H3R Clean Agents
  • GOVERNMENT REGULATION
    1
    The Montreal Protocol on Substances that Deplete the Ozone Layer

    The Montreal Protocol on Substances that Deplete the Ozone Layer is 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. The treaty was opened for signature on September 16, 1987 and entered into force on January 1, 1989. It has undergone five revisions, in 1990 (London), 1992 (Copenhagen), 1995 (Vienna), 1997 (Montreal), and 1999 (Beijing).

    The Montreal Protocol required that all production of new Halon cease by January 1, 1994. Recycled Halon and inventories produced before January 1, 1994, are now the only sources of supply.

    Click here to download pdf file of the Montreal Protocol.
    2
    EPA - Rule 40 CFR Part 82 Protection of Stratospheric Ozone

    On March 5, 1998, the U. S. Environmental Protection Agency issued a final rule covering the sale of Halon blends and the handling and disposal of Halon and Halon-containing equipment (63 FR 11084). The date on which this rule became effective is April 6, 1998. The major elements of the rule are summarized below:

    • A ban on the manufacture of any Halon blend. An exemption is provided for Halon blends manufactured solely for the purpose of aviation fire protection.
    • A prohibition on the intentional release or venting of Halons during testing, maintaining, servicing, repairing, or disposing of Halon-containing equipment or during the use of such equipment for technician training.
    • A prohibition on Halon releases that occur as a result of owner failure to maintain Halon-containing equipment to relevant industry standards.
    • A requirement that technician training relevant to Halon emissions be provided. Technicians should be trained using standard industry service practice guidelines, including NFPA, ISO and ASTM publications.
    • A requirement that Halon and Halon-containing equipment must be properly disposed of at the end of its useful life. Proper disposal is defined as sending such equipment for Halon recovery or recycling by a facility operating in accordance with NFPA 10 and NFPA 12A standards or destruction using one of several processes identified in the rule.
    3
    Ban on Halon Blends

    A Halon blend is any mixture or combination of substances that contains two or more Halons (i.e., Halon 1211, Halon 1301, or Halon 2402). As of the effective date, it is unlawful to newly manufacture any Halon blend. Existing stores of Halon blends are not affected by the ban. An exemption is provided for Halon blends manufactured solely for the purpose of aviation fire protection, provided that blends produced under this exemption are recycled to meet the relevant industry purity standards for each individual Halon.

    4
    Intentional Releases

    This rule also prohibits venting of Halons during testing, maintaining, servicing, repairing, or disposing of Halon-containing equipment, or during the use of such equipment for technician training. For health, safety, environmental, and other considerations, several limited exemptions have been provided for the following types of releases:

    • De minimis releases associated with good faith efforts to recycle or recover Halon. For example, release of residual Halon contained in fully discharged total flooding fire extinguishing systems is considered a de minimis release.
    • Release of Halons during testing of fire extinguishing systems or equipment is exempted only if the following four criteria are met: (a) systems or equipment employing suitable alternative agents are not available, (b) system or equipment testing requiring release of agent is essential to demonstrate system or equipment functionality, (c) failure of the system would pose great risk to human safety or the environment, and, (d) a simulate agent cannot be used for the testing purposes.
    • Research and development (R&D) for Halon alternatives, and analytical determination of Halon purity.
    • Releases associated with qualification and development testing during design and development of Halon-containing systems and equipment only when (a) such tests are essential to demonstrate functionality, and (b) a suitable simulate agent can not be used for the testing purposes.
    Halon releases that occur as a result of owner failure to maintain containing equipment to relevant industry standards are also prohibited.

    However, this prohibition does not apply to emergency releases of Halon for legitimate fire extinguishing, explosion inertion, or other emergency applications for which the systems or equipment were designed.

    5
    Technician Training

    This rule also requires that technician training relevant to Halon emissions be provided. Technicians hired on or before April 6, 1998 must be trained by September 1, 1998; technicians hired after April 5, 1998 shall be trained within 30 days of hiring, or by September 1, 1998, whichever is later. In the Preamble to the rule, EPA pointed to several industry publications containing standard service practice guidelines and other information relevant to the development of training programs. These include NFPA, ISO, and ASTM publications; facilities may find these documents, or the most recent and relevant versions of these documents, helpful during the development of training programs and materials. Facilities are not limited to the use of the above-mentioned documents as guidance, however.

    6
    Proper Disposal

    This rule establishes that containing equipment must be properly disposed of at the end of its useful life. Proper disposal means only sending such equipment for Halon recovery or recycling by a facility (e.g., a manufacturer, a fire equipment dealer, a recycler, or an in-house recovery or recycling operation) operating in accordance with NFPA 10 and NFPA 12A standards. Ancillary system devices such as electrical components that are not necessary to the safe and secure containment of the Halon are not subject to this provision. In addition, equipment containing only de minimis quantities of Halon is not subject to this requirement.

    Furthermore, the Halon itself must be properly disposed of. Proper disposal means only Halon recycling by a facility operating in accordance with NFPA 10 and NFPA 12A or destruction using one of several controlled processes identified in the regulation.

    For further clarification, additional documents, or other information, please call the Stratospheric Protection Hotline at (800) 296-1996 or write to:

    Lisa Chang
    Program Implementation Branch
    Stratospheric Protection Division
    Environmental Protection Agency
    Mail Code: 6205J
    401 M Street, NW
    Washington, D.C. 20460

    Information is also available from EPA's Stratospheric Protection Home Page at the following URL address: http://www.epa.gov/ozone/index.html

    In addition, a guidance document from the U.S. EPA on the technician training and proper disposal requirements of the March 1998 rule was published in 2001.