GLOBAL SAFETY LABS, INC.

Corporate Offices
4129 South 72 nd East Avenue

Tulsa, Oklahoma 74145

Telephone: (877) 800-1222 Toll-Free

(918) 551-5500 Local

Facsimile: (918) 551-5599

www.globalsafetylabs.com

December 22, 2009

DELIVERED VIA ELECTRONIC MAIL

Shimamura.Monica@ epamail.epa.gov

Ms. Monica Shimamura United States Environmental Protection Agency

Alternatives and Emissions Reduction Branch Stratospheric Protection Division Washington, D.C. 20460

Re: Response to Incomplete SNAP Submission for Arctic Fire-Freeze ® AllWeather 1115

Dear Ms. Shimamura:

This is Global Safety Labs’ formal res ponse to your letter dated December 10, 2009, wherein you identified our SNAP Information Notice form as incomplete. This letter seeks to supplement our original responses. Be low we have provided answers (in bold ) to each of your questions, in the order they are listed in your letter.

Questions in EPA Letter dated 12/10/2009 :

1. Clarification if Arctic Fire Freeze is used as a total flooding agent. Our understanding is
that we clearly should review it as a stream ing agent, and you will clarify if we also
should review it as a total flooding agent. (p. 4 on SNAP Information Notice, section
I.B.4)

ANSWER: To clarify, Arctic Fire-Freeze ® should be reviewed as a streaming agent. Pursuant to the test standards outlined in NFPA 2001 (Standard on Clean Agent Fire Extinguishing Systems) and NFPA 2010 (Standard for Fixed Aerosol Fire Extinguishing Systems), Arctic

Fire-Freeze ® does not meet the definition of a “total flooding agent” and, therefore, will not be used as a total flooding agent. MARTY J. ROWLAND

, Chief Operating OfficerResponse to Incomplete SNAP Submission Letter dated 12/10/2009

2 2. Information on molecular weight and on the perc ent of total by weight of each of the
individual components gaseous or particulate components (bef ore and after activation-if
different). (p. 6 in SNAP Information Notice form, section II.A.1).

ANSWER: We did not provide a molecular weight on p. 6 of our initial SNAP submission because our agent is a mixture (blend) consisting of different components. But the average molecular weight of our solution is approximately 112.4. We did provide, on p. 4, section I.B.2a, the individual weight percent ages of each component as we receive them prior to blending. To further clarify this information, we are providing the weight percent of each individual component as found in the final solution of our product. The molecular weights of each component are also given.

1. (2S,3R,4R,5R)-Hexane-1,2,3,4,5,6-hexol, 49 WT%, MW = 182.17

2. Ammonium dodecyl sulfate, 1.96 WT%, MW = 283.42

3. Propane-1,2-diol, 15 WT%, MW = 76.09

4. Oxidane, 34.04 WT%, MW = 18

( THIS ANSWER CONTAINS CIB – PLEASE KEEP CONFIDENTIAL )

3. Information on vapor pressure. (p. 6 in S NAP Information Notice form, section II.A.10)

ANSWER: A value for vapor pressure wa s not provided in our initial SNAP

submission because Arctic Fire-Freeze ® has high water content; we concluded the vapor pressure would not be appreciable. The vapor pressure of water is 2.4 kPa. Therefor e, Arctic Fire-Freeze’s vapor pressure will be slightly lower than 2.4 kPa

.

4. The applicable NFPA standards. A list of the most important applicable standards, by
number and name. (p. 8 on SNAP In formation Notice, section II.C.2)

ANSWER: NFPA 10 – Standard fo r Portable Fire Extinguishers.

5. Information on costs for appropriate equipmen t (p. 9 in SNAP Information Notice form,
section II.D.3)

ANSWER: For the commercial sector, Arctic Fire-Freeze ® is designed to be used
in pre-existing dispensing system s, and we do not anticipate new
equipment or retrofitting of existi ng equipment being required. For
the military sector, vehicle system requirements are currently underResponse to Incomplete SNAP Submission Letter dated 12/10/2009

3 development but are expected to utilize readily available dispensing
components to avoid the need for ne w equipment or costly retrofits.

6. Information on the magnitude of potential envi ronmental releases at manufacture. (p.10
in SNAP Information Notice, section III.B.(d))

ANSWER: Employees or workers may be exposed to the agent a) during the process of blending the agent, b) while transferring the agent to containers or extinguishers, and/or c) while refilling extinguishers or

containment vessels. Information is also provided on p. 10, sec. III.C.(a) & (b) of our initial SNAP submission.

Procedures to address agent spills are listed in p. 3, sec. VII of our agent Material Safety Data Sheet (MSDS), which states “Clean up spilled liquid wearing gloves and goggles . Ensure the area is dry to avoid slip hazards.” The waste fr om these spills should then be disposed of according to sec. VII of the agent MSDS, which states, “Dispose of in accordance with fed eral, state, and local laws.” Our agent MSDS is provided with th is letter as “Attachment A.”

In case of exposure to humans, personal protective equipment is identified in p. 3, sec. IX of ou r agent MSDS, identifying the wearing of “Gloves, splash goggles, or safe ty glasses.” Personal protective equipment is also identified by our answer on p.11, III.C.(b). The magnitude of release at manufacturi ng sites to both humans and the environments are minimal to none since the agent contains no hazardous components or harmfu l properties. Due to its low BOD/COD values, it is considered of low hazard and should be readily manageable in most wastewater treatment systems. The agent is environmentally and human friendly, readily biodegradable, and non-toxic, as reflected in sec. XII of the agent MSDS.

7. Information on the estimated number of sites ex pected for the end use. The application
currently contains information on the manuf acturing facility but the information should
refer to the end user. (p. 11 in SNAP In formation Notice form, section III.D.(e))

ANSWER: Within the next 1-2 years, we expect the U.S. military to be our largest
end user. Our agent would primaril y be used in Mine Resistant,
Ambush Protected (MRAP) vehicles. Currently, we approximate
there being up to 5,000 of these vehi cles that potentially may be
equipped with our agent. We also anticipate several thousand
handheld portable extinguishers being utilized by warfighters in the
field. We do not anticipate many (i f any) fixed user sites. WeResponse to Incomplete SNAP Submission Letter dated 12/10/2009

4 estimate that 6% of these vehi cles annually may discharge their
system(s).

8. Information on occupation exposure potential , estimating average and high-end exposure
concentrations, providing units of measure. (p. 12 in SNAP Information Notice form,
section III.E. (g)).

ANSWER: The answers we originally provided on p.12, section III.E (a-g) were answered from the perspective of a manufacturer. The following supplementary answers are provided to section III.E (a-g) from the perspective of the end user:

(a) Suppressing fires; discharging, filling, and recharging extinguishers.

(b) When possible and accessible, proper attire should be worn by an end user when fighting fires. When recharging extinguishers, goggles should be worn to prevent splashing into eyes. Gloves are not required but can be worn for additional safety.

(c) The agent is stored and applied as a liquid.

(d) Generally, one and occasionally two people are needed to fill and recharge the extinguishers. Only one person at a time can discharge an extinguisher while fighting a fire.

(e) A typical scenario would involve very little potential for exposure. In the Steel industry, a once a year ex posure or less is typical. An In-Cab extinguisher will empty in less than one minute. Therefore, typically there will be less than one minute’s worth of activity seen by a worker. The largest extinguisher we offer will empty in less than 12 minutes (if applied as foam). The use of these extinguishers depends on probability of a fire.

(f) Dermal and eye contact are possible. Likelihood of ingestion and inhalation are very low.

(g) This answer is identical to what we provided in sec. III.E.(g) of our initial SNAP submission, which is as follows: The agent is an aqueous solution with a density of 1.19 g/mL (1.19 x 10 9 mg/m 3 ). It is typically used at a 100% con centration level but can be diluted

with water to reduce the concentr ation percentage. Any amounts of vapor or gas resulting from wo rking with or in close proximity to the agent should be considered negligible.Response to Incomplete SNAP Submission Letter dated 12/10/2009

5 9. Flash point - Please provide documents used to determine the estimated flash point of
>200°C cited on p. 6 in SNAP Information Notice form, section II.A.23.

ANSWER: On December 14, 2009, our agent was tested according to ASTM D 3828, Method B for flash point by In tertek. Intertek’s Report of Analysis is attached to this letter as Attachment B. When we initially contacted Intertek, they informed us that this ASTM method was designed for petroleum-based pro ducts, as are ASTM 92 and ASTM 93. Therefore, as a testing facility, they would not recommend use of this method for non-petroleum base d products. They will, however, perform the test at the request of the customer, with appropriate notations made on the report.

After running the first test at 350°F , no flash point was detected, so

Intertek was reluctant to continue testing. They informed us verbally that due to the water content of our agent, and since water technically has no flash point, a flash point wo uld be prevented and not detected due to the humidity. For that reason, no flash was observed at 350°F. We have since updated our agent MSDS by removing our reference to a flash point (see Attachment A).

10. Information on how the fire suppression syst em works (p. 23 of form instructions):

(ANSWERS TO THIS QUESTION CONTAIN CIB – PLEASE KEEP
CONFIDENTIAL)

Below is a sketch of our Automatic Vehicle Fire Escape & Survival System
(AVFESS).

Fig. 1 - Standard HMMWV with an AVFESS. Fig. 2 - Translucent view of AVFESS.

The Automatic Vehicle Fire Extinguishment & Survivability System (AVFESS) is designed to protect a HMMWV and its

occupants from the dangers of a fire onboard. The AVFESS extinguishes any existing flames and prevents reignition of

the fire. Soldiers are able to remain in the vehicle under cover rather than needing to evacuate into hostile gunfire.Response to Incomplete SNAP Submission Letter dated 12/10/2009

6 The AVFESS may be activated by any one of the occupants of the HMMWV, at which point it will deploy the Arctic

Fire-Freeze ®

, protecting the occupants and vulnerable vehicle surfaces and extinguish the fire within seconds.

The AVFESS consists of Arctic Fire-Freeze ®

, fireproof conduit and strategically located spray nozzles. The control

system consists of rugged switches near the occupants and dependable solid state relays. When the system is
activated, it is instantly pressurized and the Arctic Fire-Freeze ® is delivered to the occupant space, engine

compartment and four wheel areas. The Arctic Fire-Freeze ® extinguishes nearly all fires within five seconds and

protects against re

‐ ignition. The AVFESS protects the crew from fires caused by an accidental or intentional event.

• Range of room or vehicle si zes likely to be protected with the fire suppressant.

ANSWER: This question is more applicable to a total flooding system. Our system is a streaming/misting system, designed using local application principles, where the agent is applie d directly onto a fire (usually a two dimensional area), or into the three dimensional region immediately surrounding the substance or object on fire. It is not a fixed system, so the agent is not limited by physical parameters.

• The release rate of the fire extinguisher.

ANSWER: Typically, 1-2 gallons per minute.

• The dispersion of the fire extinguisher ma terial (e.g., is the charge distributed
evenly throughout the room or vehicle?)

ANSWER: The agent is applied as li quid droplets to the fire or the
suspected fire path. It is more or less evenly applied to the

surfaces that are on fire or suspected to be on fire.

• The rate of airflow in the area in which th e fire extinguisher will be used (if this
information is available) or a recommenda tion of airflow rate that would provide
proper ventilation in areas where th e fire extinguisher would be used.

ANSWER: Rate of airflow and proper ve ntilation are issues typically more
relevant to non-liquid systems. Ou r system is liquid, non-toxic,
and yields no hazardous byproducts when dispersed. Proper
ventilation and airflow are not concerns, therefore, when
dispensing our product; so no formal data has been gathered

or is available.

If you decide the fire suppre ssant is a total flooding agent, then also please provide:

• Extinguishment Concentration (specify method)

ANSWER: N/A (Arctic Fire-Freeze is not a total flooding agent)Response to Incomplete SNAP Submission Letter dated 12/10/2009

7 • Design Concentration

ANSWER: N/A (Arctic Fire-Freeze is not a total flooding agent)

Thank you for reviewing this add itional data and information. We hope it is adequate to deem
our SNAP submission “complete” and to commence the 90-day review period. If you have
questions or require further clarification, please let us know. We look forward to your earliest
reply.

Sincerely yours,

Marty J. Rowland, Chief Operating Officer