September 27, 2011

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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.

1. 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 Error! Reference source not found.5). 

Table 1 presents the composition of the proposed substitute.
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Table 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.

2. 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. 

3. 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.

4. 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 Table 2. 
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Table 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

4.1. 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).

4.2. 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 
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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 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.

5. 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 4.1.

6. 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 
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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 demand1(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.2 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. 

7. 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.3 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 7.2x10-6percent of the annual VOC emissions caused by fires,4or only about 

 

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

2

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.

3 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).

4 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.
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2.6x10-7 percent of all annual anthropogenic sources. 5 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 2.9x10-4percent of 

annual VOC emissions caused by fires, or only about 1.0x10-5percent 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.

8. 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.

 

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

assumptions.