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U.S. ENVIRONMENTAL PROTECTION AGENCY

INSTRUCTIONS FOR THE SIGNIFICANT NEW ALTERNATIVES POLICY (SNAP)

PROGRAM INFORMATION NOTICE

August, 2014

   

EPA‐1265‐14                                   Office of Atmospheric Programs

Washington, DC  20460

The U.S. Environmental Protection Agency (EPA) has prepared this instruction manual to help you in

submitting information on alternatives to the Significant New Alternatives Policy (SNAP) program.  This

manual provides instructions on submitting the SNAP Information Notice form, asserting confidentiality

claims, and submitting test data and optional information. However, please note that in the event of any

discrepancies between this document and the Code of Federal Regulations (CFR), the CFR requirements

are legally binding and take precedence.   

Part I – Introduction and CBI  

Section A‐ Instructions

All submitters must complete all of Part I‐ Introduction and CBI, Part II‐ Contact Information, Part III‐ 

General Information, Part XII‐ Attachments, and Part XIII‐ Certification. For each sector for which the

alternative is being submitted, submitters must also complete the corresponding sector‐specific data

requirements found in Parts IV to XI, outlined below for your submission to be accepted for review

under SNAP.

 Part IV‐ Refrigeration and Air Conditioning

 Part V‐ Foam Blowing

 Part VI‐ Cleaning Solvents

 Part VII‐ Fire Suppression

 Part VIII‐ Aerosols

 Part IX‐ Sterilants  

 Part X‐ Adhesives, Coatings and Inks

 Part XI‐ Tobacco Expansion

Please select the appropriate box on the Introduction and CBI tab indicating the type of notice‐ new

alternative not previously listed under SNAP or new end‐use or application of substitute currently listed

under SNAP.  

Section B‐ Identification of Alternatives

Please identify the name of the alternative, as well as the sector(s), end‐use(s), and application(s) (if

applicable) for which the form is being submitter in Part I, Section B. Sectors, end‐uses, and applications

are defined in Parts IV through XI.

Section C‐ Confidentiality Claims

If you submit information for which you would like to request Confidential Business Information (CBI)

status, you must make a claim of confidentiality at the time of submission and substantiate that claim.
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EPA will treat all claims of confidentiality consistent with 40 CFR Part 2, Subpart B. To claim information

as CBI, bracket the specific information you claim as confidential and mark the confidential box in the

column on the right‐side of the page in the corresponding row. If information is claimed as CBI, then a

public version must be submitted with the bracketed information redacted/removed.

To ensure that no confidential information is disclosed to the public, you must submit an additional

copy of the notice form, including attachments, which does not contain confidential information.

This version ("sanitized", "redacted") will be placed in the public file. It must contain all non‐

confidential information. To assert confidentiality claims for information in attachments to the

form, provide a complete copy of the attachment that clearly indicates (e.g., by circling or

bracketing) the information you wish to claim as confidential. Bracket only the specific information

you claim as confidential.  

Provide a Statement of Data Confidentiality Claims in Part I, Section C based on the instructions provided

in the form. EPA requires substantiation of all CBI claims under SNAP or a submission will be considered

incomplete.  

Part II – Contact Information

Section A‐ Submitter Contact Information

All contacts listed in Part II will be granted access to CBI, unless otherwise noted and substantiated in

Part I, Section C.

1. Person Submitting Notice ‐ Enter information for the primary submitter of the notice. The

person submitting the notice form must sign the certification in Part XIV‐ Certification.  

2. Agent ‐ Complete only if you authorize an agent to assist you in preparing this notice. The agent

must also sign the certification in Part XIV‐ Certification.

3. Technical Contact ‐ Identify a person who can provide EPA with additional technical information

on the substitute during the review period, if that contact is different than the “Person

Submitting Notice”. The technical contact identified should be located within the U.S. and be

available to be reached by telephone during normal business hours. If the authorized agent is

also the technical contact, include that person’s information in both locations.

4. Joint Submitter ‐ Identify the joint submitter, if any, who is authorized by the primary submitter

to provide some of the information required in the submission form. A submission will not be

considered complete until EPA receives all information. If information from multiple parties will

not be sent together, mark each set clearly with the same alternative name.

If you authorize another person (e.g., a foreign manufacturer or supplier) to provide information

directly to EPA, indicate which information will be supplied by the other person in Part XII

Additional Information. Such a letter in support of your submission should be provided by the

Joint Submitter on their company letterhead. An example of where this option could apply

would be in situations where alternative formulation information is held confidentially by a

foreign manufacturer. A submission will be considered incomplete until this information is
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provided. Whenever possible, use the same name for the alternative (e.g., generic name) to link

this information to your submission.

Part III – General Information

Section A – Alternative‐Specific Information

EPA must receive a complete and unambiguous identification of the new substitute. If the alternative is

not adequately identified, we will consider the submission incomplete. If you are an importer of an

alternative and do not know the chemical identity of a substitute because it is confidential, you must

contact the manufacturer or supplier and have the specific chemical identity provided directly to EPA. In

this way, manufacturers can protect confidential business information. This information may be

provided in a letter on company letterhead from the supplier.  

1. Identify Proposed Substitute ‐ (a‐d) Enter the specific name of the chemical substance, the

percent of the composition, the Chemical Abstracts Service (CAS) registry number, and the

molecular formula of the alternative. In describing chemical substances, EPA prefers that

International Union of Pure and Applied Chemistry (IUPAC) nomenclature be used for

identification purposes. If the substitute is a blend of chemicals, you must provide the exact

composition and/or the range of percent composition of all components of the blend. In

addition to active ingredients, you must also list other chemical substances in blends, such as

solvents, inhibitors, etc., that may also be present in the alternative. If your substitute is a

technology or process change, rather than a chemical substitute, then provide the name of the

alternative technology or process in (a) and proceed to (e).

(e) For alternative technologies and/or processes, provide a detailed description and diagram of

the technology or process and information on any chemical constituents.

(f) If you have applied for or hold a patent on the substitute, provide the patent name, number

(if available), and information on topics covered in the patent. It is not necessary to provide the

patent.

2. Commercial/Trade name(s) of alternative – Indicate the name(s) under which the alternative is

marketed.

3. Generic name ‐ If the identity of a substitute and the commercial/trade name are claimed as

confidential, you must provide a generic name that is only as generic as necessary to protect the

confidential identity. The name should reveal the chemical identity or alternative process

description to the maximum extent possible. The generic name may be published in the Federal

Register document announcing EPA’s acceptability determination of your alternative. If the

name seems more generic than necessary, EPA will contact you and assist you in developing an

adequate name.  

The generic name should provide sufficient information for the public by indicating the classes

of chemicals which the alternative contains without revealing specific information about the

product's composition. For example, it may be necessary to reveal that a refrigerant blend

contains an HCFC in order to allow users or importers to comply with regulations issued under

sections 604, 605 or 608 of the CAA.
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4. Impurities ‐ (a‐d) Identify by name, weight percent, and CAS number (where available) each

impurity that you reasonably anticipate will be present in the alternative as manufactured for

commercial purposes. An impurity is any chemical substance that is unintentionally present in

the alternative. List all impurities, regardless of weight percent. If the substance contains some

unidentified impurities, also enter "unidentified". Do not include substances that are mixed with

the new substance after manufacture of the primary ingredients. If there are no impurities,

enter "None." For alternative technologies and/or processes, mark “N/A” in (a) and proceed to

6.

5. Byproducts and Degradation Products‐ (a‐e) Identify any byproducts or degradation products

that you reasonably anticipate will result from the manufacture, processing, use, or disposal of

the alternative both at sites you control and in end‐use. Identify these byproducts or

degradation products by specific name or class or range of structures (e.g., HF or other acid

gases formed from the combustion of halocarbon compounds), CAS Registry number (where

available), when the byproduct or degradation product is formed (e.g., during manufacture,

during end‐use, in the event of a fire, following disposal), and the estimated amount formed

(grams) or rate of formation (grams/second).

6. Test Marketing ‐ Indicate if a test marketing notification was previously submitted to EPA.

7. Physical and Chemical Properties ‐ (a‐i) Provide the following physical and chemical properties

for chemical alternatives: molecular weight, physical state, melting point, boiling point, specific

gravity, lower flammability limit, upper flammability limit, bubble point, and flash point. The

properties included in this section are illustrative and are not an exhaustive list of potential data.

The physical characteristics requested in this section apply to all sectors; Parts IV through XI

request additional sector‐specific physical and chemical properties. For alternative technologies

and/or processes, mark “N/A” in (a) and proceed to 11.

(k) If you are extracting this information from a public reference source (e.g., CRC Handbook of

Chemistry and Physics, Merck Index), please provide copies of the references. If references

include copyrighted materials, mark as CBI.

(l) If you have performed chemical analysis and testing on the substitute (e.g., fractionation

testing, ASTM E681 for flammability limits in air) to derive the properties, attach copies of all

test reports and specify the protocol used.

8. Ozone depletion potential (ODP) ‐ (a) Provide information on the predicted 100‐year ODP of

the alternative relative to CFC‐11. If the substitute is a blend, provide the ODPs of the individual

constituents. You should also provide supporting documentation indicating how and by whom

this value was calculated.  

For purposes of calculating ODP, EPA recommends the methodology used in the Scientific

Assessment of Ozone Depletion prepared for the United Nations Environment Programme

(UNEP) by the World Meteorological Organization (WMO). The ODP refers to the amount of

ozone destroyed by a gas over its entire atmospheric lifetime (e.g. at a steady state) relative to

that due to emissions of the same mass of CFC‐11. It is defined in modeling calculations as

follows:
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Global O caused by CFC - 11

Global O caused by x

ODP = 3

3

x





Calculations should reflect ground level emissions. For aircraft applications, be sure to also

consider emissions at the appropriate altitude.

(b‐c) You should also include any other related data available to you, such as information on the

substitute's chlorine or bromine loading potential. See the 2010 WMO Scientific Assessment of

Ozone Depletion for additional information on calculating ODP and related information.  

9. Global Warming Characteristics ‐ (a‐c) Provide information on the 100‐year global warming

potentials (GWPs) of the proposed substitute relative to CO2, as well as atmospheric lifetime

(ATL) of the proposed substitute. If the substitute is a blend, provide the GWPs of the individual

constituents and an estimate of the blend at its nominal composition.  

Provide GWPs as listed in the 2007 Intergovernmental Panel for Climate Change Fourth

Assessment Report (IPCC AR4). Alternate sources may include the 2010 WMO Scientific

Assessment of Ozone Depletion or the peer‐reviewed literature. IPCC defines GWP of the

emissions of a greenhouse gas as the time integrated commitment to climate forcing from the

instantaneous release of 1kg of a trace gas expresses relative to that from 1 kg of CO2.

a c dt

a c dt

GWP=

CO CO

n

0

i i

n

0

 2 2



where‐ 

ai = the instantaneous radiative forcing due to a unit increase in the concentration of trace gas, i

ci = the concentration of trace gas, i, remaining at time, t, after its release, and

n = the number of years over which the calculation is performed.

Corresponding values for CO2 are in the denominator.

For GWP values that do not come from IPCC AR4 or WMO 2010, you should also include the

data used to calculate these potentials such as atmospheric lifetime, infrared adsorption

spectrum, and infrared absorption capacity. Provide all supporting documentation.  

(d) If the alternative is captured as a byproduct of another manufacturing or industrial process,

indicate the source of the alternative. This information is important in assessing the effects of

the new use of the substitute versus those effects occurring strictly because of the release of a

byproduct.

10. VOC Status Information – (a‐d) Indicate whether the alternative is considered to be a volatile

organic compound (VOC) and is subject to emission restrictions under Title I of the CAA (40 CFR

51.100(s)) or exempt as a VOC. If a request for VOC exemption has been submitted to EPA under

Title I, please provide information on that submission and the current status of that request, and
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provide the information on reactivity below in (d). For compounds that are not VOC exempt,

provide information on the reactivity of the compound in the atmosphere, such as the

maximum incremental reactivity in grams of O3 (ozone) per gram of VOC and/or the kOH value.

11. Cost of Proposed Substitute ‐ Estimate the cost of the chemical substitute. Information on costs

of the alternative for a specific use is requested in Parts IV through XI. Specify the units used.

12. Environmental Regulations ‐ List any environmental statute (such as those included in the form)

applicable to the manufacture, use, and disposal of the proposed substitute. Provide citations

for implementing regulations and a brief explanation of the nature of the regulatory

requirement (for example, 40 CFR part 63 subpart T, National Emission Standards for Hazardous

Air Pollutants for Halogenated Solvent Cleaning).

13. Health and Safety Regulations – Describe whether and how occupational, consumer, or general

population exposure to the proposed substitute is regulated under health and safety related

statutory authorities, such as those listed in the form. Provide regulatory citations where

available, e.g., 29 CFR 1910.132.

14. Toxicity Limits – (a‐c) Provide all concentration‐based exposure limits that have been set for the

substitute, such as Permissible Exposure Limits (PELs), occupational exposure limits including

Short‐Term Exposure Limits (STELs), Threshold Limit Values (TLVs), Recommended Exposure

Limits (RELs), or Workplace Environmental Exposure Limits (WEELs), or acceptable exposure

limits (AELs) set by the manufacturer. Submit any supporting documentation, including public

literature and information previously submitted to the SNAP program for a different submission.   

(d) If available, summarize the acute and chronic toxicity of the proposed substitute and of its

constituent chemicals on any organism (e.g. human and/or other mammals, fish, wildlife, and

plants). Attach all complete test reports that are reasonably available to you.  

15. Safety Documents ‐ Please attach a copy of any hazard warning statement, label, material safety

data sheet (MSDS), or other information which will be provided to any person who is reasonably

likely to be exposed.  

Parts IV to XI: Sector‐Specific Information

Due to the unique uses and exposures of alternatives for each of the SNAP industrial sectors, the

submission form includes individual tabs for each sector. You are only required to complete those

sections for which you are submitting to SNAP. Below are instructions for Parts IV‐X. Instruction are

organized by Section, beginning with instructions for the common elements. Instructions for questions

that are unique to a specific sector, are noted below the common elements or within the instructions for

each Section.  

If you are submitting the substitute for several end‐uses or applications, you must provide the requested

information for each. Part XI: Tobacco Expansion does not require the submission of any additional data;

therefore, no instructions are provided.
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Information claimed as confidential should be placed in [brackets] and marked as CBI. If information is

claimed as CBI, then a public version must be submitted with the bracketed information redacted or

removed.  

Section A: Use Profile

 Specific End‐use ‐ Identify the specific end‐uses and applications (if applicable) within the sector in

which the alternative is to be used. Specify the ozone‐depleting substance (ODS) and other

substances being replaced, and include an estimate of the quantity of alternative (lb) needed to

replace the ODS or other substance for each end‐use. This is known as the replacement ratio. For

example, if 100 lb of a new refrigerant will replace 150 lb of CFC‐12, the replacement ratio is 1:1.5.  

 Additional End‐Use Description – Provide a written description of the specific uses for which you

are submitting.  

 Technology Changes and Cost‐ Describe any new equipment technology changes and associated

costs that will be necessary in order to use the proposed substitute.

 Production ‐ Provide estimated information on production of the proposed substitute or equipment

using the proposed substitute. Indicate when you anticipate the substitute or new equipment using

the substitute will enter the marketplace. Include the value for total production anticipated during

the first year of production in kg.  

 Market Share ‐ Provide information on the levels of market penetration that you expect for the

substitute or new use of an existing substitute. Include estimates for the number of years you

anticipate until the substitute reaches its maximum market penetration for those uses included in

submission, and the total production level that you anticipate for the substitute when it reaches the

point of market saturation. Finally, if possible, estimate the percentage of the market held by the

substance(s) being replaced that will be captured by this substitute.  

 Application of Proposed Substitute – Provide information requested in each sector‐specific section

on the specific application of the substitute. These questions are related to both manufacturing and

use.

 Consumer Use – Where requested, indicate whether the proposed substitute will be used for

consumer use. If consumer use is expected, please describe the anticipated consumer applications.

 End‐Use Specific Standards ‐ List any standard‐setting organizations that will evaluate the proposed

substitute or will set requirements or guidelines for the substitute from a health and safety

perspective in the proposed end‐use(s). Examples include Underwriters Laboratories (UL), the

American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE), the Society of

Automotive Engineers (SAE), the National Fire Protection Association (NFPA), or the International

Organization for Standardization (ISO).

Refrigeration and Air Conditioning

 Energy Efficiency ‐ (a‐b) Provide the alternative’s impact on energy efficiency relative to the

substance it is replacing for each end‐use. Attach and describe the results of any energy

efficiency testing or modeling performed. Laboratory testing of equipment should evaluate the
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proposed substitute vs. the substance(s) being replaced. Values should be given in kWh/day or a

similar measure. Also address refrigerant/oil solubility. Computer models should account for

compressor efficiency, refrigerant transport properties, and mass flow rates for given tubing

geometry, capillary tube/suction line heat transfer, and liquid and vapor specific heats.  

 Compressor Oil ‐ Provide information on the chemical class of refrigerant oil you anticipate will

be used (e.g., polyalkylene glycol, polyolester, mineral oil) and information on the refrigerant/oil

solubility.

Foam Blowing

 Energy Efficiency ‐ (a‐b) Provide the alternative’s impact on energy efficiency relative to the

substance(s) it is replacing for each end‐use. Attach and describe the results of any energy

efficiency testing or modeling performed. Laboratory testing of equipment should evaluate the

proposed substitute vs. the substance(s) being replaced. Values should be given in kWh/day or a

similar measure.  

Cleaning Solvents

 Compatibility – Provide information on the compatibility of the solvent with metals and plastics

with regards to its use as a cleaning solvent (e.g., is the solvent corrosive to some materials).  

Fire Suppression  

 Weight and volume equivalence replacement ration: To respond to Section A, question 1(c),

use the following formula for determining weight and volume equivalence:

Weight and volume equivalents are calculated using a single, fuel‐specific design concentration

(heptane); therefore, they do not represent the exact weight or volume of the agent needed to

protect any specific space against any specific hazard. The information used to calculate the

equivalents is provided from agent manufacturers and NFPA 2001, "Standard for Clean Agent

Fire Extinguishing Systems." Equivalents are included in SNAP rulemakings for general

comparison and informational purposes only.

EPA understands that fire suppression agents must be evaluated in the context of the fire

extinguishing system equipment with which they are used. Design concentration, and weight

and volume equivalents are only meaningful when evaluated in specific system hardware

configurations. This is especially important when comparing storage volume where storage

container fill density varies with the equipment used. Agent fire suppression performance will

vary with the system used and the detailed design of the system. Therefore, fire suppression

agent manufacturers do not generally recommend design concentrations as these are also a

function of the system hardware in which they are used. Hence, these data are provided for

general guidance only and do not reflect a recommendation for system design or a basis for

rigorous quantitative comparison.

(1) Weight and volume equivalent data should be presented relative to Halon 1301 at 120 per

cent of cup burner as well as at 5 per cent, a typical use concentration;

(2) Weight and volume equivalents should be based on agent concentrations at standard

temperature and pressure;
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(3) Weight and volume equivalents should be done at both the manufacturer's recommended

design concentration and at 120 per cent of the cup burner value where the values are not the

same;

(4) Volume equivalents will be based on agent volume only (exclusive of container volume, fill

density, etc.) at 70 degrees Fahrenheit and the storage pressure specified by the manufacturer

since this varies widely and the required agent mass determined in item (5) below; and

(5) The required agent weight equivalents should be determined by the following equation:

W = V/S(C/100‐C)

where C = design concentration (% volume)

V = one cubic foot

S = agent specific vapor volume at 70 degrees F (ft3

/lb).

(6) Appropriate references to the technical literature on which the data are based should be

provided.

(d) Indicate the type (i.e., occupied or unoccupied) and purpose (e.g., engine room, machinery

space, cargo room) of space in which the extinguisher will be used.

Section B: Physical and Chemical Properties

 Physical and Chemical Properties ‐ Include data on the physical or chemical properties of the

alternative that are relevant to evaluating the proposed substitute in a specific sector. The

properties included in each section are illustrative and are not an exhaustive list of potential

data.  

Refrigeration and Air Conditioning

 ASHRAE Designation – Please identify whether the proposed substitute has been submitted to

and/or published by the ASHRAE Standing Standard Project Committee 34 (SSPC 34). If it has

been published, specify the ASHRAE designation and classification.

Foam Blowing

 Manufacture and Degradation Products – Provide a study on the catalyst used in the

manufacture of the foam blowing agent and the degradation products under different external

conditions (e.g., temperature) during use to assess potential hazards of breakdown/degradation

products of foam during use.

Fire Suppression  

 Degradation Products – Provide information on the degradation products of the alternative

following discharge in a fire situation. Explain the conditions used in determining these products

(e.g., flame temperature, time required to extinguish the fire, amount of O2 present,

combustible material).  
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Section C: Flammability (Required for Refrigeration and Air Conditioning, Foam Blowing, Cleaning

Solvent, Aerosols, Sterilant, and Adhesives, Coatings, and Inks)

 Flammability‐Related Physical and Chemical Properties ‐ Provide information on the physical

and chemical properties relevant to evaluating the flammability of the proposed substitute.

Flammability Assessments and Test Data – For flammable substitutes, please include as an

attachment the results of ASTM E681 Flammability Limits in Air. The numerical values for the

upper and lower flammability limits are requested in Part III. For flammable refrigerants, please

provide information on the maximum pressure of combustion, the maximum rate of pressure

increase during combustion, and the minimum ignition energy. If you have conducted any

analyses on flammability, please provide them.

For refrigeration and air conditioning, if an alternative is flammable (this applies to both blends

and neat chemicals), you must analyze the risk of fire resulting from the use of the substitute in

each proposed end‐use/application through a risk assessment. For refrigeration and air

conditioning, a Fault Tree Analysis (FTA) or Failure Mode and Effects Analysis (FMEA) is also

required. An FTA should include, but not be limited to, a description of typical scenarios in which

the substitute is used, potential leak scenarios, sources of ignition, and quantified probabilities

of ignition. It should also assess the likelihood of injury within each scenario. An FMEA should

describe identified failures that could result in a spark, flame, explosion, or other fire risk and

mitigation measure for each failure mode. Significant differences exist both in the design and in

the ambient conditions for various end‐uses. Thus, risk assessments are extremely sensitive to

end‐use. Low risk in one end‐use does not, in general, imply low risk in another end‐use.

For refrigerant blends that contain one or more flammable components, provide information on

fractionation during leakage, including flammability test results on the worst‐case formulation

and the worst‐case fractionation formulation for the blend.

 Flammability Concerns and Mitigation ‐ Provide all test data regarding flammability of the

substitute, including the procedures used for determining flammability and any other

information on flammability concerns. If a substitute is flammable under the conditions

expected in the proposed end‐use/application, describe any abatement techniques being used

to minimize the risks associated with use of a flammable substance (e.g., equipment design

modifications or alternate labeling).  

For flammable foam blowing agents used in spray foam, provide a training program that address

flammability concerns specific to the substitute. For foam blowing agent blends that contain one

or more flammable components, provide information on the range of composition that would

render the blend nonflammable (for example, using at least 5% of the nonflammable

component in the blend is expected to make the blend nonflammable).

Section C: Fire Suppression Agent Toxicity and Hazard Information (Required for Fire

Suppression Only)

 Inhalation Toxicity Studies – Provide an inhalation toxicity study if workers are exposed to the

chemicals during manufacture or long‐term exposure levels have not been determined by
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Occupational Safety and Health Administration (OSHA), National Institute for Occupational

Safety and Heath (NIOSH), American Conference of Industrial Hygienists (ACGIH), or American

Industrial Hygiene Association (AIHA).

 Genotoxicity Studies ‐ Provide genotoxicity studies (e.g., Ames assays, forward mutation assays,

cytogenetic assays) to determine the potential for the agent to induce DNA damage.

 In‐kind Halon Alternatives (Halocarbons) ‐ Provide the a cardiac sensitization study and acute,

sub‐acute, and subchronic toxicity inhalation studies with rats for halocarbon steaming agents

or flooding agents used in occupied spaces.

 Not‐in‐kind Halon Alternatives (Powdered Aerosols or Foam) – For foam streaming agents,

provide an acute toxicity inhalation study and an ocular irritation study (Draize test). For

powdered aerosol flooding agents proposed for use in occupied spaces, provide a static acute

toxicity inhalation study with rats at the design application density. For any powdered aerosol

fire suppression agent used in occupied spaces, provide a dermal irritation study.

 Powdered Aerosol Flooding Agents Used in Occupied Spaces – (a‐g) The use of powdered

aerosol flooding agents in occupied spaces requires special considerations of the physical

properties and toxicity of the agent and visibility in the protected space. Identify the likelihood

that the fire extinguisher will accidentally discharge (reported as the number of accidental

discharges in 1 million); the number of extinguishing devices (i.e., generators) installed in a room

and the location of these devices within the space; the discharge rate (g/s) of the fire

extinguishing device; the length of time it takes for the particles to become distributed

throughout the space and the particle size distribution over time; the settling rate of the

particles; the mass median aerodynamic diameter (MMAD) (μm) and concentration (mg/m3

) of

the effluent released from the nozzle; the composition of effluent (amounts of other gases

generated) by weight percent; and the maximum egress time for personnel from the space and

several approaches to facilitate safe egress (e.g., training, installation guidelines).  

Section D: Exposure

Provide the information requested within the Information Notice form related to potential exposure

scenarios. This section requires information on typical and maximum potential exposure scenarios

during manufacturing, use and disposal. If the substitute and equipment using the substitute are

manufactured outside of the United States, information on exposure during manufacturing is not

required. However, if the information is readily available, please submit it.

Examples of the type of information required to be submitted are provided within the form.  

 Exposure Media and Release Information: Provide the requested information.

 Potential Exposure Activities: Identify the activities during manufacture, use, servicing and

disposal during which the potential for exposure is highest. Provide information on typical and

maximum potential exposure concentrations during these activities.  
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 Training Materials: Provide information on training materials related to manufacture,

installation and servicing, and disposal. If the proposed substitute is flammable, describe how

these guidelines differ from training for non‐flammable substances.

Refrigeration and Air Conditioning

 Information on Recovery Practices: Section 608 of the Clean Air Act prohibits the intentional

release (venting) of ozone‐depleting refrigerants and their substitutes while maintaining,

servicing, repairing, or disposing of air conditioning or refrigeration equipment. Please provide

information on how the substitute will be recovered.

Foam Blowing

 Maximum Annual Emissions Rate: For each end‐use, provide maximum annual emission rates

for blowing agent leaks from foam application during the foam's lifetime (i.e., after

manufacturing and before disposal) as a percentage of the original total amount of blowing

agent used to produce the foam. Please also specify the anticipated number of years for which

the blowing agent would be leaking from the foam (i.e., the emissive lifetime). For reference,

the following are annual emission rates that EPA uses as defaults.

o Polyurethane (PU) and Polyisocyanurate Rigid Boardstock: 1%

o PU Rigid Appliance Foam: 0.25%

o Rigid PU Spray Foam: 1.5%

o Commercial Refrigeration Foam: 0.25%

o PU Rigid Slabstock: 0.75%

o PU Integral Skin Foam: 2.5%

o PU Rigid: Sandwich Panels: Continuous and Discontinuous: 0.5%

o XPS: Sheet Foam: 2%

o XPS Boardstock Foam: 0.8%

o Polyolefin Foam: 2.5%

o Phenolic Foam: 0.875%

Section I: Additional Information for Submission of Requirements for Blends of

Foam Blowing Agents (Foam Blowing Only)

For the following end‐uses, a submission is required for blends of blowing agents, including blends with

blowing agents that are already listed as acceptable:

 Polyolefin

 Polystyrene: Extruded Boardstock and Billet

 Rigid Polyurethane and Polyisocyanurate Laminated Boardstock

 Rigid Polyurethane: Spray Foam*

 Phenolic Insulation Board and Bunstock

*For spray foam, if any components of the blend are flammable, then an additional submission

is required for the blend.

For the following end‐uses, it is permissible to blend blowing agents that are already listed as acceptable

without an additional submission for the blend:   

 Rigid Polyurethane: Appliance  
13

 Rigid Polyurethane: Commercial Refrigeration

 Rigid Polyurethane: Sandwich Panels

 Rigid Polyurethane: Spray Foam*

 Rigid Polyurethane: Slabstock and Other

 Flexible Polyurethane

 Integral Skin Polyurethane

 Polystyrene: Extruded Sheet

*For spray foam, if all components of the blend are acceptable and non‐flammable, then it is

permissible to blend those blowing agents without an additional submission for the blend.

Part XII: Additional Information

Provide any additional information that may assist EPA’s review. Submitters are not required to include

information in this section.

Part XIII ‐ Attachments

Clearly identify all attachments being provided in support of the submission.  

Mark (X) in the CBI box next to any attachment that you claim as confidential. The public version of the

submission form must include the attachment name/citation at a minimum. All claims of confidentiality

must be substantiated in Part I.   

Part XIV‐ Certification

The individual identified in Part I of the form as the person submitting the Information Notice must sign

the certification in Part XIV of the form. This official is responsible for the truth and accuracy of each

statement in the certification. If an agent assists you in preparing the submission, the agent must also

sign the certification.  

A printed copy of the certification page, with original signature, must be submitted with electronic or

paper submissions. If the submission is not signed, EPA will consider the submission incomplete and will

not review the substitute.