Up in the Air

By Bill Polits

This thumbnail sketch of the history of the role of fire suppression agents and the environment will go a long way to orienting you toward the impact of current national and international regulations.

The 1930's saw a rise in activity to develop CFCs and other haloalkanes for use in refrigeration and fire suppression. By the late 1960's halon began to be used widely in fire suppression applications of many kinds and CFC-based refrigerants were being very widely used.

In the 1970's, climate scientists began to notice that the level of stratospheric ozone in the atmosphere - a critical shield protecting the surface of the earth from harmful ultraviolet radiation from the sun - was dipping dangerously low. They found that man-made chemicals, collectively known as Ozone Depleting Substances (ODS), were contributing to the loss of the ozone layer.

Concern raised by the scientific community translated into international regulations via the Vienna Conference of 1985, which resulted in the Montreal Protocol. Ratified in 1989, this treaty required a reduction in the amount of ODS (including halon) over time, and resulted in the ceasing of all halon production in industrialized countries by 1994. With respect to the stratospheric ozone layer, the Montreal Protocol has been declared a success as the rate of ozone depletion has slowed dramatically, and is expected to return to normal levels sometime in the next 50 years.

In the meantime, however, climate scientists have identified yet another man-made threat to the environment - global warming. Human activity, principally the burning of fossil fuels but also the production and accidental release of chemicals including hydrofluorocarbons (HFCs) are heating up the atmosphere, and, if predictions hold true, will have devastating effects on the ecosystem unless dramatic reductions take place. HFCs were developed as replacements for the refrigeration and fire suppressant chemicals that science had found to be corrosive to stratospheric ozone. The irony is that some of these "ozone friendly" replacements have global warming potential (GWP) ratings thousands of times higher than that of carbon dioxide, and in some cases much higher than Halon 1211 and 1301. It is here that the current battle lines are being drawn with respect to fire suppression and environmental regulations.

There are three current fronts with respect to regulations of HFCs: 1) Climate and Energy legislation currently under consideration in the United States Congress; 2) the United Nations Framework Convention on Climate Change's (UNFCCC) Copenhagen Conference, December 7 - 18, 2009, which is essentially a successor to the Kyoto Protocol, with the goal to develop international agreement about greenhouse gas emissions, and 3) current efforts by the United States, Canada, Mexico and other countries to regulate HFCs under the Montreal Protocol, thereby shifting the focus of that agreement to the job of regulating greenhouse gases.

The amount of halons, HCFC, HFC used for fire protection is only a fraction of what is used for refrigeration.

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Acronym	Name
UNEP	United Nations Environmental Program
IPCC	Intergovernmental Panel on Climate Change
UNFCCC	United Nations Framework Convention on Climate Change, Adopted May 1992
CARB	California Air Resources Board
HARC	Halon Alternatives Research Corporation
IASFPWG	International Aircraft Systems Fire Protection Working Group
LEED	Leadership in Energy and Environmental Design
USGBC	United States Green Building Council

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This legislation, a product of Representatives Henry Waxman (D-California) and Edward Markey (D-Massachusetts) was introduced to the United States House of Representatives in March of 2009, and passed a full vote on June 26, 2009, with a vote of 219-212. The bill supports energy independence, green energy jobs and provides a cap and trade system to provide a greenhouse gas emission reduction of 83% of 2005 levels by the year 2050. HFCs are regulated under the cap and trade scheme and there is no exemption for fire extinguishing agents. Depending on where cap levels are set and what happens in carbon markets, the bill would impact the price of HFCs.

For more details on H.R. 2454, click here.

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Members of the United States Senate introduced their own climate bill on October 1, 2009, as a response to the House bill which passed in June. Sponsored by Barbara Boxer (D-California) and John Kerry (D-Massachusetts), the bill is said to contain provisions to even more aggressively cut greenhouse gas emissions. More details will be posted here as they become available.

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Cap and trade – otherwise known as emissions trading – is an administrative method of achieving reductions in emissions of pollutants. A central authority sets a "cap", or limit, on the amount of emissions that are allowable under the scheme, and emitters are allowed to buy credits to offset the emissions they create. These credits are generated and offered for sale by potential emitters who have taken steps to lower their emissions below the level of their cap. Trading of these credits is carried out through markets which are regulated by the central authority. The effect of this activity is to create a cost for those who emit pollutants while creating a benefit for those who reduce their emissions of pollutants.

For more on Cap and Trade, click here.

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Montreal Protocol - an international treaty designed to protect the ozone layer by phasing out the production of a number of substances believed to be responsible for ozone depletion.

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Kyoto Protocol - an international environmental treaty with the goal of achieving stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system.

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Copenhagen, December 2009 – From December 7 – 18, 2009, the 15th meeting of the Parties of the United Nations Framework Convention on Climate Change (UNFCCC) will occur in Copenhagen, Denmark. According to the Bali roadmap, a framework for climate mitigation beyond 2012 will be agreed upon there. For a complete reference guide on the activities of the UNFCCC, including the Copenhagen meeting, click here.

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This advisory circular provides guidance on how to deal with in-flight fires, emphasizing the importance of crew members taking immediate and aggressive action in response to signs of an in-flight fire while stressing the effectiveness of halon extinguishing agents.

Click here to view the Advisory Circular (PDF).

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This report provides the technical basis for an update of guidance on the use of hand-held fire extinguishers on aircraft contained in FAA Advisory Circular 20-42C http://www.fire.tc.faa.gov/pdf/AC20-42C.pdf. Safe-use limits are established for halon and replacement extinguishing agents by using an instantaneous blood concentration of halocarbon as a criterion for adverse effect instead of a critical dose (concentration-time product).

This report is controversial because of the methodology used, and the fact that from a toxicity standpoint, it favors HFC extinguishing agents – which have very high GWP – over Halon 1211, despite, as the report states, "Halon 1211 has a history of over 25 years of safe use. This safe-use history may be used to justify the 4-percent-minute AC20-42C limits as acceptable, while agent is being phased out."

Click here to view the Guidelines (PDF).

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The Environmental Protection Agency is taking final action to grant a specific exemption from requirements to petition the Agency in order to import used ozone-depleting substances. The exemption would apply to entities that import spherical pressure vessels containing halon 1301 for aircraft fire extinguishing (``aircraft halon bottles'') for purposes of hydrostatic testing. This final rule reduces the administrative burden on entities that are importing aircraft halon bottles for the purpose of maintaining these bottles to meet commercial safety specifications and standards set forth in airworthiness directives of the Federal Aviation Administration. This action does not exempt entities that import bulk quantities of halon-1301 in containers that are being imported for other purposes.

Click here to view the Aircraft Halon Bottle Rule document.

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