HALON 1211 REPLACEMENTS
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Overview: |
Alternative fire suppression agents for Halon 1211 have been identified and are being used in the services for some military applications. Halon 1211 is a widely used fire suppression and explosion protection agent applied as a streaming agent and has been the fire extinguishing agent of choice for portable fire extinguishers in many aircraft, including the C-130. However, there are still applications which do not have suitable Halon substitutes. These operations are currently supported through the DoD Ozone Depleting Substances (ODS) Reserve. Halon has one of the higher ozone depletion potentials of any compound, and thus its production and use are being curtailed and eventually eliminated. The Montreal Protocol (1987 and subsequent) and the Clean Air Act Amendments (1990) identify Halon 1211 as a Class I ODS and established a ban on it’s domestic production effective 31 Dec 1993. Currently, halon use is restricted to recycled halon. It is estimated that recycled halon will be available until the end of Fiscal Year 2003. In order for a substitute to be approved, it must pass certain requirements. These requirements are specific for each branch of the service. The requirements for the Army are: 1) SNAP approval and 2) Toxicology clearance from the Army Surgeon General. Both of these requirements must be approved for both the specific application as well as the specific alternative agent. For the Air Force, the specific application and alternative agent must comply with AFI-32-7086 “Hazardous Materials Management”, and must not impose a greater environmental or safety risk than Halon 1211. If the application is questionable, it must undergo an Environmental Safety and Occupational Health evaluation. The Navy’s requirements are: 1) SNAP approval and 2) An ozone depleting potential (ODP) for the alternative of 0.05 or less (OPNAVINST 5090.1B, Environmental and Natural Resources Program Manual” 1 Nov 94).
In addition to these requirements, the applicable program office (for a weapon system) or fire chief (for an installation) will have regulations and directives that must be satisfied before substitutions are made. Ultimately, it is up to the program office or fire chief to make the substitution, not the user.
There are several Halon 1211 substitutes approved by the EPA’s Significant New Alternatives Policy (SNAP) program. Although none is an ideal replacement for Halon 1211, they may be considered candidates for substitution, subject to specific use conditions as cited in 40 CFR 82 Appendix A to Subpart G, "Substitutes Subject to Use Restrictions and Unacceptable Substitutes." The following substitutes are listed:
The following are acceptable subject to Narrowed Use Limits
In addition, HFC-236fa (FE-36), HFC-227ea and water mist with additives are pending a decision from EPA The majority of Halon 1211 portable fire extinguishers found inside buildings can be replaced with dry chemical extinguishers and/or carbon dioxide extinguishers. However, research and implementation is still ongoing to identify replacements for Halon 1211 extinguishers used in weapon system/specialty applications (fire and rescue vehicles on flight-lines and carrier decks, portable (wheeled) flight-line fire extinguishers, etc.) A substitute compound may not be as effective in extinguishing a fire, and so a higher concentration or greater quantity of the extinguishing may be required. The alternative for any application should be carefully reviewed for applicability to the use conditions. There are several steps that must be taken in order to provide a suitable substitute for Halon 1211:
Halon 1211 for use in mission critical applications is supplied by DLA from the Defense ODS Reserve. Procurement of Halon 1211 for any other uses requires a certification by an authorized technical representative (ATR) and approval by a senior acquisition official (SAO) at the flag/general officer or civilian SES level in accordance with the specific Service guidance implementing this law, Section 326 of the FY-93 Defense Authorization Act which is also identified as Public Law 102-484. Furthermore, excess Halon 1211 removed from non-mission-critical applications should be returned to the Defense ODS Reserve in accordance with Service procedures. Further information on return procedures can be obtained from Defense Supply Center, Richmond at (804) 279-4525/5203. |
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Compliance Benefit: |
Switching from Halon 1211 (a class I ozone-depleting chemical) to an approved non-ozone depleting alternative will help facilities meet the requirements under 40 CFR 82, Subpart D and Executive Order 12843 requiring federal agencies to maximize the use of safe alternatives to Class I and Class II ozone depleting substances, to the maximum extent practicable. In addition, the elimination of halon at the facility decreases the possibility that the facility would meet any of the reporting thresholds under 40 CFR 370 and EO 12856. Chemicals used as substitutions should be reviewed for SARA reporting issues. The compliance benefits listed here are only meant to be used as a general guideline and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g. the amount of workload involved.
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Materials Compatibility: |
Prior to replacing any halon system, the impact on the hardware should be evaluated. An impact could be caused by the alternative chemical agent, the hardware associated with the use of that agent, or by-products of the pyrolysis. An engineer who is experienced in fire protection system design should be consulted.
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Safety and Health: |
Consult your local Industrial Health specialist, your local health and safety personnel, and the appropriate MSDS prior to implementing any of these technologies.
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Benefits: |
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Disadvantages: |
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Economic Analysis: |
Use of pollution prevention funds for replacement of Halon fire extinguishing systems with non-Halon based systems is not authorized if the reason for conversion is that the existing system has reached the end of its life expectancy. The economic feasibility of each substitute is highly dependent on the application. The following provides some examples of alternative fire fighting equipment available from GSA and other sources. CO2 IAW CID A-A-52471-1-S2.5 lbs., carbon dioxide, hand operated, squeeze grip, includes vehicle bracket. Approved replacement for NSN 4210-00-555-8837 (2.75 lb. Halon fire extinguisher). NSN: 4210-01-364-1623, $114.13 IAW MIL-E-24269,
class 1 IAW CID A-A-1106
Ansul Inc. Dry Chemical Amerex ABC Dry Chemical |
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Approving Authority: |
Approval is controlled locally for non-mission critical applications and major claimant approval is not required. Mission-critical applications are under the cognizance of the appropriate system command and should be implemented only after the system command grants engineering approval. |
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NSN/MSDS: |
*There are multiple MSDSs for most NSNs. The MSDS (if shown above) is only meant to serve as an example.
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Points of Contact: |
Army: Marine Corps: Navy: Mr. Joseph Gott
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Vendors: |
Ansul Fire Protection Amerex Corporation Buckeye Fire Equipment
Co. Pem All Fire Extinguisher
Corp.
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Sources: |
Dave Koehler, Ocean City Research Corp., August
1998 |