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Significant New Alternatives Policy Program

Fire Extinguishing and Explosion Prevention Sector

Risk Screen on Substitute for Halon 1211 as a Streaming Agent in Portable Fire 

Extinguishers

Substitute: C7 Fluoroketone (C7 FK or FK-6-1-14)

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 and explosion 

suppression sector (EPA 1994) (hereinafter referred to as the Background Document). This risk screen 

evaluates the potential use of C7 Fluoroketone (also referred to as FK-6-1-14 or C7 FK) as a substitute for 

Halon 1211 to be used as a streaming agent in portable fire extinguishers. The proposed substitute is 

anticipated to be used for Classes A (ordinary combustibles), B (flammable liquids and gases), and C 

(electrical) fires, pending UL approval. The reader is referred to the Background Document for the 

methodologies and assumptions used to conduct the risk screen. Table 1 presents the composition of the 

proposed substitute. 

Table 1. Composition of C7 FK

Constituent Chemical Formula CAS Number Percent of Total

(by weight)a

3-Pentanone,1,1,1,2,4,5,5,5-octafluoro-2,4-

bis(trifluoromethyl) C7F14O 813-44-5 55-65%

3-Hexanone,1,1,1,2,4,4,5,5,6,6,6-undecafluoro2-(trifluoromethyl) C7F14O 813-45-6 35-45%

The potential risks associated with use of substitutes in streaming agents for portable fire extinguishers

have been examined at length in the Background Document. The reader is referred to this reference for a 

detailed discussion of the methodologies used to conduct this risk screen. Occupational exposure 

modeling was performed to ensure that use of the proposed substitute did not pose unacceptable risk to 
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workers during equipment manufacture. Modeling was performed at the end-use to ensure that potential 

releases of the proposed substitute did not pose unacceptable risk to fire fighters and other end-users in 

locations where the fire extinguishers are in use. Lastly, general population exposure modeling was 

performed to ensure that the proposed substitute would not pose unacceptable risk to the population at 

large. 

Section 2 of this report 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

 Section 9: References

2. SUMMARY OF RESULTS

Use of C7 FK in portable fire extinguishers is not expected to pose a significant risk to atmospheric 

integrity or to the health of the general population, and is therefore recommended for SNAP approval for 

the proposed end use. Given that proper training will be given to personnel and that appropriate personal 

protective equipment (PPE) (Occupational Safety & Health Administration [OSHA] Category D or 

higher) and proper procedures according to the MSDS (including provisions of adequate ventilation) will 

be used during manufacturing, end-use, and disposal, no risk to workers, end-users, or the general 

population is anticipated. In addition, this risk screen indicates that the use of the proposed substitute will 

be less harmful to the atmosphere than the continued use of Halon 1211, HCFC-123, or HFC-236fa. For 

applications of this and all other fire suppression equipment, ICF recommends that use be in accordance 

with the latest edition of the National Fire Protection Association (NFPA) 10 Standard for Portable Fire 

Extinguishers. 

3. ATMOSPHERIC ASSESSMENT

This section presents an assessment of the potential risks to atmospheric integrity posed by the use of C7 

FK as a streaming agent. The ODP, GWP, and ALT of the proposed substitute and replacements are 

presented in Table 2. The proposed substitute is substantially less harmful to the ozone layer and has less 

climate impact than Halon 1211. In addition, its low GWP relative to HCFCs and HFCs will provide 

environmental benefit compared to other available options in streaming applications. 

Table 2. Atmospheric Impacts of C7 FK Compared to Halon 1211 and Other Intended Non-ODS

Replacements

Streaming Agent ODP GWP ALT (years)

C7 FK 0

a 1a 7 daysa

Halon 1211 7.1b 1,890b 16b

HFC-236fa 0 9,650c 240c

HCFC-123 0.02b 77b 1.3b

a 3M SNAP Submission 2010 

b Available at: http://www.epa.gov/ozone/ods.html.

c Available at: http://www.epa.gov/ozone/geninfo/gwps.html
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4. POTENTIAL HEALTH EFFECTS

According to the MSDS, exposure to C7 FK above the exposure guideline may result in potentially 

harmful health effects. Inhalation of C7 FK could cause respiratory tract irritation and symptoms may 

include cough, sneezing, nasal discharge, headache, hoarseness, and nose and throat pain. If thermal 

decomposition of the compound occurs, inhalation of the decomposition products may also be harmful. If 

over exposure due to inhalation of C7 FK above the exposure guideline occurs, person(s) should be 

immediately removed and exposed to fresh air and medical attention should be sought if the above

mentioned symptoms develop. Contact with the eyes and/or skin during product use is not expected to 

result in significant irritation. Ingestion of C7 FK is not expected to cause health effects, and there is no 

anticipated need for first aid if ingestion of C7 FK occurs (3M 2011b). EPA’s review of the 

environmental and human health impacts of this proposed substitute is contained in the public docket for 

this decision.

When good industrial hygiene practices and the PPE and engineering control (e.g., ventilation) 

recommendations outlined in the MSDS for C7 FK, as summarized in Sections 5 and 6 of this risk screen,

are followed, these potential health effects are unlikely to occur.

5. OCCUPATIONAL EXPOSURE ASSESSMENT

C7 FK is manufactured in a closed system. According to the submitter, workers may be exposed to C7 

FK during the manufacture of the product during direct line filling of drums/containers, as well as during 

installation of the fire extinguishing systems (e.g., accidental discharge). The potential for personnel 

exposure during manufacture and installation and maintenance are examined in this section. ICF’s

estimated acceptable exposure limit (AEL) for C7 FK is 225 ppm (3368 mg/m

3

) averaged over an 8-hour 

time period (8-hour TWA) (ICF 2011). The AEL was derived using an interspecies uncertainty factor of 3 

and an uncertainty factor of 3 to compensate for uncertainty in the database – i.e., use of a 28-day, rather 

than a 90-day subchronic or 2-year chronic study to develop the 8-hour AEL. The reader is referred to 

Appendix A for a detailed explanation of the development of the AEL. The substitute’s manufacturer 

also recommends an AEL of 225 ppm (8-hr TWA) for C7 FK.

5.1 Occupational Exposure during Manufacture

For small to moderate spills of C7 FK (< 100 kg), it is recommended that the area in which the spill 

occurs be cleared of personnel until ambient concentrations return to acceptable levels. The submitter 

modeled two scenarios to determine the appropriate reentry time in case of a spill. In both scenarios, the 

ventilation rate was fixed at 6 air changes per hour (ACH) and 4.5 kg of C7 FK was released to simulate a 

small leak (see Table 3) (3M 2011a).

Table 3. C7 FK Spill Monitoring

Scenario Room Volume Peak Concentration Reentry Time

100 m3 2,200 ppm 28 min

1000 m3 225 ppm Immediate

It is recommended that each manufacturing facility has the appropriate staff and resources to design the 

appropriate working environment and adhere to reentry time guidance following a leak of the substance. 

The submitter concludes that factory production of the C7 FK using the same procedures as for C6 FK 

would result in short term worker exposure of less than 1 ppm for C7 FK. In addition, personal protective 

equipment (PPE), as suggested in the MSDS, is recommended for workers dealing with C7 FK in 

industrial settings where ventilation is inadequate to control exposure below the recommended exposure 
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guideline. For manufacture of fire extinguisher systems, the amount of proposed substitute released 

during leak testing has been estimated to be less than 30 grams per year (3M 2011a).

5.2 Occupational Exposure during Installation and Maintenance

To address the potential employee exposure to C7 FK for larger amounts of the proposed substitute, the 

submitter provided surrogate air monitoring studies for a C6 fluorinated ketone (C6 FK or NovecTM 1230)

analog. Air concentrations found during the air monitoring studies with C6 FK (described below) would 

be a conservative estimate of air concentrations of C7 FK, due to the higher boiling point and lower vapor 

pressure of C7 FK (see Table 4) (3M NovecTM 1230 SNAP Submission, 2001). 

Table 4. Boiling Point and Vapor Pressure for C7 FK and C6 FK Analog

Parameter C7 FK Proposed Substitute C6 FK Analog

Boiling Point 74 C 49 C

Vapor Pressure 125 mmHg (at 20 C) 244 mmHg (at 20 C)

According to the submitter, monitoring was conducted in two scenarios to determine the concentration of 

C6 FK during packaging, servicing, and disposal operations, which are reflective of manufacturing 

conditions for either draining the reactor or draining to drums post purification as part of the filling 

process for fire extinguishing units. The first scenario was tote filling, and monitoring was conducted 

without local exhaust which resulted in an area TWA concentration of 60 ppm. The peak instantaneous 

concentration for this scenario was 300 ppm, which is above the recommended AEL of 225 ppm over an 

8 hour period; however, this scenario was modeled without the use of local exhaust. The second scenario, 

drum filling, was performed with local exhaust and resulted in personal TWA exposure of 1.3 ppm. Table 

5 shows the additional results of the air monitoring. 

Table 5. C6 FK Air Monitoring Results

Scenario Peak Concentration Area TWA Concentration

Tote Filling—no local 

exhaust 300 ppm 60 ppm

Drum Filling--with 

local exhaust 11.7 ppm 1.3 ppm

While the analysis performed by the submitter is intended for manufacturing and packaging of C7 FK for 

distribution, it is likely that similar exposure scenarios would exist during filling of streaming systems 

containing C7 FK. As such, certain precautions should be taken regarding the peak exposure values that 

may result if a spill occurs during filling and maintenance of these systems. Based on the submitter’s 

analysis, it is recommended to have adequate ventilation, such as that provided by local exhaust fans, in 

establishments where filling and maintenance activities for streaming systems are carried out. Filling 

operations should be performed in areas with additional exposure controls, including reduced fill drop 

height, slower fill rate, and smaller containers. The manufacturer has recommended use of OSHA 

Category D or higher PPE, such as safety goggles with side shields and neoprene, nitrile rubber, or 

polymer laminate gloves, for workers dealing with C7 FK in industrial settings. In addition, all spills 

should be cleaned up immediately in accordance with good industrial hygiene practices and the MSDS for 

C7 FK, and training for safe handling procedures should be provided to all employees that would be 

likely to handle the containers of C7 FK or portable extinguishing units filled with the material. 
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6. END-USE EXPOSURE ASSESSMENT

C7 FK is expected to be used as a streaming agent in portable fire extinguishers for the industrial, 

commercial, and military sectors. It is not intended for residential or direct consumer use. C7 FK is 

designed as a clean extinguishing agent that discharges as a vapor and can be removed through normal 

ventilation. 

According to OSHA (Hazard Communication Standard 29 CFR 1910.1200(f)(1)), all portable fire 

extinguishers must have a label identifying the material and issuing appropriate hazard warnings. 

Following discharge of a portable fire extinguishing unit containing C7 FK, fire fighters and other endusers are expected to follow the warnings on the label. If the extinguisher is discharged, it is expected that 

the room would be evacuated until ventilation systems reduce airborne concentrations of the C7 FK agent 

below the recommended occupational exposure limit. 

To give guidance to fire fighters and other end-users and to assess exposure and toxicity concerns 

associated with use of a proposed Halon 1211 substitute as a streaming agent, the submitter modeled two 

scenarios to determine the appropriate ventilation and reentry time after complete discharge of a C7 FK

portable extinguishing unit. The submitter compared the results of both scenarios to the 8-hour AEL for 

C7 FK (225 ppm) and reentry times were established. In both scenarios, the ventilation rate was fixed at 6 

air changes per hour (ACH) and 10 lbs (4.5 kg) of C7 FK, the full charge of a C7 FK extinguisher, was 

discharged (3M 2011a). The peak concentrations in both scenarios were greater than the AEL and 

recommended reentry times were established when the room concentration returned to levels below the 

AEL (see Table 6).

Table 6. C7 FK Discharge Monitoring

Scenario Room Volume Peak Concentration Reentry Time Exposure Limit

100 m3 3,000 ppm 26 min 225 ppm (8-hr AEL) 1000 m3 300 ppm 3 min

These reentry times were established using the 8-hour AEL. If the peak concentrations in the room for the 

two modeled scenarios were compared to a 5-minute acute AEL (21,600 ppm)1, reentry would be 

permitted much earlier. 

Though PPE is not required for incidental exposures that may occur during normal discharge of a portable 

unit due to C7 FK’s low acute toxicity, the use of PPE is recommended for fire fighters using C7 FK in 

accordance with the MSDS for C7 FK, including full protective equipment (Bunker Gear) and a selfcontained breathing apparatus (SCBA) to protect against the effects of thermal decomposition products of 

C7 FK (3M 2011b). In addition, use of C7 FK is subject to the requirements of other organizations 

including NFPA, Underwriters Laboratories, and OSHA. 

7. GENERAL POPULATION EXPOSURE ASSESSMENT

C7 FK is not expected to cause a significant risk to human health in the general population when used as a 

streaming agent in portable fire extinguishers, and it is not intended for residential or direct consumer use. 

The following sections discuss the potential effects of C7 FK on ambient air, surface water, and as solid 

waste. 

 

1 The 5-minute acute AEL was developed using the 8-hour AEL of 225 ppm for C7 FK (Alexeeff et al. 1999).
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7.1 Ambient Air

C7 FK is expected to degrade via direct photolysis. The formation of breakdown products is not 

considered to be a toxicological concern, and their formation is expected to contribute only miniscule 

amounts to ambient air or rainwater. Thus, use of C7 FK as a streaming agent is not expected to pose a 

risk to the general population.

7.2 Surface Water

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 C7 FK, the proposed substitute is insoluble in water and has a very high Henry’s Law 

Constant, meaning the compound readily volatilizes. Thus, it is expected that all of the constituents would 

rapidly vaporize during expulsion from the container and therefore would not be likely to settle or to lead 

to surface water contamination (3M 2010b).

7.3 Solid Waste

As discussed above, C7 FK will vaporize upon discharge. Therefore, use of this agent is not expected to 

generate solid waste. To the extent that solid materials are used in post-activation clean-up procedures, 

clean-up residues should be disposed of in accordance with the C7 FK MSDS. 

8. VOLATILE ORGANIC COMPOUND ASSESSMENT

C7 FK has not been exempted as a VOC under the CAA (40 CFR 51.000). VOC emissions should be 

sufficiently controlled through standard industry practices. VOC emissions from the production of 

portable extinguishers charged with C7 FK 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 training release rates) for 

portable extinguishers was calculated to be approximately 3.5% of extinguisher charge size.2 Assuming 

this release rate, an assessment was performed to compare the annual VOC emissions from use of C7 FK 

in portable extinguishers in one year to other anthropogenic sources of VOC emissions. Assuming the 

portion for streaming agent applications of the submitter’s maximum allowable annual production, only 

approximately 1.0x10-3percent of the annual VOC emissions caused by fires,

3

or only about 3.8x10-5

percent of all annual anthropogenic VOC emission sources would be released from the charged portable 

extinguishers.

4 Moreover, even if the entire portion for streaming agent applications of the allowable 

quantity of C7 FK produced by the submitter in one year was all released to the atmosphere (extremely 

unlikely), the resulting VOC emissions would be approximately equal to 3.0x10-2percent of annual VOC 

emissions caused by fires, or only about 1.1x10-3percent of all annual anthropogenic VOC emissions. As 

these emissions are several orders of magnitude less than other anthropogenic emissions, the 

environmental impacts of these VOCs are not considered a significant risk.

 

2 The average annual leak rate (3.5%) for streaming agents was approximated using data from the Vintaging Model 

(v4.4_3.23.11). 

3 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. 

4 Based on 2010 projections calculated using 2008 EPA annual VOC emissions data (EPA 2009) and ICF assumptions. 
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9. REFERENCES

3M 2001. SNAP Submission to EPA for Novec 1230. January 3, 2001.

3M 2010a. SNAP Addendum to EPA for C7 FK. February 22, 2010.

3M 2010b. P-10-135 – C7 FK (Fluoroketone) teleconference EPA/3M Summary. November 22, 2010.

3M 2011a. Response to Incomplete SNAP submission for Fluoroketone. February 17, 2011.

3M 2011b. Safety Data Sheet – L-20154 Development Material. Issued August 11, 2011.

Alexeeff, George V., John D. Budroe, James F. Collins, Richard H.F. Lam, David C. Lewis, Michael J. 

Lipsett, Melanie A. Marty, and Thomas R. Parker. 1999. “Determination of Acute Reference 

Exposure Levels for Airborne Toxicants.” Office of Environmental Health Hazard Assessment. 

March 1999.

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. Volatile Organic Compounds – National Summary of VOC Emissions. Last updated 04 

November 2009. Accessed 16 May 2011. Available at 

<http://www.epa.gov/air/emissions/voc.htm>.

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>.

ICF 2011. Determination of an Acceptable Exposure Limit for C7 Fluoroketone. May 2011. 
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Appendix A

Determination of an AEL for C7 Fluoroketone (C7 FK)

Recommended AEL: 225 ppm (8-hour)

Basis and Endpoints: NOAEL 3000 ppm for male rats 

Study: Sub acute (29-day) Inhalation Toxicity Study with MTDID 10800 in 

Rats

Protocol: 6 hours/day, 5 days/week for 4 weeks (whole body exposure)

Concentrations: 0; 3,000; 7,500; 15,000 ppm 

NOAEL: 3,000 ppm (males) (excluding peroxisomal proliferation) 

Uncertainty Factor: 10 (3 - interspecies extrapolation; 3 – use of a sub-acute study)

AEL 225 ppm (= 3,000 * 6 hours (exposure of rats)/8 hours (workday))* 

(1/10)

Derivation of a preliminary AEL for C7 FK relies on the reported NOAEL of 3,000 ppm for male Wistar 

rats from the 29-day inhalation study at exposure doses of 0, 3,000, 7,500, and 15,000 ppm (Muijser and 

Staal, 2008). The only exposure-related effects of note in male rats were peroxisomal proliferation in 

liver cells at all exposure concentrations, and a significant increase in hepatocellular hypertrophy, as well 

as significant increases in the number of total white blood cells, lymphocytes, and neutrophils at 7,500 

and 15,000 ppm. No other effects in males were found by histological examination. All the reported 

effects were found to be reversed in a separate group of recovery males who were held for 13-days post 

exposure. No exposure-related effects were noted in female rats at any concentration; thus the NOAEL 

for females was identified as 15,000 ppm. Peroxisomal proliferation is common in male rats which have 

been exposed to certain toxicants, and the effect has been debated within the risk assessment community 

with regard to predicting liver toxicity in humans (Keshava and Caldwell 2006; Melnick 2001). The 

study authors discounted the peroxisomal proliferation, and identified a NOAEL of 3,000 ppm based on 

other mild responses at the mid- and high concentrations. ICF agrees with this decision, particularly 

given the reversibility of the effects and given the similarity in the toxicity of C7 FK with the structurally 

similar C6 FK.

Compensation for 6 hour/day exposure for 5 days/week is accomplished by multiplying the AEL of 

3,000 ppm by a factor of 0.75 (6 hour study exposure/ 8 hour typical worker exposure) to obtain a Human 

Equivalent Concentration (HEC) of 2,250 ppm. An interspecies uncertainty factor of 3 is used to account 

for the pharmacodynamic differences between rats and humans. An additional uncertainty factor of 3 is 

recommended to compensate for use of a 29-day, rather than 90-day subchronic or 2-year chronic, study 

to develop the 8-hour AEL. The supporting toxicological data for C6 fluorinated ketone (C6 FK), which 

is structurally similar to C7 FK, precludes the need for an additional UF for the quality of the database. 

Division of the HEC by 10 (multiplicative value of uncertainty factors) produces a derived AEL for C7 

fluorinated ketone of 225 ppm. 
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References

Keshava N and JC Caldwell (2006) Key issues in the role of peroxisome proliferator-activated receptor 

agonism and cell signaling in trichloroethylene toxicity. Environ Health Perspect 114(9):1464-

1470.

Melnick RL (2001) Is peroxisome proliferation an obligatory precursor step in the carcinogenicity of di(2-

ethylhexyl)phthalate (DEHP)? Environ Health Perspect 109(5):437-442.

Muijser H. and Staal YCM. (2008) Sub-acute (29-day) inhalation toxicity study with MTDID 10800 in 

rats. TNO Quality of Life, The Netherlands, for 3M Company, St Paul, MN 17 December