Significant New Alternatives Policy Program
Fire Extinguishing and Explosion Prevention Sector
Risk Screen on Substitutes for Halon 1301
Total Flooding Systems in Normally Occupied Spaces
                             Substitute: Cold Fire


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 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 Cold Fire when used as a flooding agent in normally occupied 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. 

Cold Fire is designed for primary use in military vehicle fire protection in the Advanced Automatic Fire Extinguishing System Replacement (AFES-R). AFES-R contains one extinguisher filled with two gallons of Cold Fire. The extinguisher discharges Cold Fire into the vehicle at a specific rate to meet the design concentration needed to extinguish and suppress fires. For other applications, the extinguishing system may utilize a smaller or larger extinguisher size, such that the design concentration of Cold Fire, at a minimum, is applied to the occupied space.

Table 1 presents the composition of the proposed substitute.


                       Table 1: Composition of Cold Fire
                                  Constituent
                               Chemical Formula
                                    CAS No.
                         Percent of Total (by weight)









                                       
                                       
                                       
[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: Potential Health Effects;
   * Section 5: Occupational Exposure Assessment; 
   * Section 6: End-Use Exposure Assessment; 
   * Section 7: General Population Exposure Assessment; 
   * Section 8: Volatile Organic Compound Assessment; and
   * Section 9: References.
SUMMARY OF RESULTS
Cold Fire is recommended for SNAP approval as a flooding agent in normally occupied spaces.  Given that  proper training will be provided to personnel and that appropriate PPE (OSHA Category D) and proper procedures according to the MSDS (including provision of adequate ventilation) will be used during manufacturing and disposal activities, no significant risks to workers or the general population is anticipated.  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 and substitutes used in this sector, such as HFC-227ea and HFC-125.  
ATMOSPHERIC ASSESSMENT
This section presents an assessment of the potential risks to atmospheric integrity posed by the use of Cold Fire as a flooding agent. Cold Fire contains no Class I or Class II ODS, nor any compounds with a measured global warming potential (GWP). Therefore, the use of Cold Fire will be less damaging to the atmosphere than continued use of Halon 1301, which has a GWP of 7,140 (Forster et al. 2007) and an ozone depletion potential (ODP) of 15.9 (WMO 2011). Furthermore, Cold Fire has a significantly lower impact on the climate than other substitutes used in this sector, such as HCFC Blend A, HFC-227ea, and HFC-125, as shown in Table 2.

 Table 2.  Atmospheric Impacts of Cold Fire Compared to Other Flooding Agents
                                  Refrigerant
                        Ozone Depleting Potential (ODP)
                        Global Warming Potential (GWP) 
                     Atmospheric Lifetime (ALT) in Years 
                                   Cold Fire
                                       0
                                       0
                                       0
                                  Halon 1301
                                    15.9[a]
                                   7,140[b]
                                     65[b]
                                HCFC Blend A[c]
                                   0.035[ad]
                                   1,546[b]
                                     NA[e]
                                   HFC-227ea
                                       0
                                   3,220[b]
                                    34.2[b]
                                    HFC-125
                                       0
                                   3,500[b]
                                     29[b]
[a] WMO (2010) 
[b] IPCC 4th Assessment Report (Forster et al. 2007)
[c] HCFC Blend A is a blend consisting of HCFC-123 (4.75%), HCFC-22 (82%), HCFC-124 (9.5%), and D-limonene (3.75%).
[d] WMO (2007)
[e] NA= not available. Atmospheric lifetimes are not given for blends because the components separate in the atmosphere. The ALT for HCFC-123 is 1.3 years, HCFC-22 is 12 years, HCFC-124 is 5.8 years, and D-limonene ranges from less than a minute to a few hours (IPCC 4th Assessment Report [Forster et al. 2007] and WHO 1998).
POTENTIAL HEALTH EFFECTS
According to the MSDS, Cold Fire is not a primary ocular or skin irritant, and is not considered to be orally toxic. However, Cold Fire may irritate the eyes if it is sprayed directly into them. If contact with eyes occurs, immediately flush the eyes with water. In the case of dermal exposure, the skin should be rinsed with water. Should ingestion occur, the person should drink water. Inhalation is not expected to pose a concern, but removal to fresh air is recommended. When the PPE recommendations outlined in the MSDS for Cold Fire and Section 5.1 of this risk screen are followed, these potential health effects are unlikely to occur.
OCCUPATIONAL EXPOSURE ASSESSMENT 
The potential for personnel exposure during manufacture, installation, and maintenance are examined in this section.  Discharge scenarios discussed are assumed to occur accidentally and not as the result of a fire.  In order to evaluate occupational exposure, EPA has evaluated the active compounds contained in Cold Fire.  The common application types, U.S. Food and Drug Administration (FDA) approval status, and associated hazards for these compounds are presented in Table 3. 

Table 3: Common Applications Types and FDA Approval Status of Cold Fire Constituents
                                  Constituent
                           Common Application Types
                           FDA Approval Status[a,b]
                              Associated Hazards









 
 
 
[a] FDA approvals are subject to use restrictions. Please see the cited regulation for further information.
[b] GRAS = Generally Recognized as Safe
[c] The application type and associated hazards noted in this row may not be representative of all chemicals in the category.
[d] NA = not available

   0.1.       Occupational Exposure during Manufacture
Cold Fire is not expected to pose a concern to workers during manufacture. Safety and precautionary measures make it unlikely that exposure would occur during manufacturing activities. Further, all the constituents exhibit low toxicity and are commonly used in food or cosmetic applications. 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 protect workers from exposure to all Cold Fire constituents, EPA has outlined the following recommendations in accordance with established good manufacturing practices:
   *     OSHA 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 Cold Fire or extinguishing units filled with the material.
Because worker exposure to the chemicals during the manufacturing process is unlikely, and the use of exposure controls and adherence to the appropriate occupational safety guidelines would be followed under good manufacturing practices, as mentioned above, EPA believes that manufacture of Cold Fire does not pose a significant risk to human health. 
   0.2.       Occupational Exposure during Installation and Maintenance
Cold Fire 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 not a concern, due to the physical characteristics of Cold Fire at discharge.   In addition, as noted above, all the constituents of Cold Fire exhibit low toxicity and are commonly used in food or cosmetic applications.  By adhering to safety guidelines, as mentioned previously in Section 4 and Section 5.1, the potential for worker exposures to Cold Fire during installation and maintenance will be unlikely.  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 Cold Fire. 
END-USE EXPOSURE ASSESSMENT
Cold Fire is not expected to pose significant risk to end-users when used as a flooding agent in normally occupied spaces. Cold Fire is primarily designed for use in the AFES-R in military vehicles such as the High Mobility Multipurpose Wheeled Vehicle.  For other ground vehicles with smaller volumes, the submitter has indicated that a smaller extinguisher size would be used.  For locations with lower air pressure (e.g., aircraft), the application density and performance of Cold Fire and thus, exposure pattern, is not expected to change. Based on these scenarios, EPA modeled the maximum exposure concentration of Cold-Fire that an end-user would be exposed to, assuming that the entire extinguisher is released and suspended in air. However, the resulting modeled concentration is an extremely conservative estimate. Cold Fire is released as an aqueous solution, and based on the small droplet size, the settling rate of Cold Fire is estimated to be on the order of several seconds. As such, the actual amount of Cold Fire suspended in air in the crew compartment upon release is expected to be significantly less than the modeled concentration. Further, the airflow rate is not considered in this assessment, which would further decrease the concentration of suspended Cold Fire.  Because of the low toxicity exhibited by Cold Fire and the low inhalation concentrations anticipated during discharge, Cold Fire is not considered to present a significant inhalation risk at end-use. 

Dermal and ocular exposure to Cold Fire is not expected to pose a significant risk to end-users. In the event of exposure to Cold Fire, individuals are expected to follow the instructions prescribed in the proposed substitute's MSDS. Because individuals follow the precautionary measures described in Section 4 and Section 5.1, risk of exposure and irritation will be unlikely. 
GENERAL POPULATION EXPOSURE ASSESSMENT
This section screens potential risks to the general population from exposure to releases of Cold Fire and its constituents to ambient air, surface water, and solid waste.  Cold Fire is not expected to cause a significant risk to human health in the general population when used as flooding agent in normally occupied spaces. The only consumer exposure to Cold Fire will be during discharge of the extinguishers in occupied spaces. When the precautionary measures described in the proposed substitute's MSDS and Section 4 and Section 5.1 of this risk screen, no adverse health effects are expected.
7.1. 	Ambient Air
Cold Fire is not expected to pose a significant risk to human health in the general population in ambient air concentrations. The active constituents of Cold Fire are commonly used in cosmetics or foods, including some that are FDA-approved for use in food or FDA-classified as GRAS. Therefore, Cold Fire is not expected to be a safety concern for ambient air contamination. 
7.2.  	Surface Water
Cold Fire is not expected to pose a significant risk to human health or the environment when proper disposal procedures in accordance to local, state, and federal requirements 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 Cold Fire, it is expected that all of the constituents would rapidly aerosolize during expulsion from the container and then settle as an oily water film on surfaces within the space (as opposed to becoming airborne and settling on a nearby stream). After settling, cleanup would involve washing/rinsing of surfaces. Cold Fire, as prepared and installed for use, is biodegradable and can be disposed of through municipal systems. (Concentrated Cold Fire, as manufactured prior to dilution, is significantly slower at breaking down and should not be released to waterways.) Further, during cleanup, discharges of Cold Fire are to be collected (e.g., mopped) and disposed of as a non-hazardous waste in accordance with local requirements. It is important to note that activation of the Cold Fire AFES-R 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 disposal procedures are followed in accordance to local, state, and federal requirements, Cold Fire does not pose a significant risk to human health or the environment during end-use. 
7.3. 	Solid Waste
No constituents of Cold Fire 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 Cold Fire, none are considered to be a volatile organic compound (VOC). Therefore, emissions of Cold Fire are not considered to be a contributor to VOC emissions.  
REFERENCESFIRE FREEZE WORLDWIDE, Inc.. 2012a. Response to Incomplete  SNAP Submission for Cold Fire in Total Flooding End-Use. May 24, 2012.
Fire Freeze Worldwide, Inc. 2012b. Response to Incomplete SNAP Submission for Cold Fire in Total Flooding End-Use. May 18, 2012.
Fire Freeze Worldwide,Inc.2012c. Response to Incomplete SNAP Submission for Cold Fire in Total Flooding End-Use. April 17, 2012.
Fire Freeze Worldwide, Inc 2011a. Response to Incomplete SNAP Submission for Cold Fire in Total Flooding End-Use. July 26, 2011.
Fire Freeze Worldwide, Inc2011b. Response to Incomplete SNAP Submission for Cold Fire in Total Flooding End-Use. June 14, 2011.
Fire Freeze Worldwide, Inc. 2011c. SNAP Submission to EPA for Cold Fire in Total Flooding End-Use. March 31, 2011.
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.
Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, G. Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland. 2007.  Changes in Atmospheric Constituents and in Radiative Forcing. In: Climate Change 2007:The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.
OSHA. 1994. General description and discussion of the levels of protection and protective gear. 1910.120 App B. Last updated August 22, 1994. Available at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9767

WHO (World Health Organization). 1998. Concise International Chemical Assessment Document 5. Limonene. Prepared by A. Falk Filipsson, J. Bard, and S. Karlsson. 1998.

WMO (World Meteorological Organization), 2011. Scientific Assessment of Ozone Depletion: 2010, Global Ozone Research and Monitoring Project -- Report No. 52, 516 pp., Geneva, Switzerland, 2011.

