Fire Suppression Systems Association | 3601 E. Joppa Road | Baltimore, MD 21236 | Phone: 410-931-8100 | Phone: 410-931-8111 | www.fssa.net 

December 2, 2015 

DELIVERED VIA ELECTRONIC MAIL: McCarthy.gina@Epa.gov 

Administrator Gina A. McCarthy 

U.S. Environmental Protection Agency 

William Jefferson Clinton Building 

1200 Pennsylvania Avenue, N. W. 

Mail Code: 1101A 

Washington, DC 20460

SUBJECT: Change of Status of HFCs under Clean Air Act Section 612 (SNAP Program) 

Dear Administrator McCarthy: 

The Fire Suppression Systems Association (FSSA) is a not-for-profit trade association, drawing members domestic and 

internationally and is comprised of a blend of designer/installers, manufacturers, consultants, academics, and suppliers, 

working together to share ideas and strategies for the benefit of the fire suppression systems industry. 

The Fire Suppression Systems Association supports the United States Environmental Protection Agency (EPA) and its 

ongoing evaluation and adjustment of the list of acceptable alternatives maintained under the Significant New Alternatives 

Policy Program (SNAP). The SNAP Program has been, and continues to be, a very effective means to promote the proper 

use and application of alternatives to ozone depleting halons in fire protection. 

Recently EPA received petitions from the Natural Resources Defense Council (NRDC) and the Environmental Investigation 

Agency (EIA) to further restrict or remove various products with global warming potentials from the SNAP program. It 

should be noted that the fire protection sector is the source of only about 3% of the installed quantities of HFC gases. 

However, because these extinguishing agents are virtually non-emissive in non-fire situations, it is estimated that less than 

.4% of HFC emissions from all U.S. sources is from fire protection systems. As a percentage of all U.S. greenhouse 

gas emissions, HFC fire protection agents represent a miniscule 0.008%. Further, our industry has led the way in this 

field - introducing global codes of practice for containment and leak protection well in advance of any regulatory pressures. 

For example, see the Halon Alternatives Research Corporation (HARC) publications listed below: 

 HARC Code of Practice for Use of Recycled Halogenated Clean Agents (www.harc.org) 

 HARC Voluntary Code of Practice for the Reduction of Emissions of HFC & PFC Fire Protection Agents

(www.harc.org/vcopdocument.pdf) 

 Halon Recycling Corp. Code of Practice for Halon Reclaiming Companies (www.halon.org/pdfs/code/pdf). 

FSSA is a member of HARC and was heavily involved in developing and promulgating these codes of practice. FSSA has 

always supported effective codes and regulations that take into account the unique concerns of fire protection – the risk 

posed to life and property from fire events. 
 

Fire Suppression Systems Association | 3601 E. Joppa Road | Baltimore, MD 21236 | Phone: 410-931-8100 | Phone: 410-931-8111 | www.fssa.net 

Protecting People and Property – A Unique Challenge 

The fire protection industry fully supports the goal to minimize non-fire emissions of all fire protection agents. The 

overarching concern of our industry, however, remains the reduction of risk to people and property from the threat of fire 

and explosion with products and systems proven to be effective. Every fire protection scenario presents a unique challenge. 

Rooms have different shapes, different uses and contents, and even different atmospheric conditions and fire hazard threats. 

These factors all affect, from a scientific perspective, the choice of the right fire extinguishing agent. Therefore, it is vital 

that measures to reduce emissions do not prevent fire protection scientists and engineers from determining the most 

appropriate fire extinguishing system to use for each individual scenario based on a thorough risk assessment. 

The vast majority of FSSA members offer a range of fire protection solutions, including water systems, foam, water mist, 

carbon dioxide and inert gases. FSSA fire equipment installers seek to provide the best fire protection solution for each 

hazard from among their multiple options. Fire protection engineers and Authorities Having Jurisdiction (e.g., local or state 

fire marshals, code enforcement officials, insurers) make their recommendations based on which solution is the most 

appropriate in each given design circumstance. 

To restrict this choice through arbitrary regulation – such as these proposals submitted in the NRDC and EIA letters - would 

be to put health and safety at risk. We strongly recommend against regulatory measures constraining the ability of fire 

protection professionals to make effective, appropriate fire protection choices for the protection of lives and critical property. 

Specifically, for these reasons FSSA opposes the requests to delist or modify the SNAP approvals now in place for HFC23, HFC-125, HFC-236fa and HFC-227ea. 

Use Bans Have Proven to be Damaging to the Environment 

It is very clear that use bans are not justified or productive in the Fire Protection Sector. Use bans may also have the 

unintended effect of increasing emissions, as particular firefighting agents may become instantly worthless with no marketbased incentive to recycle or dispose of the agents properly. This was a noticeable consequence of the halon use bans in 

some countries and regions (not in the US) following the application of the Montreal Protocol. In the US and elsewhere 

around the globe, recycling of firefighting agents is a robust and active market, allowing material to hold market value

and thus flow to the most critical required applications. Use bans, as proposed by the petitioners, would likely remove the 

intrinsic value of installed extinguishing agents and accelerate the decommissioning and the potential for unwanted release 

of these materials to the atmosphere. 

Emissions are Rare, Measured and Reported 

Use of agents in fire protection is unique as emissions generally only occur in the event of a fire. Thus, as noted earlier, 

the sector is almost statistically non-emissive. This means that the incidence of fires (rather than production levels) is a 

better measure by which to determine emissions in our sector. This is clearly demonstrated in data gathered by the US HFC 

Emissions Estimating Program (HEEP) conducted by the Halon Alternatives Research Corporation. (See: 

www.harc.org/images/heepfinalreport10.pdf). HEEP data verifies that emissions remain at an extremely low, stable rate, 

even though the number of installed systems year over year increases. Again, instituting a ban on certain fire extinguishing 

agents would likely result in an increase in inadvertent atmospheric emissions due to loss of value and increased 

decommissioning and handling of installed systems, producing the exact opposite to the goals sought by the petitions. 
 

Fire Suppression Systems Association | 3601 E. Joppa Road | Baltimore, MD 21236 | Phone: 410-931-8100 | Phone: 410-931-8111 | www.fssa.net 

HFC-23 Considerations 

Both petitions call for limiting the use of HFC-23 in fire suppression and explosion protection applications. Already in the 

USA, HFC-23 is generally used in limited, highly specialized fire protection applications where typically no other 

technology is as effective. The key elements of HFC-23 driving these design applications are low temperature requirements 

and/or high design concentration requirements in occupied spaces. 

HFC-23, with a boiling point of -82 °C, lower that other gaseous technologies, provides system flow characteristics and low 

temperature distribution and extinguishing performance that is not feasible with other technologies. FSSA members 

typically apply these features to applications involving cold temperature archiving and storage and on mining equipment. 

Occupied areas requiring high concentrations of extinguishing agent for protection are also candidates for use of HFC-23 

due to its low toxicity thresholds. 

HFC-227ea, HFC-236fa and HFC-125 Considerations 

HFC-227ea, HFC-236fa and HFC-125 have been widely used in the USA in fire extinguishing systems and portable 

extinguishers for over 20 years as replacements for ozone depleting halons. The bank of installed systems is considerable. 

Banning or unnecessarily restricting the use of these agents for fire extinguishing purposes, would have a serious economic 

impact on users of these systems. Recharge of systems would no longer be feasible; the cylinders, pipe and associated 

system equipment would become scrap. Currently when a system owner no longer needs a system to protect his facility, 

the agent is reclaimed, recycled, and used for future fire protection. If use bans were implemented, such agent would 

become a liability with no market value and the chance of release of the agent to the atmosphere would be increased. 

Conclusion 

FSSA is proud of its long history of working in cooperation with the EPA and other interested parties in answering the 

challenges to fire protection and environmental concerns. The fire protection sector continues to need all fire suppression 

agents that are currently available for use in order to safely and effectively protect people and critical assets from fire. 

Unnecessary restrictions on the available options for use in fire suppression applications will increase the risk to people 

without providing a significant benefit to the environment, global warming or climate change. 

Respectfully submitted, 

FIRE SUPPRESSION SYSTEMS ASSOCIATION 

Crista LeGrand 

Executive Director 

cc: Cynthia Newberg, USEPA Chief, Alternatives and Emissions Reduction Branch, Office of Atmospheric Programs 

Bella Maranion, USEPA Program Analyst 

Margaret Sheppard, USEPA Environmental Scientist