Attached below is a copy of the Environmental Protection Agency (EPA) Final Rule (89 Fed. Reg. 82682, Oct. 11, 2024) on the management and reclamation of HFCs under the AIM Act. The Rule goes into effect on December 10,2024.
Here is a summary of the Rule’s requirements applicable to use of HFC (Hydrofluorocarbons) agents in fire suppression systems. References below are in 40 CFR Part 84 of the Code of Federal Regulations.
FSSA is in the process of preparing the agenda for the division meetings at the 2025 Annual Forum. If you are a FSSA Installer or Manufacturer Member, please take a minute to submit topics that you'd like to have discussed during the March 3 meeting. (Member login is required.)
The purpose of the committee is to make recommendations to the Commissioner of the Department of Community Affairs. Recommendations may include rules and regulations pertaining to professional training, standards, identification, and record keeping procedures for certificate holders and their employees, classifications of certificates necessary to regulate the work of certificate holders and other matters necessary to effectuate the sections of the Uniform Fire Safety Act. Pursuant to N.J.S.A.52:27D-25o, the Director of the Division of Fire Safety shall serve ex officio, as well as eleven public members appointed by the Governor.
Please share this information with anyone you may know who is or will be enrolled in a fire protection program and/or any schools that have a fire protection program. To qualify for a scholarship, the applicant must complete the FSSA Scholarship Application online form and upload the necessary documents to FSSA Educational Foundation Headquarters by Saturday, June 1, 2024.
The online FSSA Training Program is an important part of our mission as the leading authority and advocate of special hazard fire protection. FSSA is proud to offer this program as a complimentary benefit to members due to the continued support of volunteer contributors.
This year, we are excited to work on improvements and course material updates to better serve our industry. One of our primary goals in improving the learning experience is to add video presentations (or think of them as mini prerecorded webinars) to each course. The FSSA Training & Development Committee is calling for volunteers to help with this project.
FSSA has filed petitions in Maine and Minnesota, seeking a Currently Unavoidable Use (CUU) exemption from the Maine PFAS law and the Minnesota PFAS law that seek to regulate products containing “intentionally added PFAS.” These laws define PFAS so broadly they would encompass certain clean agent fire suppressant agents, including HFC-227ea, FK-5-1-12 and HFC-125.
Part of the FSSA NFPA 855 Standard for the Installation of Stationary Energy Storage Systems Series
How do we try to make these as safe as possible? It starts for us with the codes and standards. You have the International Code Council, which is the ICC, that creates the International Fire Code, the International Building Code. We have the National Fire Protection Association, the NFPA. We also have to have standards testing. UL has UL 9540, which is the listing for Battery Energy Storage Systems (BESS). You look at all the codes and the codes will require UL 9540 listing for all batteries. And the test is the 9540 A test. So these have all been updated and worked on after McMicken, after Victoria in Australia, after Moss landing, after all of the fires. We're doing a much better job about getting everyone together in a room and creating better codes.
Part of the FSSA NFPA 855 Standard for the Installation of Stationary Energy Storage Systems Series
We always try to learn lessons. What worked well, what didn't work well. McMicken showed us that a clean agent type fire protection system alone is not adequate. We need something else. We need sprinklers. If we're going to be in an occupiable space, once again, we know that sprinklers don't control the thermal runaway, so all we're really doing is cooling it. Now, sprinkler water, as well as the water mist system, is really good about keeping vapors down, which is another thing that we're working on here in the valley with one of our battery installations. But sprinklers alone are not going to control the thermal runaway. It's going to do its thing until it's done.
The Fire Suppression Systems Association (FSSA) is the leading authority and advocate of special hazard fire protection. As the industry’s premier annual event for education and networking, the FSSA Annual Forum attracts a select group of top decision-makers in the industry. This year, we are expecting another record-breaking attendance, with more than 125 attendees registered.
A Joint Study by the Fire Suppression Systems Association and the Fire Industry Association (UK)
Issued November 1, 2023 - Released December 15, 2023
"The Fire Industry Association (FIA), a non-profit organisation, has pledged to dedicate a portion of its yearly revenue to support joint research initiatives that contribute to the well-being of its members, the industry, or public safety. Collaboration with other organisations is integral to the success of these projects. The partnership with the Fire Suppression Systems Association (FSSA) exemplifies the FIA's steadfast commitment to this initiative." - Robert Thilthorpe, Technical Manager, Fire Industry Association
“This research report is the culmination of almost six years’ collaboration between the UK’s Fire Industry Association (FIA) and the USA’s Fire Suppression Systems Association (FSSA). The research demonstrated that continuous recirculating airflow can enhance uniformity of gaseous agent concentrations in data center applications, even in spaces where aisle containments are present. The conclusions of the report should be quite useful to those responsible for designing and maintaining clean agent fire extinguishing systems for data centers” - Tom Wysocki, Technical Director, Fire Suppression Systems Association
FSSA is excited to host our 2024 Annual Forum at the historic Wigwam featuring elegant rooms and suites, three championship golf courses, three swimming pools, a tennis center, 440 acres of beautifully landscaped grounds, a world-class meeting center and more. There are so many things you'll love about The Wigwam, one of the top Arizona luxury resorts.
The Fire Suppression Systems Association (FSSA) is the leading authority and advocate of special hazard fire protection. As the industry’s premier annual event for education and networking, the FSSA Annual Forum attracts a select group of top decision-makers in the industry.
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.
FSSA Webinar: Going Fluorine Free – Converting a Legacy AFFF System to Fluorine-Free Foam
Thursday, October 5, 2023 12:00 pm Eastern
AFFF foam systems have been the standard for ignitable liquid firefighting for the past 40+ years. While an excellent extinguishing agent, the fluorinated compounds in AFFF have come under scrutiny in the past several years, with restrictions or outright bans on its use in many states. Fluorine-free foams have entered the market as replacements for AFFF, but no drop-in replacements exist. This case study looks at one of the first fluorine-free foam systems in New England to replace an existing legacy AFFF system. Differences in how fluorine-free foams work versus AFFF, which directly impacted the basis of design, along with the site-specific challenges that were overcome, will be discussed; along with the challenges that other fluorine-free replacement projects will face and tips to mitigate them.