Significant New Alternatives Policy Program

Fire Extinguishing and Explosion Prevention Sector

Risk Screen on Substitutes for Halon 1211 in Portable Fire Extinguishers

Substitute: Firebane® All-Weather 1115 and Firebane® 1115

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 few years, 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® All-Weather 1115 or Firebane® 1115 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 the risk screen. Table 1
presents the composition of the proposed substitutes. 

Table 1.  Composition of Firebane® All-Weather 1115 and Firebane® 1115
 

Constituent	Chemical Formula	CAS No.	Formulation

(by Weight Percent)



	Firebane® 1115	Firebane® All-Weather 1115











Because the formulations of Firebane® All-Weather 1115 and Firebane®
1115 are very similar and share the same human health and environmental
risks, the remaining sections of this risk screen address both 
Firebane® All-Weather 1115 and Firebane® 1115  (hereinafter
collectively referred to as “both Firebane® 1115 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 Firebane® 1115 formulations are recommended for SNAP approval as
streaming agents in portable fire extinguishers.  However, the
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, 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 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® 1115
formulations as streaming agents.  According to the applicant, both
Firebane® 1115 formulations contain no Class I or Class II ozone
depleting substances, nor any compounds with measured global warming
potential (GWP). Therefore, the use of Firebane® 1115 and Firebane®
All-Weather 1115 will be less damaging to the atmosphere than the
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® 1115 formulations.  The
common application types, U.S. Food and Drug Administration (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® 1115 and Firebane® All-Weather 1115
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® 1115 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® 1115 formulations are expected to be limited to the following
activities: mixing of the chemicals, filling of extinguishers, and
maintenance of extinguishers. According to the submitter, exposure to
both Firebane® 1115 formulation is expected to be in the liquid form,
with any vapor or gas exposures considered to be negligible. Workers
that may be exposed to any chemicals during manufacture or an accidental
release or spill are recommended to take precautionary measures as
listed below to minimize risk. In accordance with general procedures
prescribed in the MSDS of the proposed substitutes and by the submitter,
EPA recommends the following:

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® 1115 or Firebane® All-Weather 1115.

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 Firebane® 1115 and
Firebane® All-Weather 1115 does not pose a risk to human health.

Occupational Exposure during Installation and Maintenance

Both Firebane® 1115 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® 1115
formulations, inadvertent discharge may occur.  Oxygen displacement
during discharge of either Firebane® 1115 formulation is considered to
be negligible, and therefore not a concern during inadvertent discharge.
In addition, as noted above, all constituents exhibit low toxicity and
are commonly used in food or cosmetics 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® 1115
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® 1115 and Firebane® All-Weather 1115. 

End-Use Exposure Assessment

In order to evaluate exposure at end use, ICF has evaluated the four
active compounds contained in Firebane® 1115 or for Firebane®
All-Weather 1115. The majority of Firebane ® 1115 is composed of GRAS
compounds, and the remaining constituents are FDA-approved for use as a
direct and/or indirect food additive. These compounds are commonly used
in food, pharmaceutical, and/or cosmetic applications. Individual
constituents may cause gastrointestinal discomfort (if excessively
ingested), eye irritation, skin irritation, and/or respiratory tract
irritation. 

General Population Exposure Assessment

This section screens potential risks to the general population from
exposure to both formulations of Firebane® 1115 and its constituents to
ambient air, surface water, and solid waste.  Firebane® 1115 and
Firebane® All-Weather 1115 are not expected to cause a significant
threat to human health in the general population when used as a
streaming agent in portable fire extinguishers. The only consumer
exposure to either Firebane® 1115 formulation will be during discharge
of fire extinguishers in occupied spaces.   Firefighters and other
end-users exposed to Firebane® 1115 or Firebane® All-Weather 1115
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. 

Ambient Air

Firebane® 1115 and Firebane® All-Weather 1115 are not expected to pose
a significant threat to human health in the general population in the
ambient air concentrations. As noted previously, both Firebane® 1115
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® 1115 formulations are not expected to be a
safety concern for ambient air contamination.

Surface Water

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® 1115 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. After settling,
cleanup would involve washing/rinsing of surfaces and there would be no
restrictions on discharge to publicly owned treatment works (POTW) based
on the GRAS nature of the majority of the constituents of both
Firebane® 1115 formulations.  Further, based on information from the
submitter, the proposed substitutes are readily biodegradable and have
exceptionally low biological oxygen demands and chemical oxygen demands.
Based on these considerations, it is expected that the proposed
substitutes would not contribute to surface water contamination. 

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 clean-up procedures, clean-up
residues should be disposed of in accordance with requirements
appropriate for those materials. 

Volatile Organic Compound Assessment

Of the constituents of both Firebane 1115®formulations, only one 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 this
constituent 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® 1115 or Firebane® All-Weather
1115 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® 1115 and
Firebane® All-Weather 1115 in portable extinguisher 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 2.5x10-5 percent of the annual
VOC emissions caused by fires, or only about 9.1x10-7 percent of all
annual anthropogenic sources.   Moreover, even if all the Firebane®
1115 and Firebane® 1115 All-Weather 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 7.2x10-4 percent of annual VOC emissions caused by fires,
or 2.6x10-5 percent of all annual anthropogenic VOC emissions. As these
emissions 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. 2010a.  “Request for information on a typical
compartment size in a protected vehicle and an estimated rate of
airflow.”  February 9, 2010.	

Global Safety Labs, Inc. 2010b. “Response to Incomplete SNAP
Submission for Arctic-Firefreeze™ All-Weather 1115.” December 22,
2009.

Global Safety Labs, Inc. 2010c.  “SNAP Submission to EPA for
Arctic-Firefreeze™ All-Weather 1115.”  November 2, 2009.	

Global Safety Labs, Inc. 2010d.  “Request to Include a Formula
Modification Under Current SNAP Preliminary Acceptability Determination
for Arctic Fire-Freeze™ All-Weather 1115.”  June 15, 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>

 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). 

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

September 23, 2011

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September 23, 2011

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