SCOPE
This white paper applies to the recent environmental regulations set forth by the Environmental Protection Agency (EPA) that requires the phasing down of the production and consumption of hydrofluorocarbons (HFCs) and how this will affect clean agent fire suppression systems (FM-200 or HFC-227ea, ECARO-25 or HFC-125) that contain HFCs.
The goal of this bulletin is to ensure that the reader can ascertain all the important property loss control considerations on the use and replacement of clean agent fire suppression systems that utilize HFCs (FM-200, Ecaro-25), including acceptable alternatives.
INTRODUCTION
Clean agent fire suppression systems using FM-200 and Ecaro-25 are found in many occupancies and applications such as IT data — computer rooms, telecommunication facilities, control rooms, museums, pharmaceutical/medical facilities and historical archive storage rooms.
The American Innovation and Manufacturing (AIM) Act was enacted by U.S. Congress on December 27, 2020. The AIM Act directs the EPA to address hydrofluorocarbons by phasing down the production and consumption, maximizing reclamation and minimizing releases from equipment, and facilitating the transition to next- generation technologies and alternatives through sector-based (HVAC, fire protection) restrictions. The Kigali Amendment to the Montreal Protocol, sets the same targets/requirements of the AIM Act for every nation to phase down climate-polluting HFCs. Over 130 countries worldwide have already ratified the Kigali Amendment.
The AIM Act creates a system of HFC allocations/allowances and exchange values for manufacturers and retailers according to their global warming potential.
Under the authority/administration of the EPA, an 85% total reduction in the manufacturing and importing of HFC chemicals will be required by 2036 via a staggered, or step-down fashion, starting with an initial 10% reduction in 2022. HFCs used in fire protection clean agent suppression systems will be affected by the required phase down mostly resulting from much higher costs of virgin clean agents using HFCs for any new FM-200 or Ecaro-25 systems. HFCs used for clean agent fire suppression systems only account for 1% to 2% of the total amount of HFCs being regulated with the HVAC industry (refrigerants, coolants) accounting for the majority of the HFCs being regulated. Interestingly, the EPA did exclude
DISCUSSION/BACKGROUND
HFCs are potent greenhouse gases (GHGs) intentionally developed as replacements for ozone-depleting substances (ODS) in the refrigeration, air conditioning, aerosols, fire suppression and foam blowing sectors. They have global warming potentials (GWPs) — a measure of the relative climate impact of a GHG, that can be hundreds to thousands of times greater than carbon dioxide (CO2). FM-200 or HFC-227ea has a GWP potential that is 3,000 times greater than carbon dioxide (1 lb. of HFC-227ea is equivalent to 3,000 lbs. of carbon dioxide).
The AIM Act and EPA regulations began in 2022 with an initial 10% required baseline reduction, and the fire suppression industry has already been moving toward that goal, resulting in a cost increase of virgin HFC agents. FM-200 cost increases of around 500% (roughly $175/lb.) have begun in late 2021 and are expected to continue moving forward. ECARO-25 prices are also expected to rise nearly 50% in 2022. ECARO-25 is seeing a less dramatic increase because it is used for several applications other than fire suppression and slightly higher production rates will help to hold down costs. Hence, the costs to install a new FM-200 or Ecaro-25 system will dramatically increase starting in 2022. Viking Corporation has already made an environmentally conscious decision to stop selling FM-200 starting in 2022.
However, there is a secondary market supply available for reclaimed/recycled FM-200 and Ecaro-25. When clean agent fire suppression systems are taken out of service or decommissioned, fire protection companies purchase the clean agent cylinders and sell to other clean agent fire suppression system users. This secondary market supply has been and will continue to be used for system recharges to maintain the numerous FM-200 and Ecaro-25 systems that are already in place. The price for recycled/reclaimed FM-200/Ecaro-25 has remained stable and has not increased significantly ($35/lb.) and has historically remained steady. It also is estimated that a suitable supply of reclaimed/recycled FM-200 and ECARO-25 are available from various suppliers for system recharges so that existing systems can be maintained in service for 15 to 20 years or possibly even longer.
SOLUTION/GUIDANCE
Due to the AIM Act and the expected rising costs of virgin FM-200/Ecaro-25 clean agents, any occupancies or hazard applications needing new clean agent fire suppression systems should utilize alternatives to FM-200 and Ecaro-25. Acceptable possible alternate, environmentally friendly fire suppression agents and gases not subject to the AIM Act are 3M NOVEC 1230 (proprietary protection fluid from 3M), generic FK-5-1-12, and inert gas type suppression systems including IG-55 (ProInert) or IG-541 (Inergen).
It should be noted that the alternative clean agent fire suppression systems (3M Novec 1230) or inert gas suppression systems have their own specific design concentration and agent/gas supply amount requirements different from FM-200 systems. Careful consideration to all factors (available space for cylinders, specific hazard/occupancy, application — local application or total flooding, special insurance requirements, health/safety, etc.) should be taken into account for all new or replacement installations.
Acceptable, non-HFC-based clean agents for fire suppression systems will continue to
be developed by chemical companies and will eventually be included in current fire protection standards (NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems)².
CONCLUSION
There is no requirement or rush to replace any existing FM-200 and Ecaro-25 systems, and these systems can be maintained in place with no severe increase or high maintenance, or recharging costs expected. The availability of recycled/reclaimed FM-200 and Ecaro-25 at a reasonable price should allow systems to remain a viable protection scheme and can be maintained in place for approximately 20 more years.
New installations or expansions of current systems utilizing FM-200 or Ecaro-25 requiring virgin FM-200/Ecaro-25 clean agents will continue to be available on a limited basis, but the market price for these agents/systems will be high.
New and existing FM-200 and Ecaro-25 clean agent fire suppression systems should continue to be installed, maintained and inspected per NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems.
Sigma 7 Paragon Risk Engineering can provide risk analysis and loss prevention services for owners and operators of sites that utilize HF based clean agent fire suppression systems.
Sigma7 Paragon Risk Engineering is a worldwide risk engineering provider with over 200 engineers in 35 countries with extensive industry experience and technical expertise. We are fully independent of any insurance company or broking entity and are part of the Sigma7 group of companies, with colleagues working in other specialized areas such as forensic post loss accounting, Business Interruption pre-loss assessments, worldwide /security threat monitoring, online e-training for site personnel and financial/risk due diligence.
For more information about how Sigma 7 \ Paragon Risk Engineering Consultants can help address HFC based clean agent fire suppression systems contact us at: https://paragonconsults.com/contact/
REFERENCES
EPA United States Environmental Protection Agency — “Protecting our Climate by Reducing Use of HFCs” — www.epa.gov/climate-hfcs-reduction
NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, 2022 ed.
