Margaret Sheppard

Stratospheric Protection Division

ARL-TARDEC Fire Protection 

Information Exchange Meeting

October 14-15, 2015,Aberdeen Proving Ground, MD

EPA Overview 
Outline

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 SNAP submissions for fire suppression

 Sector activities

 SNAP stakeholder meeting on recent and 

upcoming actions

Recent petitions related to fire suppressants

Next steps

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• Acceptable - those that reduce overall risk to human health & environment

• Acceptable with use restrictions - if needed to ensure safe use

• Unacceptable

Evaluates alternatives & lists alternatives as:

• Aerosols; Foams; Refrigeration and A/C; Solvents; Fire 

Suppression; Adhesives, Coatings, Inks, etc.

Sectors include:

• Ozone Depletion Potential

• Global Warming Potential

• Flammability

• Toxicity

Considers: 

• Local Air Quality

• Ecosystem Effects

• Occupational & Consumer 

Health/Safety
SNAP Listings for Fire Suppression

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End-Use

Acceptable 

Substitutes

Unacceptable 

Substitutes

Total 

Listings

Streaming: HFCs, HCFCs

and blends, PFC, dry 

chemical, fluoroketones

(FKs), CO2, water

24 1 25

Total Flooding:

HFCs, HCFCs and

blends, PFCs, inert 

gas/generators, 

aerosols, FK, CO2, water

43 4 47

All of Fire Suppression 59 5 64
SNAP Submissions

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 2-bromo-3,3,3-trifluoropropene (2-BTP)

 Streaming and total flooding

 Parallel review with TSCA New Chemicals Program

 Ongoing review, considering additional information from 

submitter

 Inquiries on potential new submissions
Sector Activities

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 Aviation

 FAA Halon Aviation Rulemaking Committee Final 

Report (Dec. 2014)

Ongoing coordination with ICAO, HTOC

 DoD

 ODS Services Steering Committee

 Standards

NFPA, ISO Technical Committees
President’s Climate Action Plan and SNAP

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 International diplomacy

 Montreal Protocol

 Other forums both multinational and bilateral 

 Domestic actions: 

 Federal procurement

 EPA’s SNAP Program:

 Encourage private sector investment by 

identifying and approving climate-friendly 

chemicals 

 Prohibit certain uses of the most harmful 

chemical alternatives

“To reduce emissions of HFCs, the United States can and will lead 

both through international diplomacy as well as domestic actions”

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Federal Actions Addressing HFCs

• FAR proposed rule (May 11, 2015) addressed HFCs by directing 

the government to procure alternatives to high-GWP HFCs:

• Where feasible, substitute acceptable alternatives as identified by SNAP 

program

• Vendor reporting on use of HFCs (i.e., refrigerants)

• Final rule being drafted

• EO 13693 (March 19, 2015) - Planning for Federal Sustainability 

in the Next Decade 

• Direct GHG emissions reduced by at

least 40% by 2025

• Agencies to purchase sustainable

products and services identified by EPA

programs including alternatives to ODS 

and high-GWP HFCs, where feasible, as 

identified by SNAP

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SNAP Stakeholder Meeting

September 11, 2015

Washington, DC
Welcome - Scope of Meeting

 The SNAP Program 

 Recent actions

 Near-term Roadmap and Actions Being Considered 

 Discussion Questions

 Next Steps

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SNAP Action Update

 Issued two acceptability 

notices adding alternatives

 Published October 21, 2014 

 Published July 16, 2015

 Issued new rule adding five 

low-GWP flammable 

refrigerants with use 

conditions 

 Published April 10, 2015

 Published Status Change 

Rule prohibiting certain 

HFCs in certain end-uses

 Published July 20, 2015 

 HFC Emissions Reductions: 

54-64 MMTCO2eq in 2025

Near term changes can provide 

both near and long term 

benefits

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Acceptability Notices

R-450A (HFC/HFO blend) RefAC

GWP: ~604 compared to HFC-134a: 1430

1233zd(E) heat transfer & flexible PU foams 

GWP <7 compared to alternatives:1070-4000

CO2refrigerated transport

GWP: 1 compared to alternatives: ~1400-4000 

Methylal foam blowing end-uses

GWP <3 compared to alternatives: 725-1430 

HFO-1336mzz(Z) foam blowing end-uses

GWP: ~9 compared to alternatives: 725-1430

Powdered Aerosol D fire suppression

GWP <25 compared to alternatives: 0-3500

R-450A (HFC/HFO blend) RefAC

GWP: ~604 compared to HFC-134a: 1430 

R-448A (HFC/HFO blend) RefAC

GWP: 1387 compared to R-404A: 3922

R-513A (HFC/HFO blend) RefAC

GWP: 630 compared to HFC-134a: 1430

R-449A (HFC/HFO blend) RefAC

GWP:1397 compared to R-404A: 3922

HFO-1336mzz(Z) foam blowing end-uses

GWP: ~9 compared to HFC-245fa: 1030

MPHE RefAC, solvent cleaning aerosols and 

adhesives/coatings

GWP <3 compared to alternatives: 0-3500

October 2014 July 2015

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July 2015: Change of Status Rule 

• HFC-125 - January 2016

• HFC-227ea & blends - July 20, 2016

• HFC-134a - July 20, 2016/January 1, 2018

Aerosols

• HFC-134a in New Light-Duty Systems - MY 2021

• HCFC & HFC Containing Blends in New Light-Duty 

Systems - MY 2017

Motor Vehicle Air 

Conditioning

• New Supermarket Systems - January 2017

• New Remote Condensing Units - January 2018

• New Vending Machines - January 2019

• New Stand-Alone Units (small medium-temp, large 

medium-temp, low-temp)- January 2019/January 2020

• Retrofitted Retail Food Refrig Equipment and Vending 

Machines - July 20, 2016

Retail Food Refrigeration 

& Vending Machines

• All End-Uses, Except Rigid PU Spray Foam-Various dates 

between January 2017-January 2021

Foams
Some Key Principles Guiding Our Thinking

 SNAP rules will continue to consider individual end-uses

 No across the board GWP cut offs 

 No prohibition on HFCs as a whole, or in any one sector

 New HFCs or HFC blends may be listed if risk not greater 

than other available substitutes 

 Recognition that timing is a critical dimension and that each 

end use has unique considerations 

 Status change actions will be issued through notice and 

comment rulemaking

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Potential Listings Proposals 

 EPA seeking stakeholder input on listings that could include:

 Acceptable alternatives with use conditions

 Use conditions would mitigate risks, e.g., flammability, exposure limits

 Fire suppression: e.g., streaming agent for aviation

 MVAC: HFO-1234yf acceptable for Medium Duty Passenger Vans and Heavy Duty 

pickup trucks

 Other refrigeration & air conditioning end-uses for flammable and highly flammable 

refrigerants

 Unacceptable alternatives

 Where risks cannot be mitigated sufficiently, e.g., flammability, toxicity, air quality 

impacts, climate

 Certain HC and HC blends for stationary AC retrofits and MVAC systems 

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Change of Status EPA is Considering

 Change of listing status from acceptable to unacceptable

 EPA thinking potentially later transition dates than in July 20th final rule

 End-uses based on stakeholder comments and EPA analysis

 Sectors and end-uses where safer alternatives may be available

 Refrigeration and A/C

 Chillers: e.g., HFC-134a, R-407C, R-410A

 Refrigerated food processing and dispensing: e.g., HFC-134a, R-404A, R-507A

 Household refrigerators and freezers: e.g., HFC-134a 

 Cold storage warehouse: e.g., HFC-134a, R-407C, R-404A, R-507A

 MVAC: HCFC/HFC blends retrofit Light Duty vehicles 

 Foam: e.g., HFC-134a, HFC-245fa, HFC-365mfc, HFC-227ea in rigid PU spray 

foam; methylene chloride

 Fire suppression: e.g., PFCs, SF6, HFC-23

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New Petitions Related to Fire 

Suppression

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 NRDC & IGSD

 Remove HFC-23 from the list of acceptable substitutes for all new and 

retrofit industrial process refrigeration applications effective January 1, 

2017. Apply narrow use restrictions to HFC-23 in very low 

temperature refrigeration and total flooding fire suppression, allowing 

only for applications in which all other approved alternatives are 

physically inadequate effective January 1, 2017. 

 Remove sulfur hexafluoride (SF6), perfluorinated compounds (PFCs), 

HCFC-22 blends, HCFC-124, and trifluoroiodomethane (CF3I) from 

the list of acceptable substitutes in all flooding and streaming fire 

suppression applications effective January 1, 2019. 
New Petitions Related to Fire 

Suppression (cont’d)

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 EIA

• Remove SF6, HFC-23 and R-508A and R-508B (blends containing 

HFC-23) from the list of acceptable substitutes in all fire suppression 

and explosion protection applications, all new and retrofit industrial 

process refrigeration and very low temperature refrigeration 

applications, effective January 1, 2017. 

• Remove HFC-236fa, HFC-125, HFC-227ea and all remaining PFCs 

from the list of acceptable substitutes in fire protection and explosion 

protection for both total flooding and streaming applications 

effective January 1, 2019. Consider narrowed use restrictions for 

HFC-134a in these applications, with potential exemption of HFC227ea for specified applications where HFC-134a or low-GWP 

alternatives are not feasible for technical or safety reasons. 
Next Steps

 Continue to expand SNAP acceptable list

 Additional alternatives under evaluation

 Additional end-uses are being evaluated

 Continue to work with stakeholders

 E.g., Cold Food Chain Workshop in Montreal (November)

 Sector workshops and Stakeholder meetings 

 Develop next SNAP Notice for acceptable listings

 Develop next SNAP Rule to include alternatives that are:

 Acceptable with use conditions

 Unacceptable

 Change of status 

 Review new petitions

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Thank you!

Contact Information:

Margaret Sheppard

sheppard.margaret@epa.gov

(202) 343-9163

Bella Maranion

maranion.bella@epa.gov

(202) 343-9749

Chenise Farquharson, SNAP Coordinator

farquharson.chenise@epa.gov

(202) 564-7768