### September 2 3 , 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®**  **All -** **Weather 1115 and Firebane® 1115** 

**This risk screen does not**  **c ontain 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 **®** All
Weather 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 th e 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 W** **eight Percent) Firebane®**  **1115 Firebane®**  **All**  

** Weather 1115**

### September 2 3 , 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 : G eneral Population Exposure A ssessment ;  Section 7 : Volatile Organic Compound A ssessment ; and  Section 8: References
. 

### 2 **Summary**

**of Results** Both Firebane **®** 1115 formulations are recommended for SNAP approval as streaming agent s in portable fire extinguishers . However, the appropriate pers onal 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 prop osed 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, and occupational exposure should not pose a problem if PPE is used. For applications of this and al l other portable fire extinguishers , ICF recommends that National Fire Protection Agency (NFPA) S tandard 10 be followed. 

### 3 **Atmospheric As**  **sessment** This section presents an assessment of the potential risks to atmospheric integrity posed by the use of both Firebane **®** 1115 formulations as streaming agent s . 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 **®** All
Weather 1115 will be less damaging to the atmosphere than the continued use of Halon 1211. 

### 4 **O ccupational 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 ® 1115 formulations
. The co mmon application types, U.S. Food and Drug Administration ( FDA) approval status, and associated hazards for these compounds are presented in

### September 2 3 , 2011 3 Table 

### 1
.

### September 2 3 , 2011 4 **Table 1**  **: Common Applications Types an d FDA Approval Status of Firebane**  **®** 

### 1115 **and**

**Firebane ®**  

### All**- Weather**  **1115 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 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. B ased 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 extingui shers . 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 substitute s 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) ;  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 proc edures 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 11 15 does not pose a risk to human healt h. **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 F irebane **®** 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 install ation 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 2 3 , 2011 5 **5 End**  **- Use**  **E xposure**  **As sessment**  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 **G eneral Population**  **Exposure As**  **sessment** 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. Fire fighters 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 prec autionary measures describe d 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 **®** 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. A s noted previously, both Firebane **®** 1115 formulations are composed entirely of compounds that are FDA
- approved for use in f ood 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 S**  **urface Water** As discussed in the Background Document, the physicochemical properties of the maj ority 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 expul sion 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 maj ority of the constituents of both Firebane **®** 1115 formulations
. Further, based on information from the submitter, the proposed substitute s are readily biodegradable and have exceptionally low biological oxygen demand s and chemical oxygen demand s . Based on these considerations, it is expected that the proposed substitute s would not contribute to surface water contamination
. **6.3 S**  **olid 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 A ssessment**  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 fro m 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 2 3 , 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
. U sing release estimates from the Vintaging Model, the annual release rate ( including discharge, leak, and training release rate s ) 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 po rtable 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 - 5 percent of the annual VOC emissi ons caused by fires, 2 or 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 c ourse of the year (extremely unlikely), the resulting annual VOC emissions would be approximately 7.2x10 - 4 percent of annual VOC emissions caused by fires, or 2 .6 x10 - 5 percent 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 (E PA 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 2 3 , 2011 7 **8 R** **eferences** 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. Avai lable 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 All
Weather 1115 .” December 22, 2009. Global Safety Labs, Inc. 2010 c . “ SNAP Submission to EPA for Arctic
- FirefreezeTM All
-Weather 1115
. ” Novem ber 2, 2009. Global Safety Labs, Inc . 2010 d
. “Request to Include a Formula Modification Under Current SNAP Preliminary Acceptability Determination for Arctic Fire
- Freeze TM All
-Weather 1115
. ” June 15, 2010
. NFPA. 2010. NFPA 10: Standard for Portable Fire Extinguishers. 2010 Edition. Avai lable at <http://www.nfpa.org/catalog/product.asp?pid=1010&order%5Fsrc=B484>