Significant New Alternatives Policy Program

Fire Extinguishing and Explosion Prevention Sector

Risk Screen on Substitutes for Halon 1301

Total Flooding Systems in Normally Occupied or Unoccupied Spaces

Substitute: 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® 1179 when used as a flooding agent in normally
occupied or unoccupied spaces as a replacement for Halon 1301. The
reader is referred to the Background Document for the methodologies and
assumptions used to conduct this risk screen. 

 Firebane® 1179 is designed for use in an Advanced Automatic Fire
Extinguishing System (AFES), with primary use for fire protection in
military ground vehicles. AFES discharges into the vehicle in two
phases, which together extinguish any residual fires and reduce the
chance of fires from re-flash due to hot surfaces or the presence of
molten metals (GSL 2011d).

Phase 2 of AFES is not under the jurisdiction of SNAP, and is not
addressed in this risk screen. However, the potential for Phase 2
discharge to increase total exposure concentrations at end-use is
considered (see Section   REF _Ref299103438 \r \h  5 ). 

Table 1 presents the composition of the proposed substitute.

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

Constituent	Chemical Formulaa	CAS No.	Weight Percent





a N/A = not available.

Section 2 of this risk screen summarizes the results of the risk screen
for the proposed substitute.  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

Firebane® 1179 is recommended for SNAP approval as a flooding agent in
normally occupied and unoccupied spaces.  However, adequate ventilation
should be in place, appropriate personal protective equipment (PPE)
should be worn, and proper training administered for the manufacture and
disposal of this product. PPE should include safety goggles and
protective gloves. Additionally, the risk screen indicates that the use
of the proposed substitute will be less harmful to the atmosphere than
the continued use of Halon 1301.  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. 

Atmospheric Assessment

This section presents an assessment of the potential risks to
atmospheric integrity posed by the use of Firebane® 1179 as a flooding
agent.  According to the submitter, Firebane® 1179 contains no Class I
or Class II ODS, nor any compounds with measured global warming
potential (GWP). Therefore, the use of Firebane® 1179 will be less
damaging to the atmosphere than continued use of Halon 1301.

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 Firebane® 1179.  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® 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

Firebane® 1179 is not expected to pose a risk to workers during
manufacture. As indicated by the submitter, occupational exposure during
manufacture of Firebane® 1179 is expected to be limited to filling of
extinguishers (GSL 2011d). As summarized in the table above, all the
constituents exhibit low toxicity and are commonly used in food
applications. In addition, exposure to Firebane® 1179 is expected to be
in the liquid form, with any vapor or gas exposures considered to be
negligible (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 Firebane® 1179 constituents,
EPA recommends the following in accordance with general procedures
prescribed in the MSDS of the proposed substitute 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 the containers of Firebane®
1179 or extinguishing units filled with the material.

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® 1179 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
Firebane® 1179 (2011d).

Occupational Exposure during Installation and Maintenance

Firebane® 1179 is not expected to pose a significant risk to personnel
during installation and maintenance activities, even in the case of an
inadvertent discharge of the entire charge.  In such cases, oxygen
displacement is negligible and discharge of Firebane® 1179 will not
reduce oxygen levels to levels of concern (GSL 2011d).  In addition, as
noted above, all the constituents of Firebane® 1179 exhibit low
toxicity and are commonly used in food.  To ensure that the potential
for exposures during installation and maintenance are further minimized,
it is recommended that all personnel involved in the installation and
maintenance of Firebane® 1179 adhere to safety guidelines, as mentioned
previously in Section   REF _Ref292194109 \r \h  \* MERGEFORMAT  4.1 . 
It is recommended that the proposed safe handling training also focus on
prevention of an inadvertent discharge.  In case of an inadvertent
discharge, workers should immediately follow the instructions listed in
the MSDS for Firebane® 1179. 

End-Use Exposure Assessment

Firebane® 1179 is not expected to pose significant risk to end-users
when used as a flooding agent in normally occupied or unoccupied spaces.
Firebane® 1179 is designed for use in an AFES, with primary use in
military ground vehicles.  The primary health concern for Firebane®
1179 at the end-use is exposure to the post-activation discharge
products. Inhalation of the Firebane® 1179 may cause mild irritation to
the upper respiratory tract (GSL 2010). 

In the case of Firebane® 1179, it is stored and released as an aqueous
solution. The amount of time it takes for Firebane® 1179 to transverse
the crew compartment is approximately a small fraction of a second (GSL
2011a and GSL 2011d). As such, the amount of Firebane® 1179 suspended
in air in the crew compartment is expected to be minimal (GSL 2011a).
Further, this is a conservative estimate, as the airflow rate in
military ground vehicles that would further decrease the concentrations
of  suspended Firebane® 1179 is not considered in this assessment  
(GSL 2011d).  Phase 2 discharge of Firebane® 1179, as described in
Section 1, is not expected to increase concentrations of the proposed
substitute within the crew compartment; this discharge is similar to a
building sprinkler, resulting in larger droplets that will not be
suspended within the air (GSL 2011a).  Because of the low toxicity
exhibited by Firebane® 1179 and the low inhalation concentrations
anticipated during discharge, Firebane® 1179 is not considered to
present a significant inhalation risk at end-use. 

Dermal and ocular exposure to Firebane® 1179 is not expected to present
a significant risk to end-users. As indicated in the MSDS, Firebane®
1179 is not irritating to the skin and eyes. In the event of exposure to
Firebane® 1179, individuals should follow the instructions prescribed
in the proposed substitute’s 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 releases of Firebane® 1179 and its constituents to ambient
air, surface water, and solid waste.  Firebane® 1179 is not expected to
cause a significant threat to human health in the general population
when used as flooding agent in normally occupied or unoccupied spaces.
The only consumer exposure to Firebane® 1179 will be during discharge
of the extinguishers in occupied spaces. Individuals should follow the
precautionary measures described in the proposed substitute’s 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® 1179 is not expected to pose a significant threat to human
health in the general population in ambient air concentrations. As noted
previously, Firebane® 1179 is composed entirely of compounds that are
FDA-approved for use in food, of which some are also FDA-classified as
GRAS. Therefore, Firebane® 1179 is not expected to be a safety concern
for ambient air contamination. 

6.2.  	Surface Water

Firebane® 1179 is 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 Firebane® 1179, 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 within the
military ground vehicle (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) of
Firebane® 1179, it is recommended that discharges of Firebane® 1179 at
the end-use not be released to waterways. Further, it is recommended
that during cleanup, discharges of Firebane® 1179 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 be provided to all employees that would
be likely to dispose of Firebane® 1179 at end-use. Further, activation
of the Firebane® 1179 AFES is expected to be infrequent (i.e., in case
of a fire emergency), where the greatest risk is exposure to fire and
lack of oxygen.  EPA believes that when the recommended disposal
procedures are followed, Firebane® 1179 does not pose a significant
threat to human health or the environment during end-use. 

Discharges of Firebane® 1179 at manufacture to publicly owned treatment
works (POTW) 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 Firebane® 1179 manufacturing
operations. 

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 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 Firebane® 1179, 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 total flooding systems
charged with 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 testing release
rates) for total flooding systems was calculated to be approximately
2.5% of fire suppressant charge size, annually.  Assuming this release
rate, an assessment was performed to compare the annual VOC emissions
from use of Firebane® 1179 in total flooding systems 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 7.2x10-6 percent of the annual
VOC emissions caused by fires, or only about 2.6x10-7 percent of all
annual anthropogenic sources.  Moreover, even if all 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 2.9x10-4 percent
of annual VOC emissions caused by fires, or only about 1.0x10-5 percent
of all annual anthropogenic VOC emissions.  As these emissions of
Firebane® 1179 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® 1179.” July 22, 2011.

Global Safety Labs, Inc. 2011b.  “Response to Incomplete SNAP
Submission for Firebane® 1179.” June 15, 2011.

Global Safety Labs, Inc. 2011c.  “Response to Incomplete SNAP
Submission for Firebane® 1179.” May 20, 2011.

Global Safety Labs, Inc. 2011d.  “Response to Incomplete SNAP
Submission for Firebane® 1179.” May 6, 2011.

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

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

 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 2.5% for total flooding systems was
determined using the average annual leak rate (0.5%) , annual discharge
rate (2%), and annual release during testing (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 

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