5852 Baker Road • Minnetonka, MN 55345

Phone: 952.935.9745 • Fax: 952.935.9757 • www.statx.com

8/08/13

Ms. Rebecca von dem Hagen

Alternatives and Emissions Reduction Branch

Stratospheric Protection Division

United States Environmental Protection Agency

Washington, DC 20460

Re: Redacted SNAP Submission for Stat-X/Aero-K Condensed Aerosol System in Fire Suppression

Dear Ms. Von dem Hagen:

Please find attached a redacted version of our SNAP Submission as requested in your letter of 

July, 15,2013. We consider all the Attachments to the submittal including the Test Reports in 

their entirety as Confidential Business Information of Fireaway Inc.

Sincerely,

Marc V. Gross

President
Form 1265-07 (Revised 09/2011) 1 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

United States

ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460

AGENCY USE ONLY

OMB Control No.: 2060-0226 

Expires: 8/31/2014

SNAP INFORMATION NOTICE

For Significant New Alternatives

Date of Receipt:

Date 90 Day Review Begins: 

Date Review Completed: 

CBI Status: 

When completed send this form to:

Via US Postal Service: Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER SNAP DOCUMENT CONTROL OFFICER 

OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA 

U.S. EPA 1310 L STREET NW 

1200 PENNSYLVANIA AVE NW 10th FLOOR (MC 6205J) 

WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: Document Control Number

INTRODUCTION

GENERAL INSTRUCTIONS 

This form may be used to submit information under the Significant New Alternatives Policy (SNAP) program for the review of 

alternatives to class I and class II ozone-depleting substances (ODS) under section 612 of the Clean Air Act. Submitters are 

required to provide this information on new substitutes to assist the Agency in assessing the acceptability of chemicals or 

processes that are considered alternatives for ODSs. A separate notice must be filed for each alternative you are submitting. 

PAPER SUBMISSIONS: All paper submissions must be provided in three complete copies. If information is to be claimed as 

confidential, all confidential information must be excised from one of the copies, which will be placed in the public docket; the 

other two copies must include the confidential material. If no claims of confidentiality are made for the submission, all copies 

must be identical. 

CD-ROM SUBMISSIONS: The SNAP program also accepts submissions via CD-ROM. If information is to be claimed as 

confidential, all confidential information must be excised from one of the files on the CD-ROM, which will be placed in the public 

docket; the other file must include the confidential material. The file with the confidential material must include “contains CBI” in 

the file name. 

STEP-BY-STEP INSTRUCTIONS: The Instructions for the SNAP Information Notice and TSCA/SNAP Addendum (“Instructions”) 

are designed to assist applicants in completing this form. The Instructions provide step-by-step guidance on submitting a SNAP

notice, asserting confidentiality claims, completing the notice form, sector-specific data requirements, and submitting test data 

and supplemental information. 

To facilitate Agency review of alternatives, this form must be filled out as completely as possible. Please provide all information 

requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailable.

TYPE OF NOTICE (Check only one box) 

Select the appropriate box identifying the type of notice submitted: 

Manufacturer Submission: New alternative, Substance, or Formulation ___________________________________________x

Petition: New alternative, Substance, or Formulation ________________________________________________________

Petition: Revision of the Existing SNAP list _________________________________________________________________

Petition: Request to Grandfather Use of An Unacceptable Substitute _____________________________________________
Form 1265-07 (Revised 09/2011) 2 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

Part I - GENERAL INFORMATION 

You must provide the identity of the alternative chemical or 

processes and the identity and percentages of all 

components in a blend and/or process, even if you claim the 

identity as confidential. You may authorize another person 

to submit the identity for you, but your submission will not be 

complete and review cannot begin until EPA receives this 

information. 

Part II - ALTERNATIVE-SPECIFIC INFORMATION

 

Please indicate the sector(s) for which you are submitting 

information on the substitute by checking the appropriate 

boxes: 

• Refrigeration and Air Conditioning  

• Foam Blowing 

• Solvent Cleaning  

• Fire Extinguishing 

 and Explosion Prevention x

• Sterilization 

• Aerosols 

• Adhesives, Coatings, and Inks 

• Tobacco Expansion 

• Pesticides 

You may need additional copies of Part II if there are several 

manufacturing, processing, or use operations that you will 

describe in this notice. Please reproduce these sections as 

needed. 

If your substitute is also subject to review under FIFRA, 

provide the FIFRA Registration Number: 

 _____________________________ 

Part III - RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary. 

Part IV - LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on 

the form to fully answer a question. Label each continuation sheet 

with the corresponding section heading and the question. In part 

IV, list these attachments and any test data, other data, or any 

optional information that you include in this notice. 

TEST DATA AND OTHER DATA

You are required to submit all test data in your possession or 

control and to provide a description of all other data known to you if 

these data are related to the health and environmental effects of 

the manufacture, processing, distribution in commerce, use, or 

disposal of the alternative. Standard literature citations may be 

submitted if they do not appear in the open scientific literature. 

Complete test data (in English), not summaries of data, must be 

submitted if they do not appear in the open literature. The following 

are test data and other data that might be submitted (see the 

Instructions for a more complete list of data to be submitted.) 

Please indicate test data to be included in your submission notice 

by checking the appropriate boxes: 

• Health Effects Data x Yes  No 

• Flammability Data x Yes  No 

• Environmental Effects 

 Data x Yes  No 

• Environmental Fate 

 Data  Yes  No 

• Risk Assessments  Yes  No 

• Test Data Not in the Possession/ 

 Control of the Submitter  Yes  No 

• Other Data x Yes  No 

CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentiality at the time of submission for any data which are to be treated as 

Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information claimed as 

CBI will be treated in a manner consistent with 40 CFR Part 2, Subpart B. Failure to assert a claim of confidentiality at the time of 

submission may result in disclosure of information by the Agency without further notice. 

To assert a claim on this form, circle or bracket the information you claim as confidential and mark the confidential box at the bottom 

of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confidential, 

you must provide a “sanitized” version of this notice, including attachments, to EPA with your submission. For additional information 

on claiming information as confidential, please see the Instructions Manual. 

Information submitted as CBI may be accessed by companies designated as Authorized Representatives of the United States 

Environmental Protection Agency (EPA) under an EPA contract for the purpose of assisting EPA in the development and 

implementation of national regulations for the protection of stratospheric ozone, including the development of the SNAP program. 

These Authorized Representatives may have access to any information received by the Stratospheric Protection Division within the 

EPA Office of the Atmospheric Programs for use in reviewing the need for possible control of any substance, practice, process or 

activity that may reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary to ensure that 

these companies can complete the work required by the contract. 

Authorized Representatives of the Administrator are subject to the provisions of 42 U.S.C. 7414(c) respecting confidential business 

information as implemented by 40 CFR 2.301(h).
Form 1265-07 (Revised 09/2011) 3 

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Part I - GENERAL INFORMATION 

Section A - SUBMITTER IDENTIFICATION 

1. (a) Person Submitting Notice (in U.S.)

Marc V. Gross President 

Name of Authorized Official Title 

Fireaway Inc. 

Company/Organization 

5852 Baker Road, Minnetonka, MN 55345 Phone: 952.935.9745 • Fax: 952.935.9757 

Mailing Address Telephone & Fax Numbers 

mgross@statx.com 

E-mail Address 

(b) Agent (if applicable) 

____________________________________________________________________________________________________________ 

Name of Authorized Official Title 

____________________________________________________________________________________________________________ 

Company/Organization 

____________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

____________________________________________________________________________________________________________ 

E-mail Address 

(c) Joint Submitter (if applicable)

____________________________________________________________________________________________________________ 

Name of Authorized Official Title 

____________________________________________________________________________________________________________ 

Company/Organization 

____________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

____________________________________________________________________________________________________________ 

E-mail Address 

2. Technical Contact (in U.S.) 

__________________________________________________________________________________________________________ 

Name of Authorized Official Title 

_________________________________________________________________________________________________________ 

Company/Organization 

__________________________________________________________________________________________________________ 

Mailing Address Telephone & Fax Numbers 

__________________________________________________________________________________________________________ 

E-mail Address 

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter, phone, 

etc.) and the EPA staff person’s name: 

See “Continuation Sheet Part I-A-3” 

Mark (X) if None ________________ 

 Mark (X) this box if this page contains CBI __________ 
Form 1265-07 (Revised 09/2011) 4 

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Continuation Sheet 

Part I-A-3 

EPA Contacts 

The following is a listing of the contacts Fireaway has made with the EPA personnel on this matter 

identifying the form of contact, the date and the person(s) contacted at EPA. These contacts do not 

include those that were made before the current EPA SNAP approval described in EPA-HQ-OAR-2005-

0087-0009. 

• On or about May 18, 2010 Fireaway management participated in a conference call with EPA 

personnel including Bella Maranion and Margaret Sheppard. The purpose of the call was to discuss 

what type(s) of testing and data would be appropriate for a submittal requesting expansion of the StatX SNAP listing to include normally occupied spaces. 

• In addition, we believe a very limited number of email were also exchanged following the conference 

call for additional clarification. These were sent, however, by a former employee and copies are not 

available at Fireaway. 

Mark (X) this box if this page contains CBI __________ 
Form 1265-07 (Revised 09/2011) 5 

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Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative: 

Stat-X® Aero-K® Condensed Aerosol System 

(See “Continuation Sheet Part I-B-1” for explanation of this submittal and inhalation, dermal and 

ocular irritation study information). 

2. (a) Name of chemical(s) (preferably IUPAC nomenclature) and/or process name. For blends, provide the percent composition of each 

constituent. For powdered aerosols used in fire suppression, see page 11 of the Instructions for additional necessary composition information. 

 (b) Chemical Abstracts Service (CAS) registry number and molecular formula. 

 (c) For alternative processes and technologies describe the technology and provide a diagram of the system. Also provide the information 

on any chemical constituents. 

 (d) If you have applied for or hold a patent on the substitute, provide the patent name, number (if available), and information on the topics 

covered in the patent. 

a & b. Manufacturing constituents: 

a & b. Discharged agent constituents: See “Continuation Sheet Part I-B-2-a & b & c” 

c. See “Continuation Sheet Part I-B-2-a & b & c” 

d. Fireaway Inc. is a world-wide licensee for the following patents covering the technology: 

 6089326, 5865257, 6116348,6264772,5831209, 6042664 

3. Generic name: 

If the name of the substitute is declared Confidential Business Information, provide a generic name. 

Stat-X® Aero-K® 

4. Specific End-Use 

 (a) Describe each end-use that may be reasonably anticipated for the alternative. Be sure to provide a broad description (e.g., terpene-based 

semi-aqueous solvent cleaner for electronic parts, or HFC substitute refrigerant for centrifugal chillers). For a list of end uses, see Appendix A 

to the Instructions, beginning on p. 23. If the alternative is a refrigerant, indicate whether it is a candidate for use in retrofits of existing 

equipment, for use in new equipment only, or both. 

 (b) Identify the ODS and the quantity of substitute needed to replace it for each end use in pounds (i.e., the replacement ratio). 

(a) Particulate aerosol for fire and explosion suppression and inertion in total flooding applications in 

normally occupied and normally unoccupied areas (shipboard machinery spaces, marine engine 

compartments, electrical cabinets, engine compartments, turbine enclosures, flammable liquid 

storage, remote cellular base stations, etc.). 

(b) For replacement of halon 1301. Stat-X® Aero-K® is 5 times more effective than halon 1301 on a 

weight basis (i.e., 1 lb of Stat-X® Aero-K® per 5 lbs of halon 1301). 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 6 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

Continuation Sheet 

Part I-B-1 

Purpose of Submittal 

The Stat-X® Aero-K® system presently has an EPA SNAP approval for use as a total flooding fire 

extinguishing system alternative to halon 1301. However the approval limits the Stat-X® Aero-K® system 

“For use only in normally unoccupied areas.” 

As a point of reference, we have attached two documents provided by ICF to US EPA in support of the 

current SNAP approval for the Stat-X® Aero-K® system. They are: 

“Background Information for Revised Stat-X®/Aero-K® Risk Screen,” ICF to US EPA, January 31, 

2007. 

“Risk Screen on Substitutes for Halon 1301 Total Flooding System in Unoccupied Space, Substitute: 

Stat-X®/Aero-K®,”ICF to US EPA, January 30, 2007. 

The purpose of this submittal is to provide inhalation, dermal and ocular irritation study information to be 

considered for the purpose of removing the current SNAP limitation, thus approving the use of the StatX® Aero-K® system to protect areas that are considered normally occupied. 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 7 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

 

 

 

 

 

Mark (X) this box if this page contains CBI __________x

 

1

 “Effluent Concentrations of Fire Suppressant Units,” : 20 

September 1999. 

2

 “Characterization of Particulate and Gas Release After Activation of Stat-X Electrical Units,” , 

4 April 2013 3

 “Fire-Hygienic Assessment and Evaluation of Fire Extinguishing Generators of Type Stat-X 30 E," 

: 18 November 

2010. 

4

 “STAT-x, Fire Suppressant Unit: Preliminary Inhalation Toxicity Study in Rats for 15 Minutes,” 

: 11 November 2011. 5

 While the report identifies the units as 25 gram generant capacity, the units supplied by Stat-X were indeed of 30 

grams generant capacity each, thus providing an application density of 8 x 30g = 240g or 99g/m3

. 
Form 1265-07 (Revised 09/2011) 8 

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The discharge of any aerosol extinguishing system results in a reduction of visibility in the protected 

space due primarily to the uniform distribution of the particulate generated. There are several ways to 

minimize the possibility of a system discharge when personnel are still in the protected space and / or to 

mitigate the effect of the reduced visibility on safe egress for personnel still in the protected space at the 

time of system discharge. 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 9 

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Prevention 

NFPA 20106

 requires that a warning of a pending discharge and a delay in the discharge to allow 

personnel to exit the protected space. In addition, cross zone detection systems are often 

employed where detection by one zone would cause an alarm and the time delay before system 

discharge would not begin until detection by the second zone. Further the standard allows the use 

of a system abort switch located near an exit from the protected space that would prevent the 

discharge of the system until all personnel have been evacuated from the protected space. All 

systems must have the pre-discharge alarm and time delay with the cross zone detection and abort 

switch approaches optional but commonly used. 

Mitigation 

Annex C of NFPA 2010, “Reduced Visibility Information,” provides information on several 

approaches one can take to facilitate the safe egress of personnel who may not have been able to 

exit the protected space before the system discharge. The most useful of the approaches are: 

• C.10 Utilizing Light of Specific Wavelengths and Photo-luminescent Marking 

Systems 

• C.11 Decreasing Distance to Exits 

• C.12 Training 

We believe the combination of ..... 

• the favorable inhalation toxicity, dermal and ocular effects reported by the two laboratories, .... 

• the prevention techniques available for delaying system discharge until all personnel are 

evacuated from the protected space and .... 

• the NFPA 2010 mitigation approaches available to facilitate the safe egress of personnel who 

remained in the protected space during or after system discharge ..... 

 ..... serve as the basis 

for EPA to change the SNAP approval for Stat-X® Aero-K® to allow the use of our systems in normally 

occupied spaces 

Mark (X) this box if this page contains CBI __________x

 

6

 “NFPA 2010 - Standard for Fixed Aerosol Fire-Extinguishing Systems – 2010 Edition” National Fire Protection 

Association, Quincy, MA: August 2009. 
Form 1265-07 (Revised 09/2011) 10 

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Continuation Sheet 

Part I-B-2-a & b & c 

Manufacturing Constituents 

The Stat-X® Aero-K® formulation consists of three main constituents as shown in Table 1: 

 and an of the type: 

Table 1 

Manufacturing Constituents 

The combination of these three constituents are referred herein as the “generant.” The functions of the 

three constituents in the composition are: 

Discharged Agent Constituents

Upon ignition the composition reacts exothermically and produces a fine aerosol of particulate and gas 

which has an effective ability to interrupt the combustion process. 

 

 

 

 

 

Mark (X) this box if this page contains CBI __________x

 

7

 Tests conducted by . 
Form 1265-07 (Revised 09/2011) 11 

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Table 3 is an illustration of the particulate effluent percentages as submitted with the original SNAP 

Notice (EPA-HQ-OAR-2005-0087-0009). 

 

 

 

 

 

 

 

 

While the and data do not perfectly track, both sets of data are well within limits set by 

NIOSH which are illustrated in Table 5. 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 12 

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Table 5 

NIOSH Time Weighted Average Concentrations 

(ppm) 

Component 

IDLH 

(Immediately 

dangerous) 

Automobile Airbag 

Standard 

(TWA at 20 

minutes exposure) 

Carbon dioxide 40,000 40,000 

Carbon monoxide 1,200 445 

Ammonia 300 151.5 

Methane NE NE 

Nitrogen IV oxide 202 9.9 

Nitrogen II oxide 100 50.1 

Table 6 is a comparison of the Table 3 particulate data with the particulate data. Only a broad 

comparison is possible since the testing limited the identification of the particulate to broad 

categories of potassium, potassium nitrogen and other compounds. However, the study broadly 

confirms the values found in the work. 

 

 

 

 

 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 13 

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Continuation Sheet 

Part I-B-2-c 

System Description 

The Stat-X® Aero-K® system pyrotechnically generates a homogeneous mixture of gas and particulates 

that is discharged into a space containing a fire hazard or directly on the hazard itself, thereby 

extinguishing the fire. 

Figure 7 

Generator Discharging Agent 

The effluent is sufficiently non toxic that the generator can be discharged into normally occupied spaces 

for fire suppression. There are several applications for this technology ranging from industrial and marine 

fire hazards historically protected by halon 1301 or carbon dioxide systems. These applications would 

include the protection of selected spaces in aircraft, ships and vehicles – any of which might include 

military versions. 

The generator is intended to be installed to direct the discharge of the agent in a manner and at a distance 

that neither occupants nor combustible materials are subjected to temperature levels above those 

permitted in NFPA 2010 (75°C for occupants and 200°C for combustible materials). The discharge 

temperature of the gaseous effluents is controlled by the design of the heat management system. 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 14 

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Stat-X® Aero-K® generators are intended to be used either singly or several grouped together depending 

on the size of the hazard and the extinguishing concentration necessary 

Agent Effectiveness 

A single 500 gram (1.1 pounds) generator is capable of extinguishing a heptane fire in a volume of 265 

cubic feet with a safety factor of 1.3 on the agent quantity. This is comparable to 5.5 pounds of halon 

1301 at a 5% concentration to protect that same volume with a heptane fuel source. 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 

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15

Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION (Continued)

5. Impurities 

 (a) Identify each impurity that may reasonably be anticipated to be present in the chemical alternative as manufactured for commercial 

purposes. If there are unidentified impurities, enter “unidentified.” 

 (b) Provide the CAS Registry Number for each impurity if available. 

 (c) Estimate the maximum weight percentage of each impurity. If there are unidentified impurities, estimate their total weight 

percentages. 

There are no known impurities. The formulation uses reagent grade chemicals. 

6. Byproducts: 

 (a) Describe any byproducts or degradation products resulting from the manufacturer, processing, use or disposal of the chemical alternative 

or chemicals used in the new alternative. If there are unidentified byproducts/ degradation products enter “unidentified.” 

 (b) Provide the CAS Registry Number for each byproduct or degradation product if available. 

 (c) Indicate where the byproduct/degradation product is formed (e.g. during manufacturing, during use, in case of fire, etc.) and the amount 

or rate at which it is formed. 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226 

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16

Part II - ALTERNATIVE-SPECIFIC INFORMATION

Section A - PHYSICAL AND CHEMICAL PROPERTIES – See Appendix B to the Instructions to see which properties apply 

to which uses.

1.

 

 

 

 

 

 

21. 

27.

28. Flammability: Provide any information on flammability concerns. For example, if any abatement techniques are being used to

minimize the risks associated with flammable substances or mixtures, detail those techniques below. If a substitute is flammable, an 

assessment of overall risk in each end-use may be required. For flammable refrigerants, provide a fault tree analysis for each end use. 

For flammable foam blowing agents used in spray foam, provide a training program that addresses flammability concerns specific to this 

substitute. (See Appendix B to Instructions for sector-specific data requirements for flammable substances). 

The agent in its pressed form is flammable with an auto-ignition temperature of 300°C. However, it is 

contained within a double-walled, insulated, and hermetically sealed canister so exposure to flame is not a 

likely scenario. Ignition of the agent produces a fire suppressant aerosol that is extremely effective.

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 

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17

1. Ozone-depletion potential (ODP): 

 (a) Provide the 100 year ODP of the alternative relative to CFC-11, if known. If the substitute is a blend, provide the ODPs of the 

individual constituents. Reference the source for each ODP. 

 (b) Provide any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromine loading potentials). Reference 

the source of this information and attach any supporting documentation. 

Stat-X® Aero-K® contains no halogens and, therefore, has a zero ODP. 

2. Global Warming Characteristics: 

 (a) Provide the alternative’s atmospheric lifetime and global warming potential (GWP) relative to carbon dioxide over 100-year time 

horizon, and 20-year or 500-year time horizon, if known. Reference the most recent assessment report of the Intergovernmental Panel on 

Climate Change (IPCC AR4). Alternate sources may include the 2010 World Meteorological Organization (WMO) Scientific Assessment of 

Ozone Depletion or the peer-reviewed literature. If the substitute is a blend, provide the GWPs of the individual constituents and an estimate 

of the blend at its nominal composition. 

 (b) If known, provide the alternative’s expected impact on energy efficiency relative to the substance it is replacing (e.g. +/- X%) and results 

of any testing or modeling done (both theoretical and actual testing). Energy efficiency information is particularly useful for refrigerants and 

foams. 

 (c) For GWP values that do not come from AR4 or WMO 2010, provide any available additional data on the atmospheric lifetime and GWP 

of the alternative, including infrared absorption spectrum and infrared absorption capacity. Reference the source of this information. 

Mark (X) this box if this page contains CBI __________x

Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION
Form 1265-07 (Revised 09/2011) 

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18

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued) 

Section C - OTHER STATUTES AND STANDARDS 

1. Describe whether and how the manufacture, use, and disposal of the alternative is regulated under other environmental regulatory 

statutes such as those listed below. List any concentration-based or other numerical standards to which the alternative is subject under the 

standards and regulations. 

Titles of the Clean Air Act (CAA) other than Title VI: contains no hazardous air pollutants, no Class 1 ozone depleters 

and no Class 2 ozone depleters. 

the Clean Water Act (CWA): is not listed as a Hazardous Substance under the CWA, not listed as a priority pollutant and 

is not listed as a toxic pollutant under the CWA. 

the Safe Drinking Water Act (SDWA): None known. 

the Resource Conservation and Recovery Act (RCRA): has none listed for RCRA D-Series Maximum Concentration of 

Contaminants; RCRA D-Series Chronic Toxicity Reference Levels; RCRA F-Series; RCRA P-Series; nor RCRA U-Series.

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): is not controlled under FIFRA 

the Toxic Substances Control Act (TSCA): is listed on the TSCA inventory; is not on the Health & 

Safety Reporting List; is not under a Chemical Test Rule; is not listed under TSCA Section 12b; 

 does not have a SNUR under TSCA. 

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): does not have an RQ under 

CERCLA

the Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III): does not have an RQ (Section 

302); does not have a TPQ (Section 302). 

State and local laws: can be found on the following state right to know lists: New Jersey, Florida, Pennsylvania, 

Massachusetts. 

Other applicable environmental federal, state, and local laws not mentioned above: SARA Codes: flammable; 

 is not reportable under Section 313. 

2. Describe whether and how occupational, consumer, or general population exposure to the alternative is regulated under health and safety 

related statutory authorities, such as those implemented by the Food and Drug Administration (FDA), the Occupational Safety and Health 

Administration (OSHA), the Department of Transportation (DOT), and state and local laws. List any concentration-based or other numerical 

standards to which the alternative is subject under the above statutes and regulations. Also list any other standard-setting organizations such 

as the National Fire Protection Association (NFPA), the American Society of Heating, Refrigerating, and Air Conditioning Engineers 

(ASHRAE), or Underwriters Laboratories (UL) that will evaluate the substitute from a health and safety perspective. 

Food and Drug Administration (FDA) for Not applicable 

Occupational Safety and Health Administration (OSHA) and other Exposure Limits for 

NIOSH Exposure Limit: None Listed 

ACGIH Exposure Limit: None Listed 

OSHA Vacated PELs: None Listed 

Department of Transportation (DOT): is Hazard Class , Packing Group III 

State and Local Laws: California No Significant Risk Level: is not listed 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 

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Previous editions are obsolete 

19

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued) 

Section C - OTHER STATUTES AND STANDARDS 

1. Describe whether and how the manufacture, use, and disposal of the alternative is regulated under other environmental regulatory 

statutes such as those listed below. List any concentration-based or other numerical standards to which the alternative is subject under the 

standards and regulations. 

Titles of the Clean Air Act (CAA) other than Title VI: contains no hazardous air pollutants, no Class 1 ozone depleters and 

no Class 2 ozone depleters. 

the Clean Water Act (CWA): is not listed as a Hazardous Substance under the CWA, not listed as a priority pollutant and is 

not listed as a toxic pollutant under the CWA. 

the Safe Drinking Water Act (SDWA) ): None known.

the Resource Conservation and Recovery Act (RCRA): has none listed for RCRA P-Series and none listed for RCRA USeries.

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): is not controlled under FIFRA 

the Toxic Substances Control Act (TSCA): is listed on the TSCA inventory; is not on the Health & Safety 

Reporting List; is not under a Chemical Test Rule; is not listed under TSCA Section 12b; 

does not have a SNUR under TSCA. 

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): None of the chemicals in this material have an 

RQ. 

the Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III): does not have an RQ (Section 

302); does not have a TPQ (Section 302); is not reportable under Section 313. 

State and local laws: is not present on state lists from California, Pennsylvania, Minnesota, Massachusetts, Florida or New 

Jersey. 

Other applicable environmental federal, state, and local laws not mentioned above: None known 

2. Describe whether and how occupational, consumer, or general population exposure to the alternative is regulated under health and safety 

related statutory authorities, such as those implemented by the Food and Drug Administration (FDA), the Occupational Safety and Health 

Administration (OSHA), the Department of Transportation (DOT), and state and local laws. List any concentration-based or other numerical 

standards to which the alternative is subject under the above statutes and regulations. Also list any other standard-setting organizations such 

as the National Fire Protection Association (NFPA), the American Society of Heating, Refrigerating, and Air Conditioning Engineers 

(ASHRAE), or Underwriters Laboratories (UL) that will evaluate the substitute from a health and safety perspective. 

Food and Drug Administration (FDA) for Not applicable 

State and Local Laws: California No Significant Risk Level: is not listed 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

20

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued) 

Section C - OTHER STATUTES AND STANDARDS 

1. Describe whether and how the manufacture, use, and disposal of the alternative is regulated under other environmental regulatory 

statutes such as those listed below. List any concentration-based or other numerical standards to which the alternative is subject under the 

standards and regulations. 

Titles of the Clean Air Act (CAA) other than Title VI: contains no hazardous air pollutants, no Class 1 ozone depleters 

and no Class 2 ozone depleters. 

the Clean Water Act (CWA): is not listed as a Hazardous Substance under the CWA, not listed as a priority pollutant and 

is not listed as a toxic pollutant under the CWA. 

the Safe Drinking Water Act (SDWA): None known.

the Resource Conservation and Recovery Act (RCRA): is not a RCRA hazardous waste.

the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): is not controlled under FIFRA 

the Toxic Substances Control Act (TSCA): is not required to be on the TSCA list. 

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): is not a CERCLA chemical.

the Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III): does not have an RQ (Section 

302); does not have a TPQ (Section 302); is not reportable under Section 313. 

State and local laws: None known 

Other applicable environmental federal, state, and local laws not mentioned above: None known 

2. Describe whether and how occupational, consumer, or general population exposure to the alternative is regulated under health and safety 

related statutory authorities, such as those implemented by the Food and Drug Administration (FDA), the Occupational Safety and Health 

Administration (OSHA), the Department of Transportation (DOT), and state and local laws. List any concentration-based or other numerical 

standards to which the alternative is subject under the above statutes and regulations. Also list any other standard-setting organizations such 

as the National Fire Protection Association (NFPA), the American Society of Heating, Refrigerating, and Air Conditioning Engineers 

(ASHRAE), or Underwriters Laboratories (UL) that will evaluate the substitute from a health and safety perspective. 

Food and Drug Administration (FDA) for Not applicable 

Occupational Safety and Health Administration (OSHA) and other Exposure Limits for 

OSHA TLV TWA: 5mg/m3

Department of Transportation (DOT): is not regulated under DOT. 

National Fire Protection Association: has no NFPA rating. 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

21

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

1. Estimate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installation costs associated 

with the alternative. Please describe the information used as the basis for this cost estimate.

2. Provide information on production of the substitute. Include estimates on: 

 (a) Year substitute will be available if not currently produced. 

 (b) Total pounds production per year (current figure). 

 (c) Years to maximum market penetration. 

 (d) Maximum total production per year at market saturation. 

 (e) Estimated percentage of market at market saturation. 

(a) Currently produced 

3. Describe any new equipment and use profiles that will be necessary in order to use the substitute. If retrofitting of existing equipment is 

required, detail changes in technologies needed to use the alternative and address any materials compatibility issues. Provide information on 

each end-use and capital costs associated with the substitute or alternative process. Include cost of equipment and/or any new materials, 

equipment lifetime, changes in labor and energy costs.

Systems do not require pressure vessels or piping networks and are easily mounted in a distributed 

layout throughout the protected volume. Can be easily retrofitted into any area. Integrates with 

existing releasing panels and detection. Labor costs for installation are a fraction of that associated 

with other alternatives. Maintenance costs are also significantly reduced (minimal). 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

22

Part III - RELEASE AND EXPOSURE DATA

Section A - TOXICITY AND HAZARD INFORMATION

For chemical alternatives and for chemicals used with alternative processes, summarize below (and attach supporting information on) the 

acute and chronic toxicity of the substitute and of its constituent chemicals on any organism (e.g. human and/or other mammals, fish, 

wildlife, and plants), if available. Include any data on impurities and degradation products if known. Also include information on any 

permissible exposure limits (PELs), occupational exposure limits (OELs), or Acceptable Exposure Limits (AELs) that have been set for the 

substitute for use in the workplace. In addition, please attach a copy of any hazard warning statement, label, material safety data sheet, or 

other information which will be provided to any person who is reasonably likely to be exposed. (See Pgs. 16-17 of the Instructions for 

sector-specific requirements for toxicity testing). 

 

Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site (for manufacturing of substitutes and/or products containing substitutes): 

 (a) Identify all site locations (i.e., name and address) for each chemical manufacturing process. 

 (b) Identify all site locations for manufacturing of products using substitutes (e.g., refrigerators containing the substitutes). 

 (c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products containing the substitutes. 

 (d) Provide information on the magnitude of release if available, along with the media to which the substitute is released (e.g., indoor air, 

outdoor air, water, land). 

(a) Fireaway Inc., 1006 2nd Street – Area J, Camp Minden, LA 71005 

Chemicals are received in solid form at location (above). Potassium nitrate and DCDA are used as 

delivered. Resin is dissolved in acetone and mixed with other ingredients into granulated 

formulation, which is pressed into finished charge. Finished aerosol forming pellets are shipped to 

Fireaway in Minnesota for assembly into finished units. 

(b) Fireaway Inc., 5852 Baker Road, Minnetonka, MN 55345 

(c) All the three chemical constituents of Stat-X® Aero-K® are solids as is the final product. No 

releases are expected during manufacture or shipment. 

(d) N/A 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

23

Part III - RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

For each manufacturing site (manufacturing of substitutes and/or products containing substitutes): 

 (a) Describe the activities in which workers may be exposed to chemicals at the manufacturing facility. Answer items (b) through (g) for 

each activity. 

 (b) Describe any protective equipment and engineering controls used to protect workers (e.g., goggles, gloves, chemical hoods). 

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g., solid, liquid, gas). 

 (d) Estimate average and maximum numbers of workers involved in each activity. 

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year. 

 (f) Enter the contact pathway (e.g., ingestion, inhalation, dermal). 

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units of measure. 

(a) The two activities during which exposure is possible are processing chemicals into pressed 

charges and assembly of the generator containing the charge. 

(b) The production facility is ISO 9002 certified and qualified to MIL procedures. Employees utilize 

goggles, gloves, masks, chemical suits as appropriate to the operation. 

Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE

For each end-use of a substitute (end-uses using the substitute in products and/or processes): 

 (a) Provide the estimated amount (in kg/day) of each chemical released to the environment (e.g., as a solid waste or wastewater effluent) at 

the point of, or subsequent to, the end-use at a site using the substitute (e.g., in products containing the substitute and processes using the 

substitute). 

 (b) Identify the media (indoor air, outdoor air, land, water) to which the chemical will be released from that release point. 

 (c) Describe the control technology used to limit release; estimate the amount released to the environment with the control technology in 

place to limit release. If the substitute is to be disposed of, indicate the method and location of disposal. 

 (d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes. 

 (e) Identify the approximate number of sites expected to use the substitute. 

 (f) Provide information on recycling of the substitute. Describe any associated costs and equipment. 

(a) Releases will occur only when the device is used to extinguish or suppress a fire or explosion. 

The amount of release depends on the magnitude of the event. 

(b) The aerosol with gases will be released to the air. 

(c) Release is necessary to address the fire/explosion threat. 

(d) The particulate released to protect against fires and explosions are not covered under RCRA. 

Trace amounts of some gaseous byproducts 

 covered under RCRA are negligible. 

(e) Number of sites: Depends on market penetration, average size of protected volume, etc. Estimate 

<7,000. 

(f) Recycling of an agent used to extinguish fires and explosions is neither possible nor practical. 

Mark (X) this box if this page contains CBI __________x
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

24

Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the substitute (end-uses utilizing the substitute in products and/or processes): 

 (a) Describe the activities in which workers may be exposed to chemicals at the end-use (i.e., during installation, maintenance, inspection, 

servicing, or use). Answer items (b) through (g) for each activity. 

 (b) Describe any protective equipment or engineering controls used to protect workers (e.g., goggles, gloves, chemical hoods). 

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g., solid, liquid, gas). 

 (d) Estimate average and maximum numbers of workers involved in each activity. 

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year. 

 (f) Enter the contact pathway (e.g,. ingestion, inhalation, dermal). 

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units. Personal monitoring data 

may be required for some end uses (see pgs. 17-18 of Instructions). 

(a) No exposure possible during transportation, installation or maintenance. Chemical in solid form 

is contained within a double-walled, hermetically sealed metal cylinder. Exposure due to 

discharge unlikely. Systems are installed in unoccupied or normally unoccupied areas. Predischarge alarm and 60second time delay, system “lockout” mandatory if personnel may be in the 

area. 

(b) Exposure due to discharge unlikely. Systems are installed with pre-discharge alarm and 60second 

time delay, system “lockout” mandatory if personnel may be in the area. In event of discharge 

protective breathing apparatus and gloves required if entering area after the event. 

(c) No exposure during handling. In case of discharge aerosol consists of gas (30%) and solid 

particulate (70%). 

(d) Impossible to estimate – minimal. 

(e) N/A 

(f) N/A 

(g) N/A – maximum standard design concentration is 100g/m3. Average is 75g/m3. Actual exposure 

in event of accidental discharge would be much lower than these figures.

Section F - CONSUMER EXPOSURE

For each end-use of a substitute (end-uses where a consumer might be exposed): 

 (a) Identify the potentially exposed consumer population (e.g,. indoor residents). 

 (b) Identify the exposure medium (e.g., air). 

 (c) Enter the contact pathway (e.g,. ingestion, inhalation, dermal). 

 (d) Describe the exposure point of concentration. Provide (1) average and (2) high-end concentration estimates, including units of measure. 

(a) N/A 

(b) Air 

(c) Inhalation 

(d) N/A due to engineering and application restrictions. 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

25

Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULATION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes: 

 (a) Identify and number potential general population exposure points. 

 (b) For each exposure point described in (a), identify the potentially exposed population (e.g., residents at the fenceline to the 

manufacturing facility). 

 (c) Identify the contact pathway (e.g., ingestion, inhalation, dermal). 

 (d) Identify the exposure medium (e.g., air, water). 

 (e) Enter the exposure point concentration (mg/m3

 or ppb). Provide (1) average and (2) high-end estimates. 

(a) None at manufacturing. Product is manufactured in the center of a square mile rural site. 

(b) N/A 

(c) N/A 

(d) N/A 

(e) N/A 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

26

Part IV - LIST OF ATTACHMENTS

List below any attachments that complete the responses to the questions on this form or that provide additional information that may assist 

EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide citations for information already submitted to EPA as 

part of past regulatory and information activities, as well as for other information that could not be included with this submission. If you have 

attached continuation pages, describe the Part, Section and question number being continued. Attach additional pages if necessary. Mark (X) 

in the CBI box next to any attachment that contains information you claim as confidential.

Attachment Name Question # Number of Pages CBI

The following 5 documents are attached 

“Background Information for Revised Stat-X®/Aero-K® Risk 

Screen,” ICF to US EPA, January 31, 2007 Part I, Section B, 1 4 X 

“Risk Screen on Substitutes for Halon 1301 ..... Substitute: 

Stat-X®/Aero-K®,”ICF to US EPA, January 30, 2007 Part I, Section B, 1 7 X 

Hygiene-Institut-des-Ruhrgebiets Animal Exposure Study Part I, Section B, 1 12 X 

Charles River Animal Exposure Study Part I, Section B, 1 42 X 

MVA Particulate and Gas Effluent Report Part I, Section B, 2 81 X 

 

Documents not attached but supplied with initial submittal EPA-HQ-OAR-2005-0087-0009 

US Patent # 6089326 Part I, Section B, 2 

US Patent # 5865257 Part I, Section B, 2 

US Patent # 6116348 Part I, Section B, 2 

US Patent # 6264772 Part I, Section B, 2 

US Patent # 5831209 Part I, Section B, 2 

US Patent # 6042664 Part I, Section B, 2 

Gas Effluent Test Report (Talley Defense Systems) Part I, Section B, 6 

Physical Properties Document Part I, Section B, 6 

Ozone Depletion Report Part II, Section B, 2 

MSDS Aero-K® Part III, Section A 

MSDS Potassium Nitrate Part III, Section A 

MSDS DCDA Part III, Section A 

MSDS Organic Resin Part III, Section A 

Label (Current. Being revised with Underwriters Laboratories 

Canada) 

Part III, Section A 

 

Mark (X) this box if this page contains CBI __________
Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226 

Previous editions are obsolete 

27

Part V - CERTIFICATION

I certify to the best of my knowledge and belief that: 

1. All information provided in this notice is complete and truthful as of the date of the submission. 

2. I am submitting with this notice all test data in my possession or control and a description of all other data known to or 

reasonably ascertainable by me. 

3. If this is a submission of a new alternative, the company named in Part I, Question 1a of this notice: 

 (a) intends to manufacture, formulate, import, market, or use a new alternative to a Class I or Class II ozone-depleting 

substance which is identified in Part I, Section B, Question 2. 

 (b) seeks an acceptability determination on a new alternative(s) to a Class I or Class II ozone-depleting substance, which is 

identified in Part I, Section B, Question 2. 

4. The accuracy of the statements made in this notice reflects my best prediction of the anticipated facts regarding the 

alternative described herein. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to section 113(c) 

of the Clean Air Act and 18 U.S.C.§1001.

Signature and Title of Authorized Official (Original Signature Required): Date 

May 21, 2013 

 

Signature of Agent (Where Applicable): Date 

For persons filing a SNAP Information Notice, the reporting burden is estimated to average 171 hours per year. For 

persons filing a TSCA/SNAP Addendum, the reporting burden is estimated to average 36 hours her year. Burden 

means that total time, or financial resources expended by persons to generate, maintain, retain, or disclose or 

provide information to or for a Federal agency. This includes the time needed to review instruction; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying 

information; adjust the existing ways to comply with any previously applicable instructions and requirements; train 

personnel to be able to respond to a collection of information; search data sources; complete and review the 

collection of information; and transmit or otherwise disclose the information. An agency may not conduct or 

sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid 

OMB control number. 

Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any 

suggested methods for minimizing respondent burden, including through the use of automated collection techniques 

to the Director, Collection Strategies Division (2822T), U.S. Environmental Protection Agency,1200 Pennsylvania 

Ave NW, Washington, DC 20460. Include the OMB control number in any correspondence. Do not send the 

completed form to this address. 
ATTACHMENTS 1, 2, 3, 4, and 5 OF SUBMITTAL ARE

CONFIDENTIAL BUSINESS INFORMATION IN THEIR ENTIRETY