HFC-based clean fire extinguishing agents: Implications of recent legislation
Since the publication of our article Update on Environmental Regulations and the HFC-based Clean Fire Extinguishing Agents in the September 2015 issue of International Fire Protection, new environmental regulations have been introduced. In this article, we discuss the implications in fire protection of the US EPA Final Rule 21, which does not impact the use of HFCs in fire protection, and the Kigali HFC Phase Down Amendment to the Montreal Protocol which allows the continued use of HFCs during the phase down and after the phase down is complete.
Environmental impact: The scientific facts
Since hydrofluorocarbons (HFCs; e.g., FM-200) do not contain chlorine or bromine, they do not contribute to the destruction of stratospheric ozone, and have ozone depletion potential (ODP) values of zero.
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 global warming potential (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 greenhouse gases (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 greenhouse gas 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  and the European Environment Agency , and indicates that the contribution to global warming of HFCs in fire protection is negligible. For example, in the USA the impact on global warming of HFCs in fire protection represents 0.02% of the impact of all greenhouse gases on global warming. For the EU-28 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 over a decade. As seen in Figure 1, the 2016 report from the HFC Emissions Estimating Program (HEEP) indicates the impact of HFCs in fire protection is not increasing significantly and has remained essentially steady for more than a decade, despite the growing installed base .
HFC end-uses and impact of emissions
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 from the use 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 21
On December 1, 2016 the U.S. EPA published its Final Rule 21, which changes the listing status of certain HFCs in certain end-use applications. Specifically, Final Rule 21 changes the approval status of certain HFCs in three end-use applications: refrigeration, foam expansion and aerosol propellant applications.
The effects of Final Rule 21 on HFCs in fire protection? None whatsoever. Under Rule 21 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 fire protection solutions. Final Rule 21 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 and the negligible impact of HFCs in fire protection on global warming
The kigali amendment to the Montreal protocol
The Kigali Amendment, adopted in October 2016, is an amendment to the Montreal Protocol. The Amendment adds HFCs to the list of substances controlled under the Protocol to be phased down. The amendment creates four different groups of countries, each with different baseline volumes and reduction schedules. Details of the agreed-upon HFC allocation schedule are provided in Tables 1 and 2.
The Kigali Amendment does not call for a complete phase-out of HFCs, but a phase-down: a reduction to 15% to 20% of the baseline by 2036 to 2047, depending on the country involved. This remaining production extends out indefinitely, a recognition of the importance of HFC use in many critical and/or non-emissive applications, such as fire protection. As seen from Table 1, for the majority of Middle East countries the phasedown does not commence until more than a decade from today – in 2028 – at which point consumption will be frozen to levels achieved in 2024 to 2026.
The allocation framework of the Kigali Amendment does not inhibit or limit the sale of HFCs into the fire suppression market in any region. 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 CO2 equivalents) placed on the market. 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.
Figure 3 provides a graphical representation of the Kigali Amendment allocation/phase-down scheme as it applies to Group 2 Article 5 Parties (Bahrain, India, Iran, Iraq, Kuwait, Oman, Pakistan, Qatar, Saudi Arabia and the UAE). Also shown for reference in Figure 3, is the estimated relative size on a GWP-basis of the worldwide HFC fire protection market .
The HFC phase-down, as stipulated by the Kigali Amendment leaves 15% to 20% of the HFC baseline available indefinitely, which is more than adequate to encompass the needs for fire protection in the Middle East or other markets. HFCs in refrigeration, foam blowing and aerosol propellant applications account for almost the entire global 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-134a based to HFO-1234yf based technologies. As of the close of 2016, over 24 million cars employed HFO-1234yf globally, and an estimated 50 million cars will employ HFO-1234yf globally by year end 2017. 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 additional allowances for HFCs used in fire protection. The 15-20% remaining GWP-allocations will be available throughout the course of the phasedown to support the requirements of key applications such as fire protection to protect the world’s infrastructures and crucial facilities for decades to come.
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. US EPA Final Rule 21 does not impact the use of HFCs in fire protection. The Kigali Amendment to the Montreal Protocol allows for the continued use of HFCs in fire protection so that HFCs can continue to provide society with this important alternative to protect human life and property indefinitely.
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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- US EPA Report 430-R-16-002 (2016).
- EEA Technical Report No. 15 (2016).
- Report of the HFC Emissions Estimating Program (HEEP), April 2016.
- Chemours estimate.