessment; 

Section 7: Volatile Organic Compound Assessment; and

Section 8: References.

Summary of Results

Both formulations of Firebane® are recommended for SNAP approval as
streaming agents in portable fire extinguishers.  However, adequate
ventilation should be in place, appropriate personal protective
equipment (PPE) should be worn, and proper training administered for the
manufacture, use, and disposal of this product. PPE should include
safety goggles and protective gloves. Additionally, the risk screen
indicates that the use of the proposed substitutes will be less harmful
to the atmosphere than the continued use of Halon 1211.  Risk to the
general population is expected to be negligible provided that proper
disposal procedures are used, and occupational exposure should not pose
a problem if PPE is used. For applications of this and all other
portable fire extinguishers, ICF recommends that the latest edition of
National Fire Protection Agency (NFPA) Standard 10 be followed. 

Atmospheric Assessment

This section presents an assessment of the potential risks to
atmospheric integrity posed by the use of both Firebane® formulations
as streaming agents.  According to the submitter, both Firebane®
formulations contain no Class I or Class II ODS, nor any compounds with
measured global warming potential (GWP). Therefore, the use of
Firebane® 1170 and Firebane® 1179 will be less damaging to the
atmosphere than continued use of Halon 1211.

Occupational Exposure Assessment 

The potential for personnel exposure during manufacture, installation,
and maintenance are examined in this section.  The discharge scenarios
discussed are assumed to occur accidentally and not as the result of a
fire.  In order to evaluate occupational exposure, ICF has evaluated the
active compounds contained in both Firebane® formulations.  The common
application types, FDA approval status, and associated hazards for these
compounds are presented in   REF _Ref291689835 \h  \* MERGEFORMAT  Table
2 . 

Table   SEQ Table \* ARABIC  2 : Common Applications Types and FDA
Approval Status of Firebane® 1170 and Firebane® 1179 Constituents

Constituent	Common Application Types	FDA Approval Statusa,b,c	Associated
Hazards





a FDA = U.S. Food and Drug Administration

b FDA approvals are subject to use restrictions. Please see the cited
regulation for further information.

c GRAS = Generally Recognized as Safe

Occupational Exposure during Manufacture

Both formulations of Firebane® are not expected to pose a risk to
workers during manufacture. Based on the information provided in the
SNAP submission, occupational exposures during manufacture of both
Firebane® formulations are expected to be limited to mixing of the
chemicals and filling of extinguishers. As summarized in the table
above, all the constituents exhibit low toxicity and are commonly used
in food applications. In addition, exposure to either of the Firebane®
formulations is expected to be in the liquid form, with any vapor or gas
exposures considered to be negligible (GSL 2011c and GSL 2010). The risk
of exposure will be further minimized by following safety and
precautionary measures. For measures designed to minimize the hazards
associated with a specific constituent, as noted in Table 2, the
constituent’s MSDS should be referenced. In order to minimize the risk
associated with all of the constituents of either Firebane®
formulation, EPA recommends the following in accordance with general
procedures prescribed in the MSDS of the proposed substitutes and by the
submitter:

Proper Level D or higher PPE be used during handling of the substitute
(e.g., goggles, gloves);

Adequate ventilation should be in place;

All spills should be cleaned up immediately in accordance with good
industrial hygiene practices; and

Training for safe handling procedures should be provided to all
employees that would be likely to handle containers of or extinguishing
units filled with Firebane® 1170 or Firebane® 1179.

Because of the minimal chance of worker exposure to the chemicals during
the manufacturing process, the use of exposure controls and adherence to
the appropriate occupational safety guidelines as mentioned above, are
sufficient to ensure that the manufacture of both formulations of
Firebane® does not pose a risk to human health. In addition, an
automated system for charging the extinguishers, as proposed by the
submitter, would further reduce the risk of occupational exposure during
manufacture to both formulations of Firebane® (GSL 2011a and 2011b).

Occupational Exposure during Installation and Maintenance

Both Firebane® formulations are not expected to pose a significant risk
to personnel during installation and maintenance activities. During the
installation or maintenance of either of the Firebane® formulations,
inadvertent discharge may occur.  Oxygen displacement during discharge
of either Firebane® formulation is considered to be negligible, and
therefore not a concern during inadvertent discharge (GSL 2011a and GSL
2011b). In addition, as noted above, all the constituents exhibit low
toxicity and are commonly used in food applications.  To ensure that the
potential for exposure during installation and maintenance are further
minimized, it is recommended that all personnel involved in the
installation and maintenance of either of the Firebane® formulations
adhere to safety guidelines, as mentioned previously in Section   REF
_Ref292194109 \r \h  \* MERGEFORMAT  4.1 .  It is recommended that the
safe handling training also focus on the prevention of an inadvertent
discharge.  In case of an inadvertent discharge, workers should
immediately follow the instructions listed in the MSDS for Firebane®
1170 or Firebane® 1179.  

End-Use Exposure Assessment

Both formulations of Firebane® are not expected to pose significant
risk to end-users when used as streaming agents in portable fire
extinguishers. The primary health concern for both Firebane®
formulations at the end-use is exposure to the post-activation discharge
products. Both formulations of Firebane® are stored as aqueous
solutions that become gases upon introduction to fire (GSL 2011c and GSL
2010).  Inhalation of the Firebane® 1170 or Firebane® 1179 gas vapors
may cause mild irritation to the upper respiratory track; chronic
ingestion will cause gastrointestinal irritation; and eye exposure may
cause mild irritation (GSL 2011c and GSL 2010). In case of exposure,
individuals should follow the instructions prescribed in the proposed
substitutes’ MSDS. To minimize risk of exposure and irritation, EPA
recommends that individuals follow the precautionary measures described
in Section   REF _Ref292194109 \r \h  \* MERGEFORMAT  4.1 .

General Population Exposure Assessment

This section screens potential risks to the general population from
exposure to ambient air releases of both Firebane® formulations and its
constituents.  Firebane® 1170 and Firebane® 1179 are not expected to
cause a significant threat to human health in the general population
when used as streaming agents in portable fire extinguishers. The only
consumer exposure to either Firebane® formulation will be during
discharge of fire extinguishers in occupied spaces.  Firefighters and
other end-users exposed to either Firebane® formulation during release
should wear appropriate PPE, including goggles and gloves.  Individuals
should follow the precautionary measures described in the proposed
substitutes’ MSDS and Section 4.1 of this risk screen.  When the
recommended safety precautions are followed, no significant adverse
health effects are expected. 

6.1. 	Ambient Air

Firebane® 1170 and Firebane® 1179 are not expected to pose a
significant threat to human health in the general population in ambient
air concentrations. As noted previously, both Firebane® formulations
are composed entirely of compounds that are FDA-approved for use in
food, of which some are also FDA-classified as GRAS. Therefore, both
Firebane® formulations are not expected to be a safety concern for
ambient air contamination. 

6.2.  	Surface Water

Both Firebane® formulations are not expected to pose a significant
threat to human health or the environment, provided that proper disposal
procedures are followed. As discussed in the Background Document, the
physicochemical properties of the majority of halon substitutes make it
unlikely that the substitutes would be released to surface water as a
result of use. In the case of both Firebane® formulations, it is
expected that all of the constituents would rapidly aerosolize during
expulsion from the container and then settle as a liquid film on
surfaces (as opposed to becoming airborne and settling on a nearby
stream). After settling, cleanup would involve washing/rinsing of
surfaces. Because of the high biological oxygen demand (BOD) associated
with each Firebane® formulation, it is recommended that discharges of
either Firebane® formulation not be released to waterways. Further, it
is recommended that during cleanup, discharges of both Firebane®
formulations be collected (e.g., mopped) and contained in sealed
containers and then disposed of in accordance with local, state, and
federal requirements.  Training for safe disposal procedures should also
be provided to all employees that would be likely to dispose of either
Firebane® formulation at cleanup. In addition, the use of an
extinguisher is expected to be infrequent (i.e., in case of a fire
emergency), and therefore discharges would be infrequent—with proper
procedures for cleanup in place, there is a very limited cause for
concern.  Therefore, EPA believes that when the recommended disposal
procedures are followed, both Firebane® formulations do not pose a
significant threat to human health or the environment during end-use or
at cleanup. 

Discharges of either Firebane® formulation at manufacture to publicly
owned treatment works (POTWs) are subject to local, state, and federal
restrictions. Such restrictions include a limit on the BOD levels of
industrial wastewater. EPA believes that regulatory requirements on
discharges that result from manufacture are sufficient to control human
health and environmental risks associated with the manufacturing
operations of both Firebane® formulations. 

6.3. 	Solid Waste

No constituents of Firebane® 1179 are considered to be hazardous waste
under EPA regulations implementing the Resource Conservation and
Recovery Act.  During post-activation cleanup procedures, cleanup
residues should be disposed of in accordance with requirements
appropriate for those materials. 

Volatile Organic Compound Analysis

Of the constituents of both Firebane® formulations, only propylene
glycol has not been exempted as a volatile organic compound (VOC) under
the CAA (40 CFR 51.000). However, some states also have regulations
concerning exempted VOCs and the definition of a VOC, which could
exclude propylene glycol from consideration as a VOC. In general, VOC
emissions should be sufficiently controlled through regulations and
standard industry practices. VOC emissions from the production of
portable extinguishers charged with Firebane® 1170 or Firebane® 1179
are controlled through standard industry practices, and as such,
emissions from manufacture of units are likely to be minimal.  Using
release estimates from the Vintaging Model, the annual release rate
(including discharge, leak, and training release rates) for portable
extinguishers was calculated to be approximately 3.5% of extinguisher
charge size.  Assuming this release rate, an assessment was performed to
compare the annual VOC emissions from use of Firebane® 1170 and
Firebane® All-Weather 1179 in portable extinguishers produced in one
year to other anthropogenic sources of VOC emissions.  Assuming the
submitter’s current production plans, the amount of VOCs that would be
emitted would be approximately equal to 1.5x10-5 percent of the annual
VOC emissions caused by fires, or only about 5.6x10-7 percent of all
annual anthropogenic VOC emissions.   Moreover, even if all of the
Firebane® 1170 and Firebane® 1179 produced by Global Safety Labs in
one year were to be released to the atmosphere over the course of the
year (extremely unlikely), the resulting annual VOC emissions would be
approximately 4.4x10-4 percent of annual VOC emissions caused by fires,
or only about 1.6x10-5 percent of all annual anthropogenic VOC
emissions. As these emissions of Firebane® are several orders of
magnitude less than other anthropogenic emissions, the environmental
impacts of these VOCs are not considered a threat. 

References					

EPA 1994. "Risk Screen on the Use of Substitutes for Class I
Ozone-depleting Substances:  Fire Extinguishing and Protection (Halon
Substitutes)," U.S. Environmental Protection Agency, March 1994.

EPA 2008. 2005 National Emissions Inventory Data & Documentation.
Inventory Data: 42 Category Summaries. Last updated 6 July 2010.
Accessed 20 September 11. Available online at
<http://www.epa.gov/ttn/chief/net/2005inventory.html#inventorydata>.

EPA 2009.  National Emissions Inventory (NEI) Air Pollutant Emissions
Trends Data and Estimation Procedures.1970 – 2008 Average Annual
Emissions, All Criteria Pollutants.  Last updated 09 June 2009. Accessed
20 September 11. Available online at
<http://www.epa.gov/ttn/chief/trends/index.html#tables>. 

EPA 2011. The National Emissions Inventory. 2008 National Inventory
Data. Last updated 19 July 11. Accessed 20 September 11. Available
online at <http://www.epa.gov/ttn/chief/net/2008inventory.html>.

Global Safety Labs, Inc. 2011a. “Response to Incomplete SNAP
Submission for Firebane® 1170.” April 4, 2011.

Global Safety Labs, Inc. 2011b. “Response to Incomplete SNAP
Submission for Firebane® 1179.” April 4, 2011.

Global Safety Labs, Inc. 2011c.  SNAP Submission to EPA for Firebane®
1170.  February 7, 2011.

Global Safety Labs, Inc. 2010.  SNAP Submission to EPA for Firebane®
1179.  December 23, 2010.

NFPA. 2010.  NFPA 10: Standard for Portable Fire Extinguishers.  2010
Edition.  Available at
<http://www.nfpa.org/catalog/product.asp?pid=1010&order%5Fsrc=B484>

	

 BOD is the amount of oxygen consumed by microorganisms as they
decompose organic materials in water. 

 POTWs establish BOD limits in order to prevent overloading of the water
treatment system, which could potentially cause the organism-based
treatment system to fail if oxygen levels become too low for aerobic
respiration.

 The total annual release rate of 3.5% for portable extinguishers was
determined using the average annual leak rate (2%), annual discharge
rate (1.5%), and annual release during training (0%) from the Vintaging
Model (v4.4_3.23.11). 

 Based on 2010 projections calculated using 2008 EPA annual VOC
emissions data for residential wood burning and agricultural field
burning (EPA 2008 and EPA 2011) and ICF assumptions.

 Based on 2010 projections calculated using 2008 EPA annual VOC
emissions data (EPA 2009) and ICF assumptions.

  DATE \@ "MMMM d, yyyy"  September 27, 2011 

 PAGE  1 

