Environmental Protection Agency

                                                                                                                                                                  SNAP LISTING

www.adsiarmor.com

230 Duffy Ave., Hicksville, NY 11801

Tel: (516) 390‐5300      Fax: (516) 390‐2970

THE INFORMATION CONTAINED IN THIS DOCUMENT IS PROPRIETARY TO

FIREFREEZE WORLDWIDE/AMERICAN DEFENSE SYSTEM. INC.  AND FOR THE USE OF THE 

 Environmental Protection Agency                                                         .1

 19 July 2011 

Mr. John F. Rutledge III 

Director Military Programs and Special Projects 

American Defense Systems, Inc. 

230 Duffy Ave 

Hicksville, NY 11801 

jrutledge@adsiarmor.com

Ms. Margaret Sheppard 

Ms. Melissa Fiffer 

Environmental Protection Agency (EPA) SNAP 

RE: Environmental Protection Agency (EPA) SNAP Form 1265-07 (Revised 06/2008) Cold 

Fire Application for Flooding 1301 

Ms. Sheppard & Ms Fiffer 

It is with great pleasure that FireFreeze Worldwide, Inc. and its agent American Defense 

Systems, Inc. (ADSI) submits EPA SNAP form 1265-07 application for additional listing of 

Cold Fire as a flooding agent under 1301. 

In the following pages your will find a sign and completed application per your request. This 

applications in its entirety is contains confidential information relative to Cold Fire not to be 

shared outside of the Government. 

Additionally, in the I will be providing all documentation previously submitted, This will 

require more than one (1) email I will number the emails as 1 f 3, 2of3, 3of3. 

I would like to thank you for all your support during this process of getting Cold Fire listed under 

the EPA SNAP Flooding 1301. 
 Environmental Protection Agency

                                                                                                                                                                  SNAP LISTING

www.adsiarmor.com

230 Duffy Ave., Hicksville, NY 11801

Tel: (516) 390‐5300      Fax: (516) 390‐2970

THE INFORMATION CONTAINED IN THIS DOCUMENT IS PROPRIETARY TO

FIREFREEZE WORLDWIDE/AMERICAN DEFENSE SYSTEM. INC.  AND FOR THE USE OF THE 

 Environmental Protection Agency                                                         .2

Please contact me should you require additional information at 540-842-1678 or 

jrutledge@adsiarmor.com or Mr. Ray Giessler at 973-766-3816 or info@firefreeze.com

Regards, 

John F. Rutledge 

Director Military Programs and Special Projects 

American Defense Systems, Inc. 

Cc; Ray Giessler 
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

1

United States

ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460

AGENCY USE ONLY 

OMB Control No.: 2060-0226 

Expires: 06/30/2011

SNAP INFORMATION NOTICE

For Significant New Alternatives

Date of Receipt:

Date 90 Day Review Begins: 

Date Review Completed: 

CBI Status: 

When completed send this form to:

Via US Postal Service: Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER SNAP DOCUMENT CONTROL OFFICER 

OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA 

U.S. EPA 1310 L STREET NW 

1200 PENNSYLVANIA AVE NW 10th FLOOR (MC 6205J) 

WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: Document Control Number

INTRODUCTION

GENERAL INSTRUCTIONS 

This form may be used to submit information under the Significant New Alternatives Policy (SNAP) program for the review of 

alternatives to class I and class II ozone-depleting substances (ODS) under section 612 of the Clean Air Act. Submitters are 

required to provide this information on new substitutes to assist the Agency in assessing the acceptability of chemicals or 

processes that are considered alternatives for ODSs. A separate notice must be filed for each alternative you are submitting. 

All submissions must be provided in three complete copies. If information is to be claimed as confidential, all confidential 

information must be excised from one of the copies, which will be placed in the public docket; the other two copies must include 

the confidential material. If no claims of confidentiality are made for the submission, all copies must be identical. 

The attached “Guidance Manual for the SNAP Information Notice” is designed to assist applicants in completing this form. The 

manual provides instructions on submitting a SNAP notice, asserting confidentiality claims, completing the notice form, sectorspecific data requirements, and submitting test data and supplemental information. 

To facilitate Agency review of alternatives, this form must be filled out as completely as possible. Please provide all information 

requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailable.

TYPE OF NOTICE (Check only one box) 

Select the appropriate box identifying the type of notice submitted: 

Manufacturer Submission: New alternative, Substance, or Formulation FireFreeze Worldwide SUBMISSION

Petition: New alternative, Substance, or Formulation__________________________________________________________

Petition: Revision of the Existing SNAP list__________________________________________________________________

 Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

2

You must provide the identity of the alternative chemical of 

processes and the identity and percentages of all 

components in a blend and/or process, even if you claim the 

identity as confidential. You may authorize another person 

to submit the identity for you, but your submission will not be 

complete and review cannot begin until EPA receives this 

information. 

Part II - ALTERNATIVE-SPECIFIC INFORMATION

 

Please indicate the sector(s) for which you are submitting 

information on the substitute by checking the appropriate 

boxes: 

• Refrigeration and Air Conditioning  

• Foam Blowing 

• Solvent Cleaning  

• Fire Extinguishing 

 and Explosion Prevention YES 

• Sterilization 

• Aerosols 

• Adhesives, Coatings, and Inks 

• Tobacco Expansion 

• Pesticides 

You may need additional copies of Part II if there are several 

manufacturing, processing, or use operations that you will 

describe in this notice. Please reproduce these sections as 

needed. 

If you substitute is also subject to review under FIFRA, 

provide the FIFRA Registration Number: 

 _____________________________ 

Part III - RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary. 

Part IV - LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on 

the form to fully answer a question. Label each continuation sheet 

with the corresponding section heading and the question. In part 

IV, list these attachments and any test data, other data, or any 

optional information that you include in this notice. 

TEST DATA AND OTHER DATA

You are required to submit all test data in your possession or 

control and to provide a description of all other data known to you if 

these data are related to the health and environmental effects of 

the manufacture, processing, distribution in commerce, use, or 

disposal of the alternative. Standard literature citations may be 

submitted if they do not appear in the open scientific literature. 

Complete test data (in English), not summaries of data, must be 

submitted if they do not appear in the open literature. The following 

are test data and other data that might be submitted (see the 

Guidance Manual for a more complete list of data to be submitted.) 

Please indicate test data to be included in your submission notice 

by checking the appropriate boxes: 

 Health Effects Data Yes 

 Flammability Data  Yes  No 

 Environmental Effects 

 Data YES 

 Environmental Fate 

 Data YES 

 Risk Assessments  Yes  No 

1. Test Data Not in the Possession/

 Control of the Submitter  Yes  No 

 Other Data YES 

You must provide the identity of the alternative chemical of 

processes and the identity and percentages of all 

components in a blend and/or process, even if you claim 

the identity as confidential. You may authorize another 

person to submit the identity for you, but your submission 

will not be complete and review cannot begin until EPA 

receives this information. 

CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentiality at the time of submission for any data which are to be treated as 

Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information claimed as 

CBI will be treated in a manner consistent with 40 CFR Part 2, Subpart B. Failure to assert a claim of confidentiality at the time of 

submission may result in disclosure of information by the Agency without further notice. 

To assert a claim on this form, circle or bracket the information you claim as confidential and mark the confidential box at the bottom 

of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confidential, 

you must provide a “sanitized” version of this notice, including attachments, to EPA with our submission. For additional information 

on claiming information as confidential, please see the Instructions Manual. 

Information submitted as CBI may be accessed by companies designated as Authorized Representatives of the United States 

Environmental Protection Agency (EPA) under an EPA contract for the purpose of assisting EPA in the development and 

implementation of national regulations for the protection of stratospheric ozone, including the development of the SNAP program. 

These Authorized Representatives may have access to any information received by the Stratospheric Protection Division within EPA 

Office of the Atmospheric Programs for use in reviewing the need for possible control of any substance, practice, process or activity 

that may reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary to ensure that these

companies can complete the work required by the contract. 

Authorized Representatives of the Administrator are subject to the provisions of 42 U.S.C. 7414(c) respecting confidential business 

information as implemented by 40 CFR 2.301(h).
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

3

Part I - GENERAL INFORMATION 

Section A - SUBMITTER IDENTIFICATION 

1. (a) Person Submitting Notice (in U.S.)

RAYMOND GIESSLER COO 

_____________________________________________________________________________________________________________ 

Name of Authorized Official Title 

FIREFREEZE WORLDWIDE INC 

____________________________________________________________________________________________________________ 

Company/Organization 

272 RT 46 EAST ROCKAWAY NJ 07866 TEL: 973-627-0722 FAX: 973-627-2982 

____________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

(b) Agent (if applicable) 

JOHN RUTTLEDGE Director of Military Programs and Projects 

____________________________________________________________________________________________________________ 

Name of Authorized Official Title 

AMERICAN DEFENSE SYSTEMS, INC. 

____________________________________________________________________________________________________________ 

Company/Organization 

420 McKinney Parkway 

Lillington, NC 27546 Tel: 540-842-1678 Fax 910-514-9702 

____________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

(c) Joint Submitter (if applicable)

____________________________________________________________________________________________________________ 

Name of Authorized Official Title 

____________________________________________________________________________________________________________ 

Company/Organization 

____________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

2. Technical Contact (in U.S.) 

RAYMOND GIESSLER COO

__________________________________________________________________________________________________________ 

Name of Authorized Official Title 

FIREFREEZE WORLDWIDE INC 

_________________________________________________________________________________________________________ 

Company/Organization 

272 RT 46 EAST ROCKAWAY NJ 07866 TEL:973-627-0722 FAX 973-627-2982

__________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter, phone, 

etc.) and the EPA staff person’s name: 

Margaret Sheppard                                                                         Melissa Fiffer

Environmental Scientist                                                                 Stratospheric Protection Division

email: sheppard.margaret@epa.gov                                           Fiffer.Melissa@epamail.epa.gov

Mark (X) if None _____

Mark (X) this box if this page contains CBI ____ 
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

4

Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative: 

COLD FIRE / Cold Fire Tactical 

2. (a) Name of chemical(s) (preferably IUPAC nomenclature and/or process name. For blends, provide the percent composition of each 

constituents. 

 (b) Chemical Abstracts Service (CAS) registry number and molecular formula. 

 (c) For alternative processes and technologies describe the technology an d and provide a diagram of the system. Also provide the 

information on any chemical constituents. 

 (d) If you hold a patent on the substitute, provide the patent name and number and include a copy of the patent as an attachment. If you 

have submitted a patent application but have not been granted one yet, indicate the date submitted and the expected time frame for a response. 

PROPRIETARY FORMULA HAVING NO KNOWN HAZ SUBSTANCES 

a. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used 

for EPA SNAP Flooding 1301. Without any changes to the formula 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product 

(Cold Fire) formula. 

Note3: Additionally, FireFreeze Worldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All 

testing was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if 

the EPA needs to review testing. 

3. Generic chemical name (if chemical name of substitute is declared Confidential Business Information). 

b. The formula of COLD FIRE is confidential and sensitive information. Due to the number of companies that have made 

efforts to copy the formula and make-up of Cold Fire over the years causing legal action at a great expense to Fire Freeze 

Worldwide. 

c. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used 

for EPA SNAP Flooding 1301. Without any changes to the formula 

Mark (X) this box if this page contains CBI _____XX__________ 
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

5

4. Specific End-Use 

 (a) Describe each end-use that may be reasonably anticipated for the alternative. Be sure to provide a broad description (e.g. terpene-based 

semi-aqueous solvent cleaner for electronic parts, or HFC substitute refrigerant for centrifugal chillers). For a list of end uses, see Appendix A 

to the instructions, beginning on p. 19. 

 (b) Identify the ODS and the quantity of substitute (if applicable) needed to replace it for each end use in pounds (replacement ratio). 

Cold Fire is an aqueous fire suppressant agent. This has been categorized as a Firefighting Foam Agent (NOTE: NOT TO BE 

CONFUSED WITH AFFF TYPE FOAMS). Cold Fire product has been UL Classified 

 Structure fires 

 Structure protection from fires 

 Cool-down of embers on firefighters and other protective applications 

 Tire fires 

 Vehicle fires 

 Paint and oil-based fires 

 Automotive, aviation and ship board fuel fires 

 Fuel storage tanks close to fires (keeping them cool) 

 Rapid cool-down of military equipment in combat related events i.e. IEDs, VBIEDs, and EFPs 

 Protection of hazardous or explosive material from oncoming fires 

 Creation of a heat barrier to help prevent heat damage and hidden fires 

 Closed loop systems such as sprinkler systems and on-board extinguishing systems 

*The above are just a few applications of CF 

Cold Fire is listed on EPA SNAP Streaming 1211 

Cold Fire is UL Classified: 2N75 

Cold Fire is NFPA 18 

Cold Fire Is NFPA 13 

The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used for EPA 

SNAP Flooding 1301. Without any changes to the formula 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product (Cold 

Fire) formula. 

Note3: Additionally, FireFreeze Worldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Mark (X) this box if this page contains CBI _____XX__________ 
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

6

Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION (Continued)

5. (a) Identify each impurity that may reasonably be anticipated to be present in the chemical alternative as manufactured for commercial 

purposes. If there are unidentified impurities, enter “unidentified.” 

 (b) Provide the CAS Registry Number if available. 

 (c) Estimate the maximum weight percentage of each impurity. If there are unidentified impurities, estimate their total weight 

percentages. 

a. Cold Fire has no impurity that may reasonably be anticipated to be present in the suppressant agent. 

a. It should be noted that documented testing was provide to the EPA under different letter. 

b. Cold Fire has no CAS registry number 

c. Cold Fire has no impurity 

d. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used 

for EPA SNAP Flooding 1301. Without any changes to the formula 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product (Cold 

Fire) formula. 

Note3: Additionally, Fire Freeze Worldwide is listed on the EPA SNAP website as an Alternative Approved Manufacture for alternative 

replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

6. Byproducts: 

 (a) Describe any byproducts of degradation products resulting from the manufacturer, processing, use or disposal of the chemical alternative 

or chemicals used in the new alternative. If there are unidentified byproducts/ degradation products enter “unidentified.” 

 (b) Provide the CAS Registry Number if available. 

 (c) Indicate where the byproduct/degradation product is formed (e.g. during manufacturing, during use, etc.) and the amount or rate at which 

it is formed. 

a. Cold Fire has no byproducts of degradation resulting from the manufacturing process. 

b. Cold Fire has no CAS registry number 

c. Cold Fire has no byproducts of degradation resulting from the manufacturing process. 

d. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used 

for EPA SNAP Flooding 1301. Without any changes to the formula 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product (Cold 

Fire) formula. 

Note3: Additionally, Fire Freeze Worldwide, Inc. Is listed on the EPA SNAP website as an Alternative Approved Manufacture for

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Mark (X) this box if this page contains CBI _____XX______ 
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

7

Part II - ALTERNATIVE-SPECIFIC INFORMATION

Section A - PHYSICAL AND CHEMICAL PROPERTIES

1. Molecular weight: 9 LBS PER GALLON 2. Physical state at 20 C N/A

3. Melting point: N/A 4. Boiling point at 1 atm. Pressure 

 SAME AS WATER C

5. Specific gravity g/ml 6. Odor threshhold mg/m3

7. Solubility using solvent 100% WITH WATER @ temperature C 

g/L

8. Solubility in water @ temperature C

9. Partition coefficient : N/A Log Kow Log K

10. Vapor pressure @ 20 C: N/A psi 11. Critical temperature 

C

12. Critical Pressure 

psi

13. Are spectra attached? N/A 14. Disassociation constant: N/A

15. Particle size distribution : SYSTEM MAKES SIZE 16. Volatilization from soil: NA

17. Volatilization from water: NONE 18. Viscosity @ 20 C: HEAVIER THEN WATER

19. pH@concentration : 7 20. Thermal conductivity: SAME AS WATER

21. Adsorption coefficient N/A 22. Flammability limits (LFL, UFL) N/A % 

vol

23. Flash point: N/A 24. Heat of combustion NA

25. Maximum pressure rise: N/A 26. Maximum rate of pressure rise: None 

27. Other (specify)

28. Provide any information on flammability concerns. For example, if any abatement techniques are being used to minimize the risks 

associated with flammable substances or mixtures, detail those techniques below. If a substitute is flammable, an assessment of overall risk 

in each end-use may be required. (See Instructions for sector-specific data requirements for flammable substances). 

1. Cold Fire is fire suppressant agent and is 100% Non-Flammable. 

Mark (X) this box if this page contains CBI __XX_______
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

8

1. Ozone-depletion potential (ODP): 

 (a) Provide the 100 year ODP of the alternative relative to CFC-11, if known. If the substitute is a blend, provide the ODPs of individual 

constituents. 

 (b) Provide source of ODP or any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromine loading 

potentials). Reference the source of this information and attach any supporting documentation. 

a. Cold Fire formula has been approved for EPA SNAP streaming 1211 so there is no Ozone-depletion potential. This 

application is to use the same agent( Cold Fire) for EPA SNAP Flooding 1301 

b. Non- applicable 

2. Global Warming Characteristics: 

 (a) Provide the alternative’s global warming potential (GWP) relative to carbon dioxide over 100- and 500-year time horizons, if known. If 

the substitute is a blend, provide the GWPs of the individual constituents. 

 (b) If known, provide the alternative’s expected impact on energy efficiency relative to the substance it is replacing (e.g. +/- X%) and results 

of any testing or modeling done (both theoretical and actual testing). 

 (c) Provide source of GWP or any additional data on the GWP of the alternative, including the atmospheric lifetime, infrared absorption 

spectrum, and infrared absorption capacity. If the alternative (e.g. CO2 captured from a stream of waste gas as a by-product of fermentation). 

1. Cold Fire has no effect or characteristics that affect Global Warming. 

a. Official Government testing was conducted at U.S. Army Proving Grounds, Aberdeen Testing Center, during the 

May/ June 2011 time frame in support of the United States Marine Corps, Automated Fire Suppressant 

Extinguishing – Replacement (AFER-R) system used to deliver Cold Fire. 

b. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for 

streaming used for EPA SNAP Flooding 1301. Without any changes to the formula 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product (Cold 

Fire) formula. 

Note3: Additionally, FireFreeze Worldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Mark (X) this box if this page contains CBI ____XX______ 

Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

9

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued) 

Section C - OTHER STATUTES AND STANDARDS 

1. Describe whether an d how the alternative is regulated under other environmental regulatory statutes, for example other titles under the 

Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Drinking Water Act (SDWA), the Resource Conservation and Recovery Act 

(RCA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), the Comprehensive 

Environmental Response, Compensation and Liability Act (CERCLA), the Emergency Planning and Community Right-to-Know Act 

(EPCRA, also known as SARA Title III), and state and local laws. List any concentration-based or other numerical standards to which the 

alternative is subject under the above standards and regulations. 

Cold Fire is listed on EPA SNAP Streaming 1211 

Cold Fire is UL Classified: 2N75 

Cold Fire is NFPA 18 

Cold Fire Is NFPA 13 

a. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used 

for EPA SNAP Flooding 1301. Without any changes to the formula 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product 

(Cold Fire) formula. 

Note3: Additionally, FireFreeze Worldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Mark (X) this box if this page contains CBI ___XX_______
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

10

2. Describe whether and how the alternative is regulated under health and safety related statutory authorities, such as those implemented by 

the Food and Drug Administration (FDA), the Occupational Safety and Health Administration (OSHA), the Department of Transportation 

(DOT), and state and local laws. List any concentration-based or other numerical standards to which the alternative is subject under the 

above statutes and regulations. Also list any other standard-setting organizations such as the National Fire Prevention Association (NFPA) 

or the American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE), by which the substitute is evaluated. 

Cold Fire is listed on EPA SNAP Streaming 1211 

Cold Fire is UL Classified: 2N75 

Cold Fire is NFPA 18 

Cold Fire Is NFPA 13 

a.The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used for EPA 

SNAP Flooding 1301. Without any changes to the formula 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product 

(Cold Fire) formula. 

Note3: Additionally, FireFreeze Worldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Mark (X) this box if this page contains CBI ___XX_______
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

11

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

2. Estimate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installation costs associated 

with the alternative 

1.The estimates cost for Cold Fire is $18.00 per gallon there is no cost associated with using Cold Fire as a wetting agent. 

 

2.The Purpose of this application is to have Cold Fire and Approved EPA SNAP fire suppressant agent for streaming used for EPA 

SNAP Flooding 1301. Without any changes to the formula 

2. Provide information on production of the substitute. Include estimates on: 

 (a) Year substitute will be available if not currently produced. Cold Fire is currently produced 

 (b) Total pounds production per year (current figure). Cold Fire is a suppressant agent ( N/A) 

 (c) Years to maximum market penetration. N/A

 (d) Maximum total production per year at market saturation. N/A

 (e) Estimated percentage of market at market saturation. N/A 

Mark (X) this box if this page contains CBI ___XX_______
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

12

3. Describe any new equipment and use profiles. If retrofitting of existing equipment is required, detail changes in technologies needed to use 

the alternative and address any materials compatibility issues. Provide information on each end-use and capital costs associated with the 

substitute or alternative process. Include cost of equipment and/or any new materials, equipment lifetime, changes in labor and energy costs. 

1. The Automated Fire Extinguishing System- Replace (AFES-R) was designed to perform a very specific function. The AFES-R 

system was designed for USMC to protect military personnel in military vehicles (only) this is not a commercial application. 

 The number of personnel in a HMMWV could be one (1) to five (5). 

o 1-Driver, 1-Vehical commander, 2- Passengers and 1- Gunner (manning the 50 Cal. Machine Gun. 

o Note: The Gunner sits in a position where the upper half of his body is outside the crew cab in an open 

turret. 

2. The AFES-R system was designed for use in the present fielded HMMWV’s. The requirements of the AFES-R system were 

developed by the USMC. This being the first AFES-R system using a wetting agent suppressant system to be tested and field by the 

USMC information on the requirement development is unknown. To meet the AFES-R equipment’s requirements of space and 

weight we are designed a two (2) gal hydro-nomadic tank for maximum agent dispersion. Additionally, and most important is to 

extinguish fires and provide maximum protection from burns to the Marine allowing increase time to egress a burning HMMWV. 

NOTE: The Cost information for the equipment, material, equipment life is presently under a US Marine Corps solicitation for 

competitive bid. Presently the AFES-R system has been tested at China Lake Naval testing facility, has be under review by USMC Source 

teams, has complete a round of Live Burn test, as well as durability testing at Aberdeen proving Grounds, Aberdeen Testing Center. So at 

this time I am restricted from provided the requested information’s. 

Mark (X) this box if this page contains CBI ___XX______
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

13

Part III - RELEASE AND EXPOSURE DATA

Section A - TOXICITY AND HAZARD INFORMATION

For chemical alternatives and for chemicals used with alternative processes, summarize below (and attached supporting information) the acute 

and chronic toxicity of the substitute and of its constituent chemicals on any organism (e.g. human and/or other mammals, fish, wildlife, and 

plants), if available. Include any data on impurities and degradation products if known. Also include information on any “Allowable 

Exposure Limits” (AELs) that have been set for the substitute for use in the workplace. In addition, please attach a copy or facsimile of any 

hazard warning statement, label, material safety data sheet, or other information which will be provided to any person who is reasonably likely 

to be exposed. (See Guidance Manual for sector-specific data requirements). 

1. In response to this section the U.S. Department of Agriculture testing conducted for the U.S. Forestry Service address’s all

information requested above. The DoA testing is provided with this submission. 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product (Cold 

Fire) formula. 

Note3: Additionally, FireFreeze Worldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site: 

 (a) Identify all site locations (i.e. name and address) for each chemical manufacturing process. 

 (b) Identify all site locations for manufacturing of products using substitutes (e.g. refrigerators containing the substitutes). 

 (c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products containing the substitutes. 

 (d) Provide information on the magnitude of release if available, along with the media to which the substitute is released (e.g. indoor air, 

outdoor air, water, land). 

a. Cold Fire is agent mixing is accomplished at the Firefreeze facility located at : 

a. 429 ROCKAWAY VALLEY ROAD BLDG 8 AND 9 BOONTON TWP NJ 07005 

b. None applicable 

c. Cold Fire is liquid agent that if spill over accrues during mixing or filling it has been tested to be 100% Bio- Degradable 

and is washed away with water. 

d. Not available 

e. The Purpose of this application is to have Cold Fire and Approved EAP SNAP fire suppressant agent for streaming used 

for EPA SNAP Flooding 1301. Without any changes to the formula 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product (Cold 

Fire) formula. 

Note3: Additionally, Fire Freeze Worldwide, Inc. is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center, All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

14

Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

For each manufacturing site (manufacturing of substitutes and/or products containing substitutes): 

 (a) Describe the activities in which workers may be exposed to chemicals. 

 (b) Describe any protective equipment and engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods). 

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas 

 (d) Estimate average and maximum numbers of workers involved in each activity. 

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hour/day and (2) days/year. 

 (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal). FORESTRY REPORT 

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units of measure. 

a. Blended in Agent ( chemical) containment Tanks 

b. N/A Basis eye protection (safety glass) and OSHA eye washing station 

c. Cold Fire has a combinations of Liquids/Solids/Powders all of which are not harmful during mixing of the Cold Fire 

Formula 

d. Two(2) to Four (4) employees 

e. N/A 

f. None 

Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE

For each end-use of a substitute: 

 (a) Provide the estimated amount (in kg/day) of each chemical released directly to the environment (e.g. as a hazardous waste or 

wastewater effluent) at a site using the substitute (e.g. in products containing the substitute and processes using the substitute). 

 (b) Identify the media (indoor air, outdoor air, land, water) to which the chemical will be released from that release point. 

 (c) Describe the control technology used to limit release; estimate the amount released to the environment with the control technology in 

place to limit release. If the substitute is to be disposed of, indicate the method and location of disposal. 

 (d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes. 

 (e) Identify the appropriate number of sites expected to use the substitute. 

 (f) Provide information on recycling of the substitute. Describe any associated costs and equipment. 

1.In response to this section please review the testing package provided. Please pay particular attention to the Department of

Agriculture testing conducted for the U.S. Forestry Service. 

2.Cold Fire Is 100% Bio- Degradable with no adverse effects on the environment 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product (Cold 

Fire) formula. 

Note3: Additionally, Fire Freeze Worldwide, Inc. is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center, All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

15

Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the substitute (end-uses utilizing the substitute in products and/or processes): 

 (a) Describe the activities in which workers may be exposed to chemicals. 

 (b) Describe any protective equipment or engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods). 

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas). 

 (d) Estimate average and maximum numbers of workers involved in each activity. 

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year. 

 (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal). 

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units. 

a. Blended in Agent (chemical) containment tank (all chemicals are non- hazardous in mixed and un-mixed state. 

b. N/A Basis eye protection (safety glass) and OSHA eye washing station 

c. Cold Fire has a combinations of Liquids/Solids/Powders all of which are harmful during mixing of the Cold Fire Formula 

d. Two(2) to Four (4) employees 

e. N/A 

f. None 

g. None 

Section F - CONSUMER EXPOSURE

For each end-use of a substitute: 

 (a) Identify the potentially exposed population (e.g. indoor residents). 

 (b) Identify the exposure medium (e.g. air). 

 (c) Enter the contact pathway (e.g. ingestion, inhalation, dermal). 

 (d) Enter the exposure point of concentration. Provide (1) average and (2) high-end estimates. 

1. In response to the above (a thru e). A complete testing package has been provided under different letter. As part of the submission 

we have reattached to the submission email. Additionally, We will attach a copy of the final test report from Department of 

Agriculture Cold Fire Test conducted for the US Forestry Service. 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product (Cold 

Fire) formula. 

Note3: Additionally, FireFreeze Worldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Mark (X) this box if this page contains CBI ___XX______
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

16

Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULATION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes: 

 (a) Identify and number potential exposure points. 

 (b) For each exposure point described in (a), identify the potentially exposed population (e.g. residents at the fenceline). 

 (c) Identify the contact pathway (e.g. ingestion, inhalation, dermal). 

 (d) Identify the exposure medium (e.g. air, water). 

 (e) Enter the exposure point concentration (mg/m3

). Provide (1) average and (2) high-end estimates. 

1. In response to the above (a thru e). A complete testing package has been provided under different letter. As part of the submission 

we have reattached to the submission email. Additionally, We will attach a copy of the final test report from Department of 

Agriculture Cold Fire Test conducted for the US Forestry Service. 

Note1: Cold Fire agent test provided to support EPA SNAP Flooding 1301 

Note2: It should note that Cold Fire is presently listed on the EPA SNAP listing for Streaming 1211. There is no change to product (Cold 

Fire) formula. 

Note3: Additionally, FireFreeze Worldwide, Inc. Is listed on the EPA SNAP Website as an Alternative Approved Manufacture for 

alternative replacement of Ozone depletion products. 

Note4: Cold Fire and AFESR System testing have been conducted at Aberdeen Proving Grounds, Aberdeen Testing Center; All testing 

was conducted by the US Government and is under review. If requested we will provide the Contracting officer information if the EPA 

needs to review testing. 

Mark (X) this box if this page contains CBI ___XX_______
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

17

Part IV - LIST OF ATTACHMENTS

List below any attachments that complete the responses to the questions on this form or that provide additional information that may assist 

EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide citation for information already submitted to EPA as 

part of past regulatory and information activities, as well as for other information that could not be included with this submission. If you have 

attached continuation pages, describe the Part, Section and question number being continued. Attach additional pages if necessary.

Attachment Name Question # Number of Pages CBI

Initial letter to EPA SNAP dtd 31 March 2011w/ testing 

Response to EPA SNAP questions dtd 14 June 2011 

Department of Agriculture ( US Forestry Service ) 

official test reports Cold Fire 

 

Cold Fire MSDS 

Initial Cold Fire Power Point Presentation 

 

 

Mark (X) this box if this page contains CBI __XX______
Form 1265-07 (Revised 06/2008) 

Previous editions are obsolete 

18

Part V - CERTIFICATION

I certify to the best of my knowledge and belief that: 

1. All information provided in this notice is complete and truthful as of the date of the submission. 

2. I am submitting with this notice all test data in my possession or control and a description of all other data known to or 

reasonably ascertainable by me. 

3. If this is a submission of a new alternative, the company name in Part I, Question 1a of this notice: 

 (a) Intends to manufacture, formulate, import, market, or use a new alternative to a Class I or Class II ozone-depleting 

substance which is identified in Part Me, Section B, Question 2. 

 (b) seeks an acceptability determination on a new alternative(s) to a Class I or Class II ozone-depleting substance, which is 

identified in Part I, Section B, Question 2. 

4. The accuracy of the statements made in this notice reflects my best prediction of the anticipated facts regarding the 

alternative described herein. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to section 113(c) 

of the Clean Air Act and 18 U.S.C.§1001.

Signature and Title of Authorized Official (Original Signature Required): Date 

“signed “ Raymond Giessler COO 19 July 2011 

Signature of Agent (Where Applicable): Date 

 19 July 2011 

For persons filing a SNAP Information Notice, the reporting burden is estimated to average 150 hours per year. 

For persons filing a TSCA/SNAP Addendum, the reporting burden is estimated to average 46 hours her year. 

Burden means that total time, or financial resources expended by persons to generate, maintain, retain, or disclose 

or provide information to or for a Federal agency. This includes the time needed to review instruction; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying 

information; adjust the existing ways to comply with any previously applicable instructions and requirements; train 

personnel to be able to respond to a collection of information; search data sources; complete and review the 

collection of information; and transmit or otherwise disclose the information. An agency may not conduct or 

sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid 

OMB control number. 

Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any 

suggested methods for minimizing respondent burden, including through the use of automated collection 

techniques to the Director, Collection Strategies Division (2822T), U.S. Environmental Protection Agency,1200 

Pennsylvania Ave NW, Washington, DC 20460. Include the OMB control number in any correspondence. 

Do not send the completed form to this address.

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