As part of FSSA's partnership with FPA Australia, the Global Outreach Committee is sharing this event with our members. Fire Australia 2024 will be held May 7-9 at the Gold Coast Convention and Exhibition Centre. If any FSSA members are attending, feel free to comment on this post so you can connect with each other. Visit the FPA Australia website for event details.

On July 20, 2023, the EPA published an update to (40 CFR Part 84) which implements the American Innovation and Manufacturing Act. The updated regulations, effective September 18, 2023, include new requirements to verify the quality of HFC fire suppressant agents by laboratory testing as well as additional recordkeeping requirements. These updated regulations affect FSSA members who fill or recharge HFC fire system cylinders. An overview of the EPA regulation was given at the FSSA Annual Forum and discussed at the division meetings. (88 Fed. Reg. 46836)

SUMMARY OF THE REGULATORY UPDATES

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.

Copies of the FSSA petitions are linked below.

NFPA 855 What To Do for Data Centers When They Want to Change Out the Lead Acid Batteries to Lithium Ion?

NFPA 855 Partnering with AHJs to Implement Local Codes

NFPA 855 Why is Partnering with Organizations like FSSA, NFPA & ICC Important?

The FSSA Global Outreach Committee is connecting with other like organizations with the goal of sharing information across the industry.  The Fire Protection Association of Australia published the following information bulletin, Selection and Use of Firefighting Foams.

The purpose of this Information Bulletin is to increase awareness of the issues surrounding the selection and use of firefighting foams based on their:

NFPA 855 How to Work with Your AHJ on an HMA

NFPA 855: Would Annunciator Panels Have Made a Difference at the McMicken Arizona Lithium-Ion Facility Fire?

NFPA 855: What is a Plume Study and Why is it Important to your Hazard Mitigation Analysis (HMA)?

The Hazard Mitigation Analysis (HMA) is step number one. This is the first thing that you as manufacturers, you as installers, you as property managers that are looking for properties, need to talk about; do we have an HMA for our batteries? I had someone come up to me recently and say, well, sometimes when we pick a site, we don't know the technology. Okay, you normally have a couple in mind or two, or three. Make an HMA with all three technologies and then we can just get rid of the ones that you don't end up using. But let's start this hazard mitigation analysis early. Because what it does is it looks at the consequences of failure. And if you look at the Phoenix Fire Code, we require this for every single battery installation. NFPA 855 and the base International Fire Code (IFC) has three different criteria.

NFPA 855: How are battery manufacturers working with UL to create safer batteries?

In the ICC, Chapter 12 is what deals with lithium ion and other batteries Currently, there's a committee called the Fire Code Action Committee that brings in industry, manufacturers, AHJ’s, like myself, and experts. We're working on different parts of Chapter 12 for energy issues. Be careful, just because a jurisdiction adopts Chapter 12, we might amend it. In the City of Phoenix, we amended Chapter 12, heavily. Ours is probably a little bit more restrictive than most of the country. I would say our sprinkler density, that we'll talk about here in a little bit, is more restrictive. We wanna require our AHJs to be more restrictive, so be careful. Always look at the code amendments from that local jurisdiction.

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.

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.

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

On October 19, 2023, the EPA issued a proposed rule titled Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes under Subsection (h) of the American Innovation and Manufacturing Act of 2020 (88 FR 72216). For additional information on the proposed rule and supporting documents, please visit https://www.epa.gov/climate-hfcs-reduction/management-certain-hydrofluorocarbons-and-substitutes-under-subsection-h. 

The rulemaking proposes the following requirements:

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.