## 1 **United States** 

## ENVIRONMENTAL PROTECTION AGENCY **Washington, DC 20460 AGENCY USE**  **ONLY** OMB Control No.: 2060 - 0226 Expires: 06/30/201 1 

## SNAP INFORMATION NOTICE **For Significant New Alternatives** Date of Receipt: Date 90 Day Review Begins: Date Review Compl eted:
CBI Status: When completed send this form to: Via US Postal Service: Via Overnight Delivery Service: SNAP DOCUMENT CONTROL OFFICER SNAP D OCUMENT CONTROL OFFICER OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA U.S. EPA 1310 L STREET NW 1200 PENNSYLVANIA AVE NW 10 th F LOOR (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 o n 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 conf idential material. If no claims of confidentiality are made for the submission, all copies must be identical. manual provides instructions on submitting a SNAP not ice, asserting confidentiality claims, completing the notice form, sector-specific data requirements, and submitting test data and supplemental information. To facilitate Agency review of alternatives, this form must be filled out as completely as possibl e. Please provide all information requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailabl e. TYPE OF NOTICE (Check only one box) Select the appropriate box identifying the type of noti ce submitted: Manufacturer Submission: New alternative, Substance, or Formulation___________________________________________ 

# X Petition: New alternative, Substance, or Formulation__________________________________________________________ Petition: Revisi on of the Existing SNAP list__________________________________________________________________ Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________

## 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 w ill 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 t he substitute by checking the appropriate boxes:

ü Refrigeration and Air Conditioning ü Foam Blowing ___ ü Solvent Cleaning ___ ü Fire Extinguishing X and Explosion Prevention ü Sterilization ___ ü Aerosols ___ ü Adhesives, Coatings, and Inks ___ ü Tobacco Expansion ___ ü Pesticides ___ You may need additional copies of Part II if there are several manufacturing, processing, or use operations that you will describe in this not ice. 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 nece ssary. **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 

### X Yes No ___ Flammability Data 

### X Environmental Effects Data 

### X Environmental Fate Data Risk Assessments Test Data Not in the Possession/ Control of the Submitter Other Data 

### X 

## 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 b e treated as Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information c laimed as CBI will be treated in a manner consistent with 40 CFR Part 2, Subpart B. Failure to assert a claim of conf identiality 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 confid ential, you must nformation 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 Auth orized Representatives may have access to any i nformation 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 strat ospheric 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 confident ial business information as implemented by 40 CFR 2.301(h). Yes No ___ Yes No ___ Yes ___ No ___ Yes ___ No ___ Yes No ___

## 3 **Part I -**  **GENERAL INFORMATION** Section A- SUBMITTER IDENTIFICATION **1. (a) Person Submitting Notice (in U.S.)**

________________________________________________________________________________ ____________________ _______ __ Name of Authorized Official Title **J.G.L. Aaldering Managing Director** 

_________________________________________________________________________________________________________ ___ Company/Organization **D SP**  **A.nl BV**

**_________________________________ ____________________________________________________________________**  **______ _**  Mailing Address Telephone & Fax Numbers **DSPA.nl BV**  **Postbus 6572 T +31 (0) 24 37 89 581**  **TheNetherlands F +31 (0) 24 37 87 583**  **E -**  **mail. j.aaldering@dspa.nl Internet. http://www.dspa.nl**  **Chamber of Commerce. 39060741 VAT. No. NL 007677443B01**  **(b) Agent (if applicable) Jim Hoptry**  **VP -** **Operations** Name of Authorized Official Title **E4 Safety Products,LLC**

_____________________________________________________ ___ ________

___ _ Company/Organization **6767 Huntley Road Columbus , Ohio 43229 Phone (614) 431**  **- 5103**  **Fax (614) 839**  **- 9252**  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.) Joseph Kuesis**  **Director**

_______ _____________________________________________________________________________________________ ____ __ Name of Authorized Official Title

_______ _______________________________________________________________________________________________ ___ Company/Organization **E4 SAFETY PRODUCTS LLC 6767 HUNTLEY ROAD COLUMBUS,**  **OH 43229 USA**  **Phone (614) 431**  **- 5103**  **Fax (614) 839**  **- 9252** 

_____________________________________________________________________________________________________ ____ _ 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, April 1, 2011**  **Phone con versation and emails**  **April 20,2011 In -**  **person in Columbus, OH Margaret Sheppard**  Mark (X) if None ________________ Mark (X) this box if this page contains CBI __________ **6503 Nijmegen**

## 4 **Part I -**  **GENERAL INFORMATION (continued)** Section B - ALTERNATIVE IDENTIFICATION 1. Commercial/Trade name (s) of alternative: **OK, No CBI in this box. 1.) DSPA, 2.) Dry Sprinkler Powdered Aerosol, 3.) FIT 5, 4.) FIT, 5.) Fire Interruption Technology**  2. (a) Name of chemical(s) (preferably IUPAC nomenclature and/or process name. For blends, provide th e percent composition of each constituent
. (b) Chemical Abstracts Service (CAS) registry number and molecular formula. (c) For alternative processes and technologies describe the technology 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 attachm ent. If you have submitted a patent application but have not been granted one yet, indica te the date submitted and the expected time frame for a response. 

# CONFIDENTIAL 3. Generic chemical name (if chemical name of substitute is declared Confidential Business Information). **OK, No CBI in this box. Answer:**  **DSPA GENERATOR**

4. Specific End - Use **OK, No CBI in this box.** (a) Describe each end - use that may be reasonably anticipated for the alternative. Be sure to provide a broad description (e.g. terpene - based s emi - 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. **Answer: DSPA generators are used for fire and explosion suppressio**  **n as a replacement for Halon 1301 Total Flooding Agents. DSPA mobile**  **generators (streaming)**  **are intended for use in ships and industrial buildings and by fire departments as a first action to suppress A, B, C and K Class fires in enclosed areas and as fixe**  **d installations in all industrial and commercial structures and in the transport sector (trains, trucks, cars, and ships) as a replacement or to augment current fire suppression systems already in**  **- place**  **for normally unoccupied spaces**  **.** (b) Identify the ODS and the quantity of substitute (if applicable) needed to replace it for each end use in pounds (replacement ratio). **Answer: NA. There are no Ozone depleting substances contained per the EPA**  **lists of all ozone -** **depleting substances (ODS) recognized by** **the Montreal Protocol including ODP and GWP.**

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# X

## 5 **Part I -**  **GENERAL INFORMATI ON (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, e **(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. 

# CONFIDENTIAL

**6. By** **- produc** **ts (a)**  Describe any by- products 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 by- products/ degradation products enter **(b)** Provide the CAS Registry Number if available. **(c)** Indicate where the by- product/degradation product is formed (e.g. during manufacturing, during use, etc.) and the amount or rate at which it is formed. 

# CONFIDENTIAL

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## X

## 6 **Part II -**  **ALTERNATIVE -** **SPECIFIC INFORMATION Section A** **- PHYSICAL AND CHEMICAL PRO**  **PERTIES** 1. Molecular weight 2. Physical state at 20°C 3. Melting point 4. Boiling point at 1 atm. Pressure 5. Specific gravity 6. Odorthreshold mg/m3 7. Solubility using solvent @ temperature 8. Solubility in water @ temperature 9. Partition coefficient Log Kow 

### Log K 10. Vapor pressure @ 20 ° C psi 11. Critical temperature 12. Critical Pressure psi 13. Are spectra attached? 14. Disassociation constant 1. Particle size distribution 16. Volatilization from soil
17. Volatilization from water 18. Viscosity @ 20 ° C 19. pH co ncentration 20. Thermal conductivity 21. Adsorption coeffi cient 22. Flammability limits (LFL, UFL) % vol 23. Flash point 24. Heat of combustion 25. Maximum pressure rise 26. Maximum rate of pressure rise 27. Other (specify) 28 . Provide any information on flammability concerns. For example, if a ny 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). 

# CONFIDENTIAL

.

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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. Answer: **NA. There are no Ozone depleting substances contained per the EPA lists of all ozone**  **- depleting substances**  **(ODS) recognized by the Montreal Protocol including ODP and GWP.** (b) Provide source of ODP or any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromin e loading potentials). Reference the source of this information and attach any supporting documentation. Answer: **Source: EPA website and EPA documents pertinent to all ODPs recognized by the Montreal Protocol and the EPA including ODP and GWP.** 

2. Global Warming Characteristics: oxide 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 th - X%) and results of any testing or modelling done (both theoretical and actual testing). (c) Provide source of GWP or any additional data on the GW P of the alternative, including the atmospheric lifetime, infrared absorption spectrum, and infrared absorption capacity. If the alternative (e.g. CO 2 captured from a stream of waste gas as a by product of fermentation). **Not Applicable**

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## Part II **- ALTERNATIVE**  **- SPECIFIC INFORMATION (Continued)**  **Section B -**  **ATMOSPHERIC INFORMATION**

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**Part II -**  **ALTERNATIVE -** **SPECIFIC INFORMATION (continued) Section C**  **- OTHER STATUTES AND STANDARDS**  1. Describe whether and how the alternative is regulated under other environmental regulatory sta tutes, 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 Substa nces 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 - base d or other numerical standards to which the alternative is subject under the above standards and regulations. **Not Applicable**

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 Enginee rs (ASHRAE), by which the substitute is evaluated. 

### NFPA 2010 **UL 2127, "Inert Gas Clean Agent Extinguishing System Units," ULC Subject C1500, "Aerosol Generating Fire Extinguishing System Units.**  **See Attachment B.112**

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## 9 **Part II -**  **ALTERNATIVE -** **SPECIFIC INFORMATION (continued) Section D**  **- COST AND AVAILABILITY OF THE ALTERNATIVE**  1. Estimate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installation costs associated with the alternative. 

# CONFIDENTIAL

2. Provide information on production of the substitute. Include estimates on: (a) Year substitute will be available if not currently produced. (b) Total pounds production per year (current figure). (c) Years to maximum market penetration. (d) Maximum total production per year at market saturation. (e) Estimated percentage of market at market saturation. 

# CONFIDENTIAL

3. Describe any new equipment and use p rofiles. 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 cost associated with the substitute o r alternative process. Include cost of equipment and/or any new materials, equipment lifetime, changes in labor and energy costs **. Not Applicable** **/ System does not require piping network** 

Mark (X) this box if this page contains CBI 

# X

## 10 **Part III -**  **R ELEASE 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 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). 

# CONFIDENTIAL
**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 substitute s). (c) Identify the points of release and/or exposure during the manufactu re 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). 

# CONF IDENTIAL

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# x

## 11 **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. **Answer: Due to automatic production the workers will not exposed to chemicals during transportation, installation or maintenance.**  (b) Describe any protective equipment and engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods). **Answer: The**  **production equipment and employees are qualified and meet all recent demands concerning**  **safe working.** (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas). **Answer: During manual processing the raw materials are solids** (d) Estimate average and maximum numbers of workers involved in each activity. **Answer: Maximum 2; average 1** (e) Estimate avera ge and maximum duration of activity for any worker, in terms of (1) hour/day and (2) days/year. **Answer: Maximum 12h/day and 360 days/year. Average: 8h/day and 240 days/year** (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal). **Answer: Contact pathway possible by inhalation**  (g) Estimate the average and high - end exposure concentrations (separated by a /), being sure to provide units of measure. **Answer: No exposure Note: No** **t a**  **US A**  **based manufacturing and No USA based manufacturi**  **ng facilities exist or are planned.**


## 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 hazard ous waste or wastewater effluent) at a site using the substitute (e.g. in products containing the substitute and processes using the substitute). **Answer: The generator consists of solid blocks that are not friable and are contained in rigid steel casing a nd unless**  **activated will not be normally released into the environment. The only time a release into the environment will occur is when a unit is activated to suppress an ongoing fire.**  (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 amou nt 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. **Answer: The release of aerosol is necessary to suppress the fire** (d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes. **Answer: Trace amounts of some gaseous by -**  **products are not covered under RCRA; these by -**  **products are negligible.** (e) Identify the appropriate number of sites expected to us e the substitute. **Answer :**  **DSPA generators are most suitable for extinguishing of Class A and Class B fire in normally unoccupied areas** (f) Provide information on recycling of the substitute. Describe any associated costs and equipment. **Answer: Recyc**  **ling is neither possible nor prac tical.** 

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## 12 **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 produ cts and/or processes): (a) Describe the activities in which workers may be exposed to chemicals. **Answer: Workers will not exposed to chemicals during transportation, installation or maintenance. The generator consists of solid blocks that are not fri**  **able and are contained in rigid steel casing in which workers can have no direct contact with the substitute**  (b) Describe any protective equipment or engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods). **Answer: Goggles or a cloth respirator maybe needed if the worker was in the room when the generator was activated,**  **otherwise, no equipment is needed.** (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas). **Answer: Dur ing manual processing the raw materials are solids**  (d) Estimate average and maximum numbers of workers involved in each activity. **Answer: Maximum 2; average 1** (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year. **Answer: Maximum 12h/day and 360 days/year. Average: 8h/day and 240 days/year** (f) Enter the contact pathway (e.g. ingestion, inhalation, dermal). **Answer: Contact pathway possible by inhalation** (g) Estimate the average and high - end exposure concentrations (separated by a /), being sure to provide units. **Answer: No exposure** 



## Section F **- CONSUMER EXPOSURE**  **No consumer applications at this time for a Halon substitute**

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## 13 **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. **Answer: No potential e xposure during manufacturing**  **.** (b) For each exposure point described in (a), identify the potentially exposed population (e.g. residents at the fenceline). **Answer: Not applicable** (c) Identify the contact pathway (e.g. ingestion, inhalation, derm al). **Answer: Not applicable** (d) Identify the exposure medium (e.g. air, water). **Answer: Not applicable** (e) Enter the exposure point concentration (mg/m 3 ). Provide (1) average and (2) high - end estimates. **Answer: Not applicable Not manufacture**  **d in the USA**

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## 14 **Part IV -**  **LIST OF ATTACHMENTS** List below any attachments that complete the responses to the questions on this form or that provide additional in formation that ready 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 continue d. Attach additional pages if necessary. Attachment Name Question # Number of Pages CBI **RU 2150310C1 Part**  **I; Section B; 2d**  **6 RU2153376C1**  **Part I; Section B; 2d**  **6 RU2164809C2**  **Part I; Section B; 2d**  **6 KIWA Nederland BV; DSPA Fire Protection System; Study on a**  **condensed aerosol 8 -**  **1 generator consisting of a solid aerosol forming compound and a cooling mechani**  **sm Part I; Section B;**  **5a 13**  **X Experimental Detection of Combustion Components of the Aerosol**  **Solid Media of the AGS. Part I; Section B; 6**  **4 X**  **MSDS DSPA Fixed Installation Generator Version 3.0 Part III, Section A**  **5 Comparison Chart ( DSPA compared to t**  **hree different suppression mediums)**  **Attachment B.111**  **1 Title 21**  **- Food and Drugs**  **Chapter I -**  **US Food and Drug Administration Department of Health and Human Services**  **Subchapter B -**  **Food for Human Consumption Attachments**  **B.112, B.112.1, B.112.2**  **3**

**DSPA Aer osol generator ULC witness tests**  **/ Hughes Associates Attachment B.113**  **21 X**  **Confidential Business Information Statement Attachment B.114**  **1 X**  **Live Specimen Test results / DSPA Aerosol Attachment B.115**  **5 X**  **BRE Global Test results Fire Suppression in a P rison Cell**  **Attachment B.116 30**  **X BRE Global**  **- A UKAS member lab, part of ILAC**  **Attachment B.117 2**  **Intertek -**  **UL 711(modified) rating and Fire testing of Fire extinguishers Attachment B.118**  **3 X**  **Answers to Incomplete SNAP submission dated: 06 -**  **16 -** **2011 Atta**  **chment B.119 9**  **X EPA Requested DSPA mobile system testimonials**  **Attachment B.120 2**  **Clarification of responses provided in the attachment to the revised submission**  **from 7/27/2011 Attachment B.121**  **Question A.1 1**  **Column s A**  **through F X**  **Clarification of responses provided in the attachment to the revised submission**  **from 7/27/2011 Attachment B.12**  **1 Question A.2**  **1 Column G X**  

### Quantity of agent needed to replace Halon 1211 in pounds **(lbs.) Attachment B.12**  **2 1**  **X**

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Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGs.

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Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGs.

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Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGs.

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Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGs.

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# Comparison chart **(Attachment B.111) (Comparing DSPA to three known mediums of fire suppression agents)** 

**D SPA**  **Inert gas Halon 1301**  **CO2 Environmental damage**  **None Low**  **Very high Average**  **Toxicity Evacuation**  **None NO**  **Low high** 

**YES Low**  **NO High**  **YES Volume**  **N/A >45%**  **5% 8**  **- 40%**  **Corrosion None**  **Low Above average**  **None**
**Concentration 50**  **gr/m3 550**  **- 950**  **gr/m 3**  **200 -**  **350 gr/m**  **3 700**  **- 1500gr/m**  **3**

## 56 **FDA (Attachment B.112)**  

## Title 21- Food and Drugs **Chapter I- US Food and Drug Administration Department of Health and Human Services**  **Subchapter B-Food for Human Consumption**
**PART 184 -- DIRECT FOOD SUBSTANCES AFFIRMED AS GENERALLY RECOGNIZED AS SAFE**

**Subpart B--Listing of Specific Substances Affirmed as GRAS**



### Sec. 184.1619 Potassium carbonate
. (a) Potassium carbonate (K2CO3, CAS Reg. No. 584-08-7) is produced by the following methods of manufacture: (1) By electrolysis of potassium chloride followed by exposing the resultant potassium to carbon dioxide; (2) By treating a solution of potassium hydroxide with excess carbon dioxide to produce potassium carbonate; (3) By treating a solution of potassium hydroxide with carbon dioxide to produce potassium bicarbonate, which is then heated to yield potassium carbonate. (b) The ingredient meets the specifications of the Food Chemicals Codex, 3d Ed. (1981), p. 240, which is incorporated by reference. Copies are available from the National Academy Press, 2101 Constitution Ave. NW., Washington, D.C. 20418, or available for inspection at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html. (c) In accordance with 184.1(b)(1), the ingredient is used in food with no limitation other than current good manufacturing practice. The affirmation of this ingredient as generally recognized as safe (GRAS) as a direct human food ingredient is based upon the following current good manufacturing practice conditions of use: (1) The ingredient is used in food as a flavoring agent and adjuvant as defined in 170.3(o)(12) of this chapter; nutrient supplement as defined in 170.3(o)(20) of this chapter; pH control agent as defined in 170.3(o)(23) of this chapter; and processing aid as defined in 170.3(o)(24) of this chapter. (2) The ingredient is used in food at levels not to exceed current good manufacturing practice. (d) Prior sanctions for this ingredient different from the uses established in this section do not exist or have been waived. [48 FR 52442, Nov. 18, 1983]

## 57 **FDA (Attachment B.112.1)**  

## Title 21- Food and Drugs **Chapter I- US Food and Drug Administration Department of Health and Human Services**  **Subchapter B-Food for Human Consumption**
**PART 184 -- DIRECT FOOD SUBSTANCES AFFIRMED AS GENERALLY RECOGNIZED AS SAFE**

**Subpart B--Listing of Specific Substances Affirmed as GRAS** 

### Sec. 184.1135 Ammonium bicarbonate. (a) Ammonium bicarbonate (NH4HCO3, CAS Reg. No. 1066-33-7) is prepared by reacting gaseous carbon dioxide with aqueous ammonia. Crystals of ammonium bicarbonate are precipitated from solution and subsequently washed and dried. (b) The ingredient meets the specifications of the Food Chemicals Codex, 3d Ed. (1981), p. 19, which is incorporated by reference. Copies are available from the National Academy Press, 2101 Constitution Ave. NW., Washington, DC 20418, or available for inspection at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html. (c) In accordance with 184.1(b)(1), the ingredient is used in food with no limitation other than current good manufacturing practice. The affirmation of this ingredient as generally recognized as safe (GRAS) as a direct human food ingredient is based upon the following current good manufacturing practice conditions of use: (1) The ingredient is used as a dough strengthener as defined in 170.3(o)(6) of this chapter; a leavening agent as defined in 170.3(o)(17) of this chapter; a pH control agent as defined in 170.3(o)(23) of this chapter; and a texturizer as defined in 170.3(o)(32) of this chapter. (2) The ingredient is used in food at levels not to exceed current good manufacturing practice. (d) Prior sanctions for this ingredient different from the uses established in this section do not exist or have been waived. [48 FR 52439, Nov. 18, 1983]

## 58 **FDA (Attachment B.112.2)**  

## Title 21- Food and Drugs **Chapter I- US Food and Drug Administration Department of Health and Human Services**  **Subchapter B-Food for Human Consumption**
**PART 184 -- DIRECT FOOD SUBSTANCES AFFIRMED AS GENERALLY RECOGNIZED AS SAFE**

**Subpart B--Listing of Specific Substances Affirmed as GRAS** 

### Sec. 184.1613 Potassium bicarbonate. (a) Potassium bicarbonate (KHCO3, CAS Reg. No. 298-14-6) is made by the following processes: (1) By treating a solution of potassium hydroxide with carbon dioxide; (2) By treating a solution of potassium carbonate with carbon dioxide. (b) The ingredient meets the specifications of the Food Chemicals Codex, 3d Ed. (1981), p. 239, which is incorporated by reference. Copies are available from the National Academy Press, 2101 Constitution Ave. NW., Washington, DC 20418, or available for inspection at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html. (c) In accordance with 184.1(b)(1), the ingredient is used in food with no limitation other than current good manufacturing practice. The affirmation of this ingredient as generally recognized as safe (GRAS) as a direct human food ingredient is based upon the following current good manufacturing practice conditions of use: (1) The ingredient is used as a formulation aid as defined in 170.3(o)(14) of this chapter; nutrient supplement as defined in 170.3(o)(20) of this chapter; pH control agent as defined in 170.3(o)(23) of this chapter; and processing aid as defined in 170.3(o)(24) of this chapter. (2) The ingredient is used in food at levels not to exceed current good manufacturing practice. (d) Prior sanctions for this ingredient different from the uses established in this section do not exist or have been waived. [48 FR 52442, Nov. 18, 1983]

## 59 **DSPA AEROSOL GENERATOR ULC WITNESS TESTS**

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## 78 **DSPA Aerosol Generator ULC Witness Tests**

## 79 **(Attachment B.114) Claim of Confidential Business Information**  **All sections bracketed in RED are considered to be Confidential Business Information. Part 1- General Information**  **Section B- Alternative Identification 1.) The information contained within contains company trademarks and copyrights.**  **2.) Chemical composition is considered a patented formula and proprietary intellectual property. This information is not for public exposure as it would damage the business**  **Should it become public knowledge and be copied. 5A.) Private company test results, not for public dissemination.**  **6.) Chemical composition is considered a patented formula and proprietary intellectual property. This information is not for public exposure as it would damage the business**  **should it become public knowledge and be copied 6c.) Chemical composition is considered a patented formula and proprietary**  **intellectual property. This information is not for public exposure as it would damage the business should it become public knowledge and be copied**  **Part II Alternative specific information Section A Physical and Chemical properties**  **1.) The physical and chemical properties of the product are patented and a proprietary company formula. The characteristics and properties of the formula are also**  **considered proprietary and company intellectual property. Section D- Cost and Availability of the Alternative.**  **1.) Any information pertaining to cost , manufacturing, sales and marketing are to be considered private company information and strictly confidential.**  **Part III Release and Exposure Section A Toxicity and Hazard information**  

## Chemical composition is considered a patented formula and proprietary **intellectual property. This information is not for public exposure as it would damage the business**  **Attachments- Company proprietary test results, not for public dissemination**  **KIWA Nederland BV; DSPA Fire Protection System; Study on a condensed aerosol 8 -**  **1 generator consisting of a solid aeroso**  **l forming compound and a cooling mechanism Part I; Section B; 5a**  **Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGS. Part I; Section B; 6**  **DSPA Aerosol generator ULC witness tests / Hughes Associates Attachment B.113**  **Co nfidential Business Information Statement**  **Attachment B.114 Live Specimen Test results / DSPA Aerosol**  **Attachment B.115 Live Specimen Test results / DSPA Aerosol**  **Attachment B.115 BRE Global Test results Fire Suppression in a Prison Cell**  **Attachment B.1 16**  **BRE Global -**  **A UKAS member lab, part of ILAC Attachment B.117**  **Intertek -**  **UL 711(modified) rating and Fire testing of Fire extinguishers Attachment B.118** 

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## BRE GLOBAL, A MEMBER OF UKAS 

# United Kingdom Accreditation Service **ILAC - the International Laboratory Accreditation Cooperation - is an international cooperation of laboratory and inspection accreditation bodies formed more than 30 years**  **ago to help remove technical barriers to trade. Accreditation allows people to make an informed decision when selecting a laboratory, as it**  **demonstrates competence, impartiality and capability. It helps to underpin the credibility and performance of goods and services.**  **Accreditation bodies around the world, which have been evaluated by peers as competent, have signed an arrangement that enhances the acceptance of products and services across**  **national borders. The purpose of this arrangement, the ILAC Arrangement, is to create an international framework to support international trade through the removal of technical**  **barriers. laboratory and inspection accreditation bodies representing**  **more than 70 economies and regional organizations. The ultimate aim of the ILAC Arrangement is the increased use and acceptance by industry as**  **well as regulators of the results from accredited laboratories and inspection bodies, including results from laboratories in other countries. In this way, the free-trade goal of 'product**  **tested once and accepted everywhere' can be realized. ILAC provides a focus for:**  **Developing and harmonizing laboratory and inspection accreditation practices Promoting laboratory and inspection accreditation to industry, governments,**  **regulators and consumers Assisting and supporting developing accreditation systems**  **Global recognition of laboratories and inspection facilities via the ILAC Arrangement, thus facilitating acceptance of test, inspection and calibration data accompanying**  **goods across national borders The following are US signatory members to ILAC:**  **1.) American Association for Laboratory Accreditation (A2LA)**  

## 2.) **National Voluntary Laboratory Accreditation Program (NVLAP** 

## 3.) **International Accreditation Service, Inc (IAS)** 

## 4.) **ANSI-ASQ National Accreditation Board** 

## 5.) **Laboratory Accreditation Bureau (L-A-B)** 

## 6.) **Perry Johnson Laboratory Accreditation, Inc. (PJLA)** 

## 7.) **American Society of Crime Laboratory Directors/Laboratory Accreditation Board (ASCLD/LAB)** 

## 8.) **AIHA Laboratory Accreditation Program, LLC (AIHA-LAP, LLC)**

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# User Testimonials requested by the EPA **DSPA-5 Mobile systems Intense Heat Dramatically Reduced in Basement Fire**  March 2009 ROCKY MOUNTAIN HOUSE, AB A thermal imaging camera helped make up the mind of Deputy Fire Chief Rob Shanks of the Rocky Mountain House Fire Department. A temperature of 900° C threatened his crew as he contemplated an interior attack on a basement fire in an Alberta home. Choosing to deploy a DSPA-5 , Chief Shanks watched in amazement as the temperature dropped to 400° C approximately 20 seconds after the DSPA-5 dispersed its powder aerosol. The interior attach followed.
The fire was confined to the basement. The department estimates property savings at approximately $100,000. **Attic Fire is No Match for DSPA-5 Saving Owner $80,000 in Property Damage**  January 2009 SECHELT, BRITISH COLUMBIA Hot wood ashes in a bucket by the wall of a garage were enough to kindle a fire that quickly spread into the attic of the detached two-car structure. Fire Chief Bill Higgs quickly surveyed the situation and made the decision to deploy a DSPA-5 through an attic hatch opening. To his surprise, 15 to 20 seconds were enough to knock down the flames, leaving just a few hot that the $20,000 loss to the structure is one-fifth of the amount that could have been lost without the DSPA-5.

uation, the quick knock down of the fire by the DSPA-5 reduced our need to use water on the structure and allowed our crew and trucks to return to the station in less than two n in fire

## 129 **Attachment B.120** 

# New Fire Fighting Device Saves the Day and the Structure September 2008 HIGH RIVER, AL A four-unit apartment fire provided one of the first opportunities for Alberta firefighters to deploy DSPA-5 in a real-world setting. For the High River Volunteer Fire Department, the device more than proved its worth. Once introduced into the fire, the DSPA-5 quickly suppressed the flames and protected the other three - to 1,000 degrees to 300- It was the H The Fire Withinthat resulted in its receiving the first DSPA- The Fire Withinsupplying us with the DSPA-5, we were able to deploy it at a working structure fire. It saved the building but it also decreased fire and water January 2008 LEDUC, AB A temperature of -56° F (-49°C) had frozen the hydrant solid and the house on fire outside Edmonton, Alberta looked like a sure loss. The same fate seemed to await a nearby RV and house. Leduc firefighter Troy Mutch elected to use a DSPA-5 to see if he could buy time until a truck arrived. Mutch later recalled that the DSPA-5 pulled the fire back into the house for almost fifteen minutes, creating time enough for the truck to arrive and tamp out the last of the fire. would have spread to the RV and adjacent house. Thanks to the DSPA-5, there was no damage to either.

## 130 **Attachment B.121** Clarification of responses provided in the attachment to the revised submission Q-A.1

## 131 **Attachment B.122** Quantity of agent needed to replace Halon 1211 in pounds (lbs.)