Since the publication of our original article Environmental Regulations and HFC-based Clean Fire Extinguishing Agents in the February 2013 issue of International Fire Protection, two major pieces of environmental legislation have been introduced that substantiate the continued sustainability of HFCs in fire protection. In this article, we discuss the implications in fire protection of the US EPA Final Rule 20 and the EU F-Gas II Regulations.
Environmental impact: the scientific facts
- Ozone Depletion
Since hydrofluorocarbons (HFCs; e.g., FM-200) do not contain chlorine or bromine, they do not contribute to the destruction of stratospheric ozone; as a result, HFCs are not subject to the provisions of the Montreal Protocol, which pertain only to ozone depleting substances (ODSs).
- Global Warming
The impact of HFCs in fire protection on global warming/climate change is often misunderstood and misrepresented. It is important to understand that the impact of a gas on climate change is a function of both the GWP of the gas and the amount of the gas emitted. For example, carbon dioxide (CO2) has one of the lowest GWP values of all GHGs (GWP=1), yet due to the massive amounts of CO2 released into the atmosphere from numerous sources emissions of CO2 account for approximately 85% of the impact of all GHG emissions. Clearly, the GWP value by itself cannot be employed to evaluate the environmental sustainability of a particular compound. Emissions of HFCs from fire suppression applications are extremely low, hence the impact of these emissions on climate change is negligible.
Information related to the environmental impact of HFCs in fire protection is available from several independent sources, including the US EPA [1] and the European Environment Agency [2], and indicates that the contribution to global warming of HFCs in fire protection is negligible. For example, in the US the impact on global warming of HFCs in fire protection represents 0.019% of the impact of all greenhouse gases on global warming. For the EU-15 countries, the impact on global warming of HFCs in fire protection represents 0.05% of the impact of all greenhouse gases on global warming.
Historical data reveals that the contribution of HFCs in fire protection to global warming has remained essentially constant for almost a decade. As seen in Figure 1, the 2015 report from the HFC Emissions Estimating Program (HEEP) indicates the impact of HFCs in fire protection is not increasing significantly and has remained steady for more than a decade, despite the growing installed base.
Not all hfcs are created (or treated) equally
Figure 2 shows that the impact of HFC emissions on global warming from other much larger and much more emissive HFC applications such as refrigeration dramatically dwarfs the impact of HFCs in fire protection applications.
Regulatory bodies understand the above scientific facts and to date HFCs in fire suppression applications have been subject to different sets of regulations. For example, since 2006 the original European Union F-Gas Regulation has treated HFCs in highly emissive applications such as mobile air conditioning (MAC) differently than HFCs in fire protection applications: HFCs in MAC applications are regulated under a separate MAC Directive of the F-Gas Regulations.
US EPA final rule 20
On July 20, 2015 the U.S. EPA published its Final Rule on the Change of Listing Status for Certain Substitutes under the Significant New Alternatives Policy (SNAP), also known as US EPA Final Rule 20. The US EPA explains their reason for the listing status changes on the first page of the document: “We make these changes based on information showing that other substitutes are available for the same uses that pose lower risk overall to human health and the environment.” The Final Rule will change the approval status of certain HFCs in refrigeration, foam expansion and aerosol propellant applications.
The effects of Final Rule 20 on HFCs in fire protection? None whatsoever. Under Rule 20 there are no changes to the listing status of any HFC in any fire protection application, and the HFC-based clean agents continue as approved, effective and sustainable fire protection solutions. The Final Rule is consistent with the negligible impact of HFCs in fire protection on global warming, and in addition is consistent with the lack of alternatives which match the overall combination of proven performance, safety in use and cost effectiveness offered by the HFC clean agents.
European Union F-Gas II Regulations
- Original EU F-Gas Regulation
Regulation (EC) No 842/2006 of the European Parliament and of the Council on certain fluorinated greenhouse gases, the original “EU F-Gas Regulation,” published on May 17, 2006, and entered into force in 2007. The primary objective of EC 842/2006 was to prevent and reduce emissions of HFCs. EC 842/2006 included, in Articles 3 through 10, requirements related to the prevention of leakage (containment), recovery, personnel training, record keeping, reporting and labeling, all with the goal of reducing unnecessary emissions. The regulation recognized fire suppression applications as essentially non-emissive, and imposed no restrictions on the use of HFCs in fire suppression applications. For a detailed review of the original F-Gas Regulations and HFC clean agents, see the February 2013 issue of International Fire Protection.
- EU F-Gas II Regulation
Regulation (EU) No 517/2014 of the European Parliament and of the Council of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No. 842/2006, also known as the “EU F-Gas II Regulation,” entered into force on 1 January 2015 and repealed and replaced the original EU F-Gas Regulation. Consistent with US EPA Rule 20, the EU F-Gas II Regulation also recognizes the value and sustainability of the HFC clean agent fire protection technologies – since HFCs in fire protection have a negligible impact on global warming, restricting HFC use in fire protection applications would not provide any significant reduction in global warming.
The EU F-Gas II Regulation retains the requirements of Articles 3 through 10 from the original EU F-Gas Regulation related to containment, recovery and training – as a result, the fire protection industry is already complying with these requirements. EU F-Gas II requirements related to containment, including leakage prevention, repair and inspection schedules, are satisfied by the existing inspection regimes established in the ISO 14520, EN 15004 and NFPA 2001 standards. Numerous commercial entities, already actively involved in the recovery, reclamation and recycling of HFC-based clean fire extinguishing agents, currently meet the recovery-related requirements of the EU F-Gas II Regulation. Training and certification programs for personnel involved in the handling of fluorinated GHGs have been in place for more than a decade within the fire protection sector, meeting the training requirements of the EU F-Gas II Regulation. In summary, the requirements of Articles 3 through 10 of the EU F-Gas II Regulation involve activities already part of any responsible product stewardship program and impose no additional restriction or burden on the use of HFC-based clean agents.
- EU F-Gas II Allocation Quotas
A significant change from the original EU F-Gas Regulation of 2006 is the creation of allocation quotas. Article 16 of the F-Gas II Regulation establishes an allocation of quotas for placing HFCs on the market in the EU each year; Article 15 requires that producers and importers not exceed their quota. Article 16 establishes a reference value for producers and supporters, based on the annual average of quantities of HFCs (expressed in terms of CO2 equivalents) each have placed on the market from 2009 to 2012. The reference value is calculated in accordance with Annex V of the Regulation and quotas are then allocated employing the reference value and the allocation mechanism described in Annex VI of
the Regulation.
The allocation framework of the F-Gas II Regulation does not inhibit or limit the sale of HFCs into the fire suppression market. The allocation scheme represents an overall “cap and reduction” of HFCs on a GWP-weighted basis over a specific time period – a “phase-down,” NOT a “phase- out” of HFCs. The phase-down mechanism involves a gradually declining cap on the total of bulk HFCs (in tonnes of CO2 equivalents) placed on the EU market: with a freeze in 2015, followed by a first reduction in 2016 and by 2030 reaching 21% of the levels sold in 2009 to 2012. An important aspect of this allocation scheme is that it does not restrict the amount of any particular HFC placed on the market or the amount of HFCs used in any particular application; it simply restricts the total CO2 equivalents of all HFCs that can be placed on the market in a given year. Table 1 shows the schedule as indicated in
Annex V of the Regulation.
Figure 3 provides a graphical representation of the EU F-Gas II allocation scheme. The HFC phase-down, as stipulated by the EU F-Gas II Regulation is unlikely to affect the supply of HFCs available for fire protection in the EU market. Fire protection represents only 1% of the EU HFC market on a mass basis and 3% of the total EU HFC market on a GWP-weighted basis [3]. As seen in Figure 3, HFCs in refrigeration, foam blowing and aerosol propellant applications account for almost the entire EU HFC market. In the future the allocations required for these markets will be only a fraction of what is required today, due to the replacement of HFCs in refrigeration, propellants and foam expansion. For example, the need for HFC refrigerant allocations is already decreasing as the mobile air conditioning industry migrates from HFC-based to HFO-based technologies. HFO-1234yf is already installed in over 6 million automobiles, and is projected to be installed in approximately 18 million automobiles globally by 2016. Additional regulatory constraints on specific HFCs in refrigeration and other non-fire protection applications, along with the shrinking requirements of the HFC refrigeration market, will result in unused allowances, providing more than enough rights for HFCs used in fire protection.
Conclusion
The emissions of HFCs in fire protection are extremely low; hence their impact on global warming is negligible. As a result, restricting HFC use in fire protection applications would not provide any significant reduction in global warming and regulators can provide greater benefit to the environment with more focus on sectors with much larger impacts. Regulators clearly understand this, as evidenced by the recent decisions of the US EPA and European environmental regulators. US EPA Final Rule 20 and the EU F-Gas II Regulation are based on sound science and recognize the value, importance, and non-emissivity of HFC clean agents in fire protection.
With the recent major regulatory decisions in the USA and Europe, HFCs in fire protection remain approved, effective and sustainable fire protection solutions.
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About the Author
Mark L. Robin is Senior Technical Services Consultant, Specialty Fluorochemicals at Chemours.
