If one is working through a distributor or an installing contractor that has a supply agreement or a contract with an original equipment manufacturer (OEM) for the equipment that is listed using Novec 1230 fluid, they are likely listed with FK-5-1-12 from alternative suppliers as well. Novec 1230 is a neat (single component) agent. It is typically discharged from a cylinder with a nitrogen super pressurization or one with a separate nitrogen tank design used in a piston flow fashion giving a “push” to it.
It is recommended that one first checks with the original equipment manufacturer and their representative installing contractor to make sure they are supplying it with a listed or approved system. And second, make sure that they have a certificate of analysis assuring the quality of the clean agent material.
There has not been a sufficient concern to compel regulatory authorities to put restrictions on the use of Halon from a persistent standpoint, and for other reasons. The PFCs, HFCs, and HCFCs, are all being regulated for other reasons, based on ozone depletion potential (ODP), global warming potential (GWP), and so forth. The European ECHA has a proposal in place but at this point in time, clean agents are considered for derogation in the proposal.
In December 2022, 3M announced its plans to exit the manufacturing of 3M™ Novec™ 1230 Fire Protection Fluid and their fluorochemical line of products completely by 2025, shocking the fire protection industry, as no one saw it coming. There is still a lot of excitement and maybe some angst or concern out in the marketplace. The best advice is to stay calm because regulatory resolution is not something that will unfold very quickly. There currently exist proposed changes offered or enacted state legislation that have taken place, particularly here in the United States. Even with current action, time is needed to determine what really needs to be done. There will be much discussion but watch for action.
Halocarbon clean agents are not going away anytime soon. Halon manufacturing was banned in Article One countries back on December 31st, 1992, at 11:59 PM EST, yet decades later we still see halon systems in use. This is not to say that things will be exactly the same for systems using Novec 1230 fluid, but these things do not tend to move very quickly. What is important is that halocarbons are not going away anytime soon, and 3M has made it clear that they plan to honor their commitments to fulfill orders of the product already made.
Trifluoroacetic acid (TFA) actually meets the definition of PFAS because it has a CF3 radical on the molecule. Researchable comments exist regarding the fate of trifluoroacetic acid, like from Columbia Climate School Center. The source of the currently observed levels is unknown and puzzling according to them. In 2001, the observed TFA concentrations were orders of magnitude larger than those predicted to result from the atmospheric degradation of the replacement of HCFCs and HFCs. The Columbia researchers noted that at the time FK-5-1-12 was not even commercialized.
Another collaborative study was conducted in 2002 and published in Environmental Science and Technology by the Environmental Laboratory in Seattle, Washington, the Department of Environmental Chemistry and Eco Toxicity in Germany, Scripps Institution of Oceanography, the University of California San Diego in La Jolla, and NOAA. The purpose of that study was to estimate TFA in ocean waters, given the material is strongly hydrophilic, and to assess whether today's levels are mainly from anthropogenic origin or whether biological or geological sources must be considered. Their conclusion at that time was that TFA is present in the global environment in two major compartments, in the ocean water and in the atmosphere, and in other areas, precipitation and fresh waters and so forth.
The European Chemicals Agency (ECHA) is currently accepting comments in the REACH restriction process regarding future use of per and polyfluoroalkyl substances (PFAS), including those used in fire protection like FK-5-1-12. This is a three-phase process according to ECHA. Phase 1 is preparation and submission of a restriction proposal, beginning with notification of intent to submit a restriction, then the registry of intentions, preparing the restriction dossier, and then submission and conformity check. Phase 2-A, a consultations phase, includes a consultation on the restriction report and a consultation on the Committee for Socio-Economic Analysis (SEAC) draft opinion. Phase 2-B is an opinion development phase that includes advice from the forum, RACs opinion and SEACs opinion. Finally, Phase 3 is the decision and follow-up phase including commission decision on the restriction, complying with the restriction, and enforcing the restriction. Regarding FK-5-1-12 as well as other halocarbon clean agents, ECHA is currently in the second phase which, again in itself has two phases; consultations and opinion development. So, once completed, with comments taken until 25 September 2023, there will be a decision and follow up on what the regulation is going to be in Europe.
The atmospheric degradation mechanism of FK-5-1-12 looks like this as a balanced equation C2F5(O)CF(CF3)2—-->4CO2+CF3COOH+9HF. Taniguchi concludes the photolysis of the ketone in the air results in a radical, uh, and also carbonyl fluoride will be incorporated in the air cloud and seawater where it'll undergo hydrolysis to, to give the trifluoroacetic acid. Similarly, the carbonyl fluoride will undergo hydrolysis to give CO2 and HF. The CO2, as well as any of these, the other two products that result from reacting with ketone at the concentrations expected in the environment is not considered harmful according to Taniguchi. The concentrations expected from what is going to be emitted into the atmosphere, combined with a short atmospheric lifetime, the global warming potential is negligible.
The acronym PFAS is short for per or polyfluoroalkyl substance. Depending on the source, there are up to 15,000 products or materials that meet the definition of PFAS. PFAS includes a broad category of materials that can be solids, liquids or gasses. Some fire protection materials, defined as PFAS, that are components in aqueous film forming foams (AFFF) are considered persistent, bioaccumulative, and toxic (PBT). Because of this, their use in fire protection and other applications is being phased out globally by the U.S. EPA and other regulatory agencies.
On June 29, the EPA announced its framework for addressing new and new uses of per- and poly-fluoroalkyl substances (PFAS). The framework outlines EPA’s planned approach when reviewing new PFAS and new uses of PFAS to ensure that, before these chemicals are allowed to enter into commerce, EPA will undertake an extensive evaluation to ensure they pose no harm to human health and the environment. Read the news release here.
The EPA has issued its Fire Suppressant Recycling Under the HFC Allocation Program Questions and Answers Fact Sheet dated May 2023. It provides guidance regarding when a company is considered an HFC Fire Suppressant Recycler, and its reporting obligations under the AIM Act. This guidance was first requested by FSSA in March 2022. A key provision in the fact sheet:
Who qualifies as an HFC fire suppressant recycler?
3M Company recently issued a release stating the company’s intention to exit per- and polyfluoroalkyl substance (PFAS) manufacturing and work to discontinue the use of PFAS across its product portfolio by the end of 2025. This was a business decision by 3M and will include the manufacturing of its 3M™ Novec™ 1230 Fire Protection Fluid - which is 3M’s trademarked-version of the FK-5-1-12 fire suppression agent.
In the release, 3M states that “PFAS can be safely made and used” and its “products are safe for their intended use.” The company commits to facilitating an orderly transition for customers. The announcement does pledge 3M will fulfill its current contractual obligations.
To: State and Local Building Officials, Fire Marshals, and other Local Authorities From: The Fire Suppression Systems Association
The Fire Suppression Systems Association (FSSA) is a membership organization composed of manufacturers, installers, and professionals engaged in the application of fire suppression systems and other fire extinguishing technologies. The FSSA is very concerned with the severity of fires and explosions occurring in battery energy storage systems (BESS) using new battery technologies. Our members have collectively witnessed severe disruptions due to fires originating in these systems.
