GLOBAL SAFETY LABS, INC.

Corporate Offices 

4129 South 72nd 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 response 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. Below 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 streaming 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 Officer 

 

 
Response to Incomplete SNAP Submission Letter dated 12/10/2009 

2 

2. Information on molecular weight and on the percent of total by weight of each of the 

individual components gaseous or particulate components (before 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 percentages 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 SNAP Information Notice form, section II.A.10) 

ANSWER: A value for vapor pressure was 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. Therefore, 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 Information Notice, section II.C.2) 

ANSWER: NFPA 10 – Standard for Portable Fire Extinguishers. 

5. Information on costs for appropriate equipment (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 systems, and we do not anticipate new 

equipment or retrofitting of existing equipment being required. For 

the military sector, vehicle system requirements are currently under 
Response 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 new equipment or costly retrofits. 

6. Information on the magnitude of potential environmental 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 from these spills should then be 

disposed of according to sec. VII of the agent MSDS, which states, 

“Dispose of in accordance with federal, state, and local laws.” Our 

agent MSDS is provided with this letter as “Attachment A.” 

In case of exposure to humans, personal protective equipment is 

identified in p. 3, sec. IX of our agent MSDS, identifying the wearing 

of “Gloves, splash goggles, or safety glasses.” Personal protective 

equipment is also identified by our answer on p.11, III.C.(b). The 

magnitude of release at manufacturing sites to both humans and the 

environments are minimal to none since the agent contains no 

hazardous components or harmful 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 expected for the end use. The application 

currently contains information on the manufacturing facility but the information should 

refer to the end user. (p. 11 in SNAP Information 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 primarily be used in Mine Resistant, 

Ambush Protected (MRAP) vehicles. Currently, we approximate 

there being up to 5,000 of these vehicles 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 (if any) fixed user sites. We 
Response to Incomplete SNAP Submission Letter dated 12/10/2009 

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estimate that 6% of these vehicles 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 exposure 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 109 mg/m3). It 

is typically used at a 100% concentration level but can be diluted 

with water to reduce the concentration percentage. Any amounts 

of vapor or gas resulting from working 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 Intertek. 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 products, as are ASTM 92 and ASTM 

93. Therefore, as a testing facility, they would not recommend use of 

this method for non-petroleum based 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 would 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 system 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 sizes 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 applied 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 material (e.g., is the charge distributed 

evenly throughout the room or vehicle?) 

ANSWER: The agent is applied as liquid 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 the fire extinguisher will be used (if this 

information is available) or a recommendation of airflow rate that would provide 

proper ventilation in areas where the fire extinguisher would be used. 

ANSWER: Rate of airflow and proper ventilation are issues typically more 

relevant to non-liquid systems. Our 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 suppressant 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 

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• Design Concentration 

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

Thank you for reviewing this additional 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