September 27, 2011

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Significant New Alternatives Policy Program

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 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 suppression 

and explosion protection sector (EPA 1994) (hereinafter referred to as the Background Document). This 

risk screen discusses the potential 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 

Formulaa

CAS No. Formulation (by Weight Percent)

Firebane® 1170 Firebane® 1179

a N/A = not available.
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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: General 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 agents in portable fire 

extinguishers. However, adequate ventilation should be in place, appropriate personal 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 substitutes 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) Standard 10 be followed.

3. Atmospheric Assessment

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

Firebane® formulations as streaming agents. 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® 1179 will be less damaging to the atmosphere than 

continued use of Halon 1211.

4. Occupational Exposure Assessment

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. 
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Table 2: Common Applications Types and FDA Approval Status of Firebane® 1170 and 

Firebane® 1179 Constituents

Constituent

Common 

Application 

Types

FDA Approval Statusa,b,c Associated Hazards

a FDA = U.S. Food and Drug Administration

b FDA approvals are subject to use restrictions. Please see the cited regulation 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 submission, 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 

food 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 2011c and GSL 2010). 

The 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 substitutes and by the submitter:

 Proper Level D or higher PPE be used during handling of the substitute (e.g., goggles, gloves);

 Adequate ventilation should be in place;

 All spills should be cleaned up immediately in accordance with good industrial hygiene 

practices; and

 Training 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® 1179.

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 proposed by the 

submitter, would further reduce the risk of occupational exposure during manufacture to both 

formulations of Firebane® (GSL 2011a and 2011b).
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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 food applications. To 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. It is 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 Assessment

Both formulations of Firebane® are not expected to pose significant risk to end-users when used as 

streaming agents 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 solutions that become gases 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 2011c 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 Assessment

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® 1179 are not expected to 

cause a significant threat to human health in the general population when used as streaming agents 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. Ambient Air

Firebane® 1170 and Firebane® 1179 are not expected to pose a significant threat to human health in the 

general population in ambient air concentrations. As noted previously, both Firebane® formulations are

composed entirely of compounds that are FDA-approved for use in food, of which some are also FDAclassified 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 
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nearby stream). After settling, cleanup would involve washing/rinsing of surfaces. Because of the high 

biological oxygen demand1(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 infrequent—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-use or at cleanup. 

Discharges of either Firebane® formulation at manufacture to publicly owned treatment works (POTWs) 

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 Analysis

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 51.000). However, some states also have 

regulations concerning exempted VOCs and the definition of a VOC, which could 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® 1179 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.3 Assuming 

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

Firebane® 1170 and Firebane® All-Weather 1179 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 1.5x10-5percent of the annual 

VOC emissions caused by fires,4or only about 5.6x10-7 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-based 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 release 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 (EPA 2008 and EPA 2011) and ICF assumptions.

5 Based on 2010 projections calculated using 2008 EPA annual VOC emissions data (EPA 2009) and ICF 

assumptions.
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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 4.4x10-4percent of annual VOC emissions 

caused by fires, or only about 1.6x10-5percent 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 considered 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 

June 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>