International Coordinating Council of Aerospace Industries 

Associations

c/o Aerospace Industries Association

1000 Wilson Boulevard, Suite 1700

Arlington, VA 22209-3928 

United States of America

info@iccaia.org www.iccaia.org 

AeroSpace and Defence Industries Association of Europe • Aerospace Industries Association of America • Aerospace Industries Association of Brazil

Aerospace Industries Association of Canada • Society of Japanese Aerospace Companies • Union of Aviation Industrialists 

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Mr. James Jones 

Assistant Administrator 

Office of Chemical Safety and Pollution 

Prevention 

1201 Constitution Ave. NW 

Washington, DC 20460 

Ms. Janet McCabe 

Assistant Administrator 

Office of Air and Radiation 

Environmental Protection Agency 

William Jefferson Clinton Building 

1200 Pennsylvania Avenue, N. W. 

Mail Code: 6101A 

Washington, DC 20460 

18 December 2015

ICCAIA/AWC/094

Subject: ICCAIA Cabin Safety Working Group, Fire Extinguishing Agent AMPAC 2-BTP, 

Request to Expedite Review and Approval 

Reference: Case #P-14-0260 - 2-bromo-3,3,3-trifluoropropene (2-BTP) 

Dear Assistant Administrators Jones and McCabe: 

We are writing to request that the EPA expedite review and approval of 2-BTP, an 

environmentally friendly alternative to halon-based extinguishing agents currently used in handheld fire extinguishers on commercial airplanes. 

Being an accredited body to the International Civil Aviation Organization (ICAO), ICCAIA 

represents aircraft manufacturers in the United States, Europe, Canada, Brazil , Russia and Japan. 

Under ICCAIA leadership, working groups provide industry positions to support ICAO in 

developing Standards and Recommended Practices (SARPS) which ICAO contracting Nations 

are obliged to implement into their national regulations or to consider as guidance materials. 

Under the oversight of the ICCAIA Airworthiness Committee, the ICCAIA Cabin Safety 

Working Group is tasked to work on all cabin safety regulatory issues, including firefighting and 

related equipment standards. 
 

AeroSpace and Defence Industries Association of Europe • Aerospace Industries Association of America • Aerospace Industries Association of Brazil

Aerospace Industries Association of Canada • Society of Japanese Aerospace Companies • Union of Aviation Industrialists 

Page 2 of 3

Decades of experience with the complex scenario of firefighting in an occupied aircraft cabin or 

cockpit in flight has led to halon 1211 becoming the preferred fire extinguishing agent in 

transport aircraft providing sufficient fire-fighting properties, being non-toxic to occupants, and 

allowing equipment small and light enough to be used in an emergency situation in the confines 

of an aircraft cabin or cockpit. 

However, in order to implement the Montreal Protocol on Ozone Depleting Substances with its 

production ban of halons, in 2011 ICAO published revisions to its Annex 6 “Operation of 

Aircraft” requiring that all aircraft placed into service on or after December 31st 2016 be 

equipped with halon-free handheld fire extinguishers. 

Currently there are no approved fire extinguishing agents available which are equivalent to halon 

1211 in all relevant aspects. To provide the fire-fighting capacities of halon 1211, extinguishers 

with currently approved alternative agents are significantly heavier and larger. As such, these fire 

extinguishers (agents) would result in severe impacts on cabin/cockpit design, equipment 

accessibility and handling by aircraft crews. Further, some currently-approved halon-free 

extinguishing agents are expected to be subject to future environmental restrictions in production 

and use. 

From an environmental perspective, the best solution would be a non-ozone depleting substance 

(ODS) with low global warming potential (GWP) which can serve as a “drop-in” replacement 

for halon 1211 extinguishers. In discussions with ICAO and aviation regulators (such as the US 

FAA), aircraft OEM experts are focused on 2-BTP which is currently being reviewed by the 

EPA for approval. EPA SNAP approval is one of the pre-requisites for agent manufacturers to 

establish economically viable agent production, agent recycling, and product support programs 

for civil aviation. This is because civil aviation is a high-risk industry but relatively small sector 

needing only a limited quantity of fire-fighting agents but requiring reliable product quality and 

availability for several decades. 

The agent 2-BTP, developed by the US manufacturer AMPAC, is a non-ODS and has a GWP of 

less than 1. It would allow compliance with the Montreal Protocol and related national 

implementing regulations. Due to its composition it is not subject to future production bans 

under HFC-regulations. 

With regard to fire-fighting, 2-BTP has passed UL fire tests and the US FAA Minimum 

Performance Standards. Although 2-BTP fire extinguishers are slightly heavier than current 

halon fire extinguishers, they are sized to be drop-in replacements, so the impacts on aircraft 

design, safety and fire-fighting procedures would be minimal. Drop-in replacement fire 

extinguishers will enable airline operators to more easily retrofit their fleets, and therefore will 

likely result in more rapid removal of halon from airplanes and the associated environmental 

benefits. 
 

AeroSpace and Defence Industries Association of Europe • Aerospace Industries Association of America • Aerospace Industries Association of Brazil

Aerospace Industries Association of Canada • Society of Japanese Aerospace Companies • Union of Aviation Industrialists 

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Taking into account the time needed to develop, certify and introduce aviation-approved fireextinguishing equipment into the fleet of commercial airplanes, the aircraft OEMs are concerned 

about the lack of any reliable schedule regarding an EPA decision on 2-BTP approval. 

To overcome this situation, the aircraft OEMs organized in ICCAIA respectfully request that 

EPA expedite the review/approval, or grant an approval with restrictions or requirements for 

mitigation means, to allow 2-BTP production and use for aviation handheld fire-extinguishers. 

The ICCAIA Cabin Safety Working Group thanks EPA for considering this request. We would 

be happy to provide any aircraft-related information needed to complete your approval process 

as we both work towards our joint goal of environmental protection. 

Respectfully, 

Simon Lie 

Chair, ICCAIA Airworthiness Committee 

Tim Holey 

Chair, ICCAIA Cabin Safety Working Group