### September 27, 2011 1 

## Significant New **Alternatives Policy Pr ogram**  **Fire Extinguishing and Explosion Prevention Sector Risk Screen**  **on Substitutes for Halon 1211 in Portable Fire Extinguishers**

**Substitute: Firebane®**  **1170 and Firebane®**  **1179**

**This risk screen does not**  **contain Clean Air Act (CAA) Confidential Business**  **Information (CBI) and, therefore, may be**  **disclosed to the public.**

**1. Introduction**  Ozone

- depleting substances (ODS) are being phased out of production in response to a series of diplomatic and legislative efforts that have taken place over the past two decades, including the Montreal Protocol and the Clean Air Act Amendments of 1990 (CAAA). The U.S. Environmental Protection Agency (EPA), as authorized by Section 612 of the CAAA, administers the Significant New Alternative s 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 availa ble in EPA's docket. The purpose of this risk screen is to supplement EPA’s Background Document on the fire suppression and explosion protection sector (EPA 1994) (hereinafter referred to as the Background Document). This risk screen discusses the potenti al human health and environmental risks posed by Firebane® 1170 or Firebane® 1179 when used as a streaming agent in portable fire extinguishers as a replacement for Halon 1211. The reader is referred to the Background Document for the methodologies and assumptions used to conduct this risk screen. Table 1 presents the composition of the proposed substitutes.

**Table 1**  **: Composition of**  **Firebane® 1170 and**  **Firebane® 1179**  **Constituent Chemical** 

**Formula a**  **CAS No. Formulation (by Weight Percen**  **t) Firebane®**  **1170 Firebane®**  **1179**

a N/A = not available.

### September 27, 2011 2 Because the formulations of Firebane® 1170 and Firebane® 1179 are very similar and share the same human health and environmental risks, the remaining sections of this risk screen address both Firebane® 1170 and Firebane® 1179 (hereinafter collectively referred to as “both Firebane formulations”). Section 2 of this risk screen summarizes the results of the risk screen for the proposed substitutes listed in Table 1. The remainder of the risk screen is organized into the following sections:

 Section 3 : Atmospheric Assessment ;
 Section 4 : Occupational Exposure Assessment;
 Section 5 : End

-Use Exposure Assessment ;
 Section 6 : G eneral Population Exposure Assessment ;
 Section 7: Volatile Organic Compound Assessment; and
 Section 8: References

. 

### 2. **Summary**

**of Results** Both formulations of Firebane® are recommended for SNAP approval as streaming agent s in portable fire extinguishers. However, adequate ventilation should be in place , appropriate per sonal protective equipment (PPE) should be worn , and proper training administered for the manufacture, use, and disposal of this product. PPE should include safety goggles and protective gloves. Additionally, the risk screen indicates that the use of the proposed substitute s will be less harmful to the atmosphere than the continued use of Halon 1211. Risk to the general population is expected to be negligible provided that proper disposal procedures are used , and occupational exposure should not pose a problem if PPE is used. For applications of this and all other portable fire extinguishers, ICF recommends that the latest edition of National Fire Protection Agency (NFPA) S tandard 10 be followed

. 

### 3. **Atmospheric As**  **sessment** This section presents an assessment o f the potential risks to atmospheric integrity posed by the use of both Firebane® formulations as streaming agent s . According to the submitter , both Firebane® formulations contain no Class I or Class II ODS , nor any compounds with measured global warming potential (GWP). Therefore, the use of Firebane® 1170 and Firebane® 117 9 will be less damaging to the atmosphere than continued use of Halon 1211. 

### 4. **Occupational Exposure As**  **sessment** The potential for personnel exposure during manufacture, installation , and maintenance are examined in this section. The discharge scenarios discussed are assumed to occur accidentally and not as the result of a fire. In order to evaluate occupational exposure, ICF has evaluated the active compounds contained in both Firebane® formulations

. The common application types, FDA approval status, and associated hazards for these compounds are presented in Table 2

.

### September 27, 2011 3 **Table 2**  **: Common Applications Types and FDA Approval S**  **tatus of Firebane®**  **1170 and Firebane®**  **1179 Constituents**  **Constituent Common** 

**Application Types**  **FDA Approval Status a,b**  **,c Associated Hazards** 

a FDA = U.S. F ood and Drug Administration b FDA approvals are subject to use restrictions. Please see the cited reg ulation for further information. c GRAS = Generally Recognized as Safe
**4.1. Occupational Exposure during Manufacture**  Both formulations of Firebane **®** are not expected to pose a risk to workers during manufacture. Based on the information provided in the SNAP sub mission, occupational exposures during manufacture of both Firebane® formulations are expected to be limited to mixing of the chemicals and filling of extinguishers

. As summarized in the table above, all the constituents exhibit low toxicity and are commonly used in foo d applications . In addition, exposure to either of the Firebane® formulations is expected to be in the liquid form, with any vapor or gas exposures considered to be negligible (GSL 2011 c and GSL 2010 ). T he risk of exposure will be further minimized by following safety and precautionary measures . For measures designed to minimize the hazards associated with a specific constituent, as noted in Table 2, the constituent’s MSDS should be referenced. In order to minimize the risk associated with all of the constituents of either Firebane® formulation , EPA recommends the following in accordance with general procedures prescribed in the MSDS of the proposed substitute s and by the submitter:

 Proper Level D or higher PPE be used during handling of the su bstitute (e.g. , goggles, gloves);
 A dequate ventilation should be in place;
 All spills should be cleaned up immediately in accordance with good industrial hygiene practices; and
 T raining for safe handling procedures should be provided to all employees that would be likely to handle containers of or extinguishing units filled with Firebane® 1170 or Firebane® 117 9

. Because of the minimal chance of worker exposure to the chemicals during the manufacturing process, the use of exposure controls and adherence to the appropriate occupational safety guidelines as mentioned above, are sufficient to ensure that the manufacture of both formulations of Firebane® does not pose a risk to human health. In addition, an automated system for charging the extinguishers, as prop osed by the submitter, would further reduce the risk of occupational exposure during manufacture to both formulations of Firebane® (GSL 2011a and 2011b).

### September 27, 2011 4 **4.2. Occupational Exposure during Installation and Maintenance**  Both Firebane® formulations are not expected to pose a significant risk to personnel during installation and maintenance activities. During the installation or maintenance of either of the Firebane® formulations , inadvertent discharge may occur. Oxygen displacement during discharge of either Firebane® formulation is considered to be negligible, and therefore not a concern during inadvertent discharge (GSL 2011a and GSL 2011b). In addition , as noted above, all the constituents exhibit low toxicity and are commonly used in foo d applications

. T o ensure that the potential for exposure during installation and maintenance are further minimized, it is recommended that all personnel involved in the installation and maintenance of either of the Firebane® formulations adhere to safety guidelines , as mentioned previously in Section 4.1

. Itis recommended that the safe handling training also focus on the prevention of an inadvertent discharge. In case of an inadvertent discharge, workers should immediately follow the instructions listed in the MSDS for Firebane® 1170 or Firebane® 1179

. 

### 5. **End -**  **Use Exposure A ssessment**  Both formulations of Firebane® are not expected to pose significant risk to end

-users when used as streaming agent s in portable fire extinguishers. The primary health concern for both Firebane® formulations at the end

-use is exposure to the post

- activation discharge products. Both formulations of Firebane® are stored as aqueous solution s that become gas es upon introduction to fire (GSL 2011c and GSL 2010). Inhalation of the Firebane® 1170 or Firebane® 1179 gas vapors may cause mild irritation to the upper respiratory track; chronic ingestion will cause gastrointestinal irritation; and eye exposure may cause mild irritation (GSL 2011 c and GSL 2010 ). In case of exposure, individuals should follow the instructions prescribed in the proposed substitutes ’ MSDS . To minimize risk of exposure and irritation, EPA recommends that individuals follow the precautionary measures described in Section 4.1

. 

### 6. **General Population Exposure**  **As sessment**  This section screens potential risks to the general population from exposure to ambient air releases of both Firebane® formulations and its constituents. Firebane **®** 1170 and Firebane **®** 11 79 are not expected to cause a significant threat to human health in the general population when used as streaming agent s in portable fire extinguishers. The only consumer exposure to either Firebane **®** formulation will be during discharge of fire extinguishers in occupied spaces. Firefighters and other end

-users exposed to either Firebane **®** formulation during release should wear appropriate PPE, including goggles and gloves. Individuals should follow the precautionary measures described in the proposed substitutes’ MSDS and Section 4.1 of this risk screen . When the recommended safety precautions are followed, no significant adverse health effects are expected. **6.1. Am**  **bient A ir**  Firebane® 1170 and Firebane® 1179 are not expected to pose a significant threat to human health in the general population in ambient air concentrations. A s noted previously, both Firebane® formulations are composed entirely of compounds that are FDA

- approved for use in food, of which some are also FDA

classified as GRAS . Therefore, both Firebane® formulations are not expected to be a safety concern for ambient air contamination. **6.2. Surface Water**  Both Firebane® formulations are not expected to pose a significant threat to human health or the environment , provided that proper disposal procedures are followed . As discussed in the Background Document, the physicochemical properties of the majority of halon substitutes make it unlikely that the substitutes would be released to surface water as a result of use. In the case of both Firebane ® formulations , it is expected that all of the constituents would rapidly aerosolize during expulsion from the container and then settle as a liquid film on surfaces (as opposed to becoming airborne and settling on a

### September 27, 2011 5 nearby stream) . After settling, cleanup would involve washing/rinsing of surfaces

. Because of the high biological oxygen demand 1 ( BOD ) associated with each Firebane® formulation, it is recommended that discharges of either Firebane® formulation not be released to waterways. Further, it is recommended that during cleanup, discharges of both Firebane® formulations be collected (e.g., mopped) and contained in sealed containers and then disposed of in accordance with local, state, and federal requirements. Training for safe disposal procedures should also be provided to all employees that would be likely to dispose of either Firebane® formulation at cleanup. In addition, the use of an extinguisher is expected to be infrequent (i.e., in case of a fire emergency), and therefore discharges would be inf requent

— with proper procedures for cleanup in place, there is a very limited cause for concern. Therefore, EPA believes that when the recommended disposal procedures are followed, both Firebane® formulations do not pose a significant threat to human health or the environment during end

-us e or at cleanup

. Discharges of either Firebane® formulation at manufacture to publicly owned treatment works (POTW s ) are subject to local , state, and federal restrictions. Such restrictions include a limit on the BOD levels of industrial wastewater. 2 EPA believes that regulatory requirements on discharges that result from manufacture are sufficient to control human health and environmental risks associated with the manufacturing operations of both Firebane® formulations

. **6.3. Solid Waste**  No constituents of Firebane® 1179 are considered to be hazardous waste under EPA regulations implementing the Resource Conservation and Recovery Act

. During post
- activation cleanup procedures, cleanup residues should be disposed of in accordance with requirements appropriate for those materials. 

### 7. **Volatile Organic Compound A nal**  **ys is**  Of the constituents of both Firebane® formulations , only propylene glycol has not been exempted as a volatile organic compound (VOC) under the CAA (40 CFR 51.0 00 

### ). However, some states also have regulations concerning exempted VOCs and the definition of a VOC, which c ould exclude propylene glycol from consideration as a VOC



### . In general, VOC emissions should be sufficiently controlled through regulations and standard industry practices. VOC emissions from the production of portable extinguishers charged with Firebane **®** 1170 or Firebane **®** 11 79 are controlled through standard industry practices, and as such, emissions from manufacture of units are likely to be minimal

. U sing 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. 3 Assuming this release rat e, an assessment was performed to compare the annual VOC emissions from use of Firebane **®** 11 70 and Firebane **®** All

-Weather 11 79 in portable extinguishers produced in one year to other anthropogenic sources of VOC emissions. Assuming the submitter’s current production plans, the amount of VOCs that would be emitted would be approximately equal to 1.5x10 - 5 percent of the annual VOC emissions caused by fires, 4 or only about 5.6 x10 - 7 percent of all annual anthropogenic VOC emissions

. 5 Moreover, even if all of the Firebane® 1170 and Firebane® 1179 produced by Global Safety

1 BOD is the amount of oxygen consumed by microorganisms as they decompose organic materials in water. 2 POTWs establish BOD limits in order to prevent overloading of the water treatment system, which could potentially cause the organism

-ba sed treatment system to fail if oxygen levels become too low for aerobic respiration. 3 The total annual release rate of 3.5% for portable extinguishers was determined using the average annual leak rate (2%) , annual discharge rate (1.5%) , and annual releas e during training (0%) from the Vintaging Model (v4.4_3.23.11). 4 Based on 2010 projections calculated using 2008 EPA annual VOC emissions data for residential wood burning and agricultural field burning (E PA 2008 and EPA 2011 ) and ICF assumptions. 5 Base d on 2010 projections calculated using 2008 EPA annual VOC emissions data (EPA 2009) and ICF assumptions.

### September 27, 2011 6 Labs in one year were to be released to the atmosphere over the course of the year (extremely unlikely), the resulting annual VOC emissions would be approximately 4.4x10 - 4 percent of annual VOC emissions caused by fires, or only about 1 .6 x10 - 5 percent of all annual anthropogenic VOC emissions. As these emissions of Firebane® are several orders of magnitude less than other anthropogenic emissions, the environmental impacts of these VOCs are not c onsidered a threat. 

### 8. **References** EPA 1994. "Risk Screen on the Use of Substitutes for Class I Ozone

- depleting Substances: Fire Extinguishing and Protection (Halon Substitutes)," U.S. Environmental Protection Agency, March 1994. EPA 2008. 2005 National Emissions Inventory Data & Documentation. Inventory Data: 42 Category Summaries. Last updated 6 July 2010. Accessed 20 September 11. Available online at <http://www.epa.gov/ttn/chief/net/2005inventory.html#inventorydata>. EPA 2009. National Emissions Inventory (NEI) Air Pollutant Emissions Trends Data and Estimation Procedures. 1970

– 2008 Average Annual Emissions, All Criteria Pollutants . Last updated 09 Ju ne 2009. Accessed 20 September 11. Available online at <http://www.epa.gov/ttn/chief/trends/index.html#tables>. EPA 2011. The National Emissions Inventory. 2008 National Inventory Data. Last updated 19 July 11. Accessed 20 September 11. Available online at <http://www.epa.gov/ttn/chief/net/2008inventory.html>. Global Safety Labs, Inc. 2011a. “Response to Incomplete SNAP Submission for Firebane® 1170.” April 4, 2011. Global Safety Labs, Inc. 2011b. “Response to Incomplete SNAP Submission for Firebane® 1179.” April 4, 2011. Global Safety Labs, Inc. 2011c. SNAP Submission to EPA for Firebane® 1170. February 7, 2011. Global Safety Labs, Inc. 2010. SNAP Submission to EPA for Firebane® 1179. December 23, 2010. NFPA. 2010. NFPA 10: Standard for Portable Fire Extinguishers. 2010 Edition. Available at <http://www.nfpa.org/catalog/product.asp?pid=1010&order%5Fsrc=B484>