September 23, 2011

1

Significant New Alternatives Policy Program

Fire Extinguishing and Explosion Prevention Sector

Risk Screen on Substitutes for Halon 1211 in Portable Fire Extinguishers

Substitute: Firebane® All-Weather 1115 and Firebane® 1115

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 few years, 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® AllWeather 1115 or Firebane® 1115 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 the risk screen. Table 1 presents the composition of the proposed 

substitutes. 

Table 1. Composition of Firebane® All-Weather 1115 and Firebane® 1115 

Constituent Chemical 

Formula CAS No.

Formulation

(by Weight Percent)

Firebane® 1115 Firebane® AllWeather 1115
September 23, 2011

2

Because the formulations of Firebane® All-Weather 1115 and Firebane® 1115 are very similar and share 

the same human health and environmental risks, the remaining sections of this risk screen address both 

Firebane® All-Weather 1115 and Firebane® 1115 (hereinafter collectively referred to as “both 

Firebane® 1115 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 Firebane® 1115 formulations are recommended for SNAP approval as streaming agents in portable 

fire extinguishers. However, the 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, 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 

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® 1115 formulations as streaming agents. According to the applicant, both Firebane® 1115

formulations contain no Class I or Class II ozone depleting substances, nor any compounds with 

measured global warming potential (GWP). Therefore, the use of Firebane® 1115 and Firebane® AllWeather 1115 will be less damaging to the atmosphere than the 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® 1115 formulations. The common application types, U.S. Food and Drug Administration 

(FDA) approval status, and associated hazards for these compounds are presented in 
September 23, 2011

3

Table 1. 
September 23, 2011

4

Table 1: Common Applications Types and FDA Approval Status of Firebane® 1115 and 

Firebane® All-Weather 1115 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® 1115 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® 1115 formulations are expected to be limited to the following activities: mixing of the 

chemicals, filling of extinguishers, and maintenance of extinguishers. According to the submitter, 

exposure to both Firebane® 1115 formulation is expected to be in the liquid form, with any vapor or gas 

exposures considered to be negligible. Workers that may be exposed to any chemicals during manufacture 

or an accidental release or spill are recommended to take precautionary measures as listed below to 

minimize risk. In accordance with general procedures prescribed in the MSDS of the proposed substitutes

and by the submitter, EPA recommends the following:

 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® 1115 or Firebane® All-Weather 

1115.

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 Firebane® 1115 and Firebane® All-Weather 1115 

does not pose a risk to human health.

4.2 Occupational Exposure during Installation and Maintenance

Both Firebane® 1115 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®

1115 formulations, inadvertent discharge may occur. Oxygen displacement during discharge of either 

Firebane® 1115 formulation is considered to be negligible, and therefore not a concern during inadvertent 

discharge. In addition, as noted above, all constituents exhibit low toxicity and are commonly used in 

food or cosmetics 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® 1115 formulations adhere to safety guidelines, as mentioned 

previously in Section Error! Reference source not found.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® 1115

and Firebane® All-Weather 1115. 
September 23, 2011

5

5 End-Use Exposure Assessment

In order to evaluate exposure at end use, ICF has evaluated the four active compounds contained in 

Firebane® 1115 or for Firebane® All-Weather 1115. The majority of Firebane ® 1115 is composed of 

GRAS compounds, and the remaining constituents are FDA-approved for use as a direct and/or indirect 

food additive. These compounds are commonly used in food, pharmaceutical, and/or cosmetic 

applications. Individual constituents may cause gastrointestinal discomfort (if excessively ingested), eye 

irritation, skin irritation, and/or respiratory tract irritation. 

6 General Population Exposure Assessment

This section screens potential risks to the general population from exposure to both formulations of 

Firebane® 1115 and its constituents to ambient air, surface water, and solid waste. Firebane® 1115 and 

Firebane® All-Weather 1115 are not expected to cause a significant threat to human health in the general 

population when used as a streaming agent in portable fire extinguishers. The only consumer exposure to 

either Firebane® 1115 formulation will be during discharge of fire extinguishers in occupied spaces. 

Firefighters and other end-users exposed to Firebane® 1115 or Firebane® All-Weather 1115 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® 1115 and Firebane® All-Weather 1115 are not expected to pose a significant threat to human 

health in the general population in the ambient air concentrations. As noted previously, both Firebane®

1115 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® 1115 formulations are not expected to 

be a safety concern for ambient air contamination.

6.2 Surface Water

As discussed in the Background Document, the physicochemical properties of the majority of halon 

substitutes make it unlikely that the substitutes would be released to surface water as a result of use. In the 

case of both Firebane® 1115 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. After settling, 

cleanup would involve washing/rinsing of surfaces and there would be no restrictions on discharge to 

publicly owned treatment works (POTW) based on the GRAS nature of the majority of the constituents of

both Firebane® 1115 formulations. Further, based on information from the submitter, the proposed 

substitutes are readily biodegradable and have exceptionally low biological oxygen demands and 

chemical oxygen demands. Based on these considerations, it is expected that the proposed substitutes

would not contribute to surface water contamination.

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 clean-up procedures, 

clean-up residues should be disposed of in accordance with requirements appropriate for those materials. 

7 Volatile Organic Compound Assessment

Of the constituents of both Firebane 1115®formulations, only one 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 this constituent 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 
September 23, 2011

6

with Firebane® 1115 or Firebane® All-Weather 1115 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.1 Assuming 

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

Firebane® 1115 and Firebane® All-Weather 1115 in portable extinguisher 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 2.5x10-5percent of the annual 

VOC emissions caused by fires,2or only about 9.1x10-7 percent of all annual anthropogenic sources. 3

Moreover, even if all the Firebane® 1115 and Firebane® 1115 All-Weather produced by Global Safety 

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 7.2x10-4percent of annual VOC emissions 

caused by fires, or 2.6x10-5percent of all annual anthropogenic VOC emissions. As these emissions are 

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

VOCs are not considered a threat.

 

1 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). 

2 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.

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

assumptions.
September 23, 2011

7

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. 2010a. “Request for information on a typical compartment size in a protected 

vehicle and an estimated rate of airflow.” February 9, 2010.

Global Safety Labs, Inc. 2010b. “Response to Incomplete SNAP Submission for Arctic-FirefreezeTM AllWeather 1115.” December 22, 2009.

Global Safety Labs, Inc. 2010c. “SNAP Submission to EPA for Arctic-FirefreezeTM All-Weather 1115.” 

November 2, 2009.

Global Safety Labs, Inc. 2010d. “Request to Include a Formula Modification Under Current SNAP 

Preliminary Acceptability Determination for Arctic Fire-FreezeTM All-Weather 1115.” June 15, 

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>