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The impact of new legislation on fire suppression choices in hazardous environments

22 January 2015

Recent changes have been made to the F-gas Regulation in Europe, which aims to reduce the use of greenhouse gases, including hydrofluorocarbons (HFCs).  Bart Goeman, Fire Protection Fluid Business Development Manager at 3M, looks at some of the issues raised.

HFCs are potent greenhouse gases with long atmospheric lifetimes
HFCs are potent greenhouse gases with long atmospheric lifetimes

Fire suppression has long been of paramount importance in environments where managing risks is a high priority.  After all, a small fire in an already dangerous environment can have catastrophic consequences such as interruptions in operation, damage to high-value equipment, not to mention worker health and safety repercussions.  Now, there’s a new issue to consider: new environmental regulation.

On 12 March, 2014, the European Parliament voted to support a European Commission proposal to cut the use of hydrofluorocarbons (HFCs) to 79% below average 2009-2012 levels by 2030, as part of the on-going F-gas Regulation EC No. 842/2006.  This has since become law and the provisions of which are effective from January 2015.  This has direct impact on the use of HFCs in fire suppression systems, since they have some of the highest global warming potentials (GWPs) relative to other sectors. 

While fire suppression systems that use HFCs are widely used, there are also a number of alternatives that are well-established and installed in a variety of situations worldwide, including environmentally sustainable synthetic clean agents, water-based systems and inert gases.  Before we look at those different options, let’s take a closer look at the history of HFCs and the recent changes to the F-gas Regulation.

The future for HFCs

During the phase out of halon back in the early Nineties, many users began looking into other fire protection options that did not damage the ozone layer. HFCs proved to be a popular choice and have since become widespread.  However, even without the new legislation, there have been some concerns: while the ozone depletion potential of HFCs is zero, they are potent greenhouse gases. For instance, the global warming potential (GWP) of HFC-227ea is 3,220. This means it is 3,220 times more potent than CO2 in its climate impact.  HFCs used in fire suppression have a higher GWP than those HFCs used in other applications.

It has been reported in the US Proceedings of the National Academy for Sciences that if nothing changes, HFC emissions are likely to be equivalent to between 9-19% of global greenhouse gas emissions by 2050.  Of course, regions will differ, but it’s interesting to note the claim that without significant action, HFC emissions in the US are expected to double by 2020 and nearly triple by 2030, as reported on the Climate Action Plan website.

Focus on legislation

Following the European Parliament’s vote to support the European Commission’s proposal to cut use of HFCs by 2030, the European Council approved the law in April 2014.  HFC-227ea, HFC-125, and HFC-236fa are impacted in the overall scope of the Regulation under the HFC phase-down. HFC-23 will be prohibited from being placed on the market after 1 January 2015.

Some people may claim that the F-gas Regulation can be dismissed in the fire suppression market, on the basis that HFCs have low emissions in fire suppression (in other words, the claim that they are non-emissive unless a system discharge occurs).  In fact, the F-gas Regulation are about reducing emissions by controlling the use (and as a consequence, the production and importation of HFCs). Therefore, the effect on the fire suppression industry is very real.  Since HFCs sold into fire suppression have some of the highest GWPs relative to other sectors, this market is likely to be more severely impacted. 

Under the HFC cap and phase-down, HFC producers will be allocated a production/import quota for HFCs and will have difficult decisions to make.  Because the quota will be in CO2 equivalent (related to the GWP) and HFCs sold into the fire suppression market have some of the highest GWPs, this framework does not favour HFCs sold into fire suppression.  For example, an HFC producer would consume the same percentage of a quota by making either one ton of HFC-227ea, three tons of HFC-245fa, or five tons of HFC-32. 

Nor is it just new fire suppression systems that are affected by this legislation.  Given that fire suppression systems can easily be in situ for 20 or more years, any HFC-based system already installed or purchased over the next few years will be affected by the F-gas Regulation.  HFCs used for recharging existing systems, or in the installation of additional new HFC-based systems, will be increasingly impacted by the phase-down schedule.  Associated costs are anticipated to be disproportionately impacted.  Suddenly those purchasing HFC-based fire suppression systems will not only face immediate price consequences, they will also need to be aware of other future issues such as system recharge costs and potential end-of-life costs when a system is ultimately decommissioned.

It’s a worldwide issue

Inert gas fire suppression - Image: 3M
Inert gas fire suppression - Image: 3M

Europe is not the only region putting HFCs under the spotlight right now.  On 10 July 2014, the US Environmental Protection Agency (EPA) issued its proposal to change the status of hydrofluorocarbons (HFCs) in certain applications that is estimated to reduce harmful greenhouse gas emissions by as much as 42 million metric tons of carbon dioxide equivalent by 2020. According to the proposal, this is equal to the carbon dioxide emissions from more than five million homes’ annual electricity use.

The Spanish Council of Ministries has approved a tax on fluorinated greenhouse gases (Law 16/2013 from October 2013). As part of Spain’s efforts to improve public financing during the Euro crisis, the tax, effective 1 January 2014, is designed to raise revenue and further protect the environment through tax policy. The tax is levied on the consumption of fluorinated gases (F-gases) with global warming potential (GWP) above 150, including HFCs.

Elsewhere, the US has made agreements with both China and India to phase down the use of HFCs.  The Green Building Index (GBI) in Malaysia has initiated significant measures to heighten the awareness of the environmental impacts of the options available for clean agent fire suppression and, in particular, the climate impacts of HFC-227ea and HFC-125.

Looking at the alternatives

Changes in legislation - whether now or in the future - will put a substantial amount of uncertainty on the future supply and cost of HFCs sold into fire suppression. However, because this market already has cost-effective substitutes available, the transition away from HFCs may be more seamless than for other sectors.  Alternatives include synthetic or ‘clean’ agents that are not affected by the F-gas Regulation, as well as inert gasses and water-based systems. 

Water-based systems

Water-based systems naturally have no global warming potential and low toxicity.  While they work well in many environments, they are less suitable for spaces that contain sensitive or delicate equipment, because they can cause electrical short-circuiting or cause permanent damage to components.  Also, water-based systems cascade downwards (two-dimensional) so this may mean that not all equipment is covered.  There is also a need to dispose of contaminated water. 

Inert gases

Another option is inert gases.  Inert gases are generally mixtures of argon and nitrogen and work by removing oxygen from the protected area. In order to do so, large quantities of gas is required to displace the air (and reduce oxygen). Storage of this large quantity of agent has a significant cylinder footprint (and weight) even when stored at 300 bar. Inert gases are efficient but have a significantly longer discharge time (compared to synthetic agents) ranging to up to 2 minutes, then 30 seconds to put out the fire.  The reduction or elimination of oxygen means they are not ideal for use in occupied spaces as they could be hypoxic at the concentration level required to extinguish a fire. As inert gases need high pressure to operate, additional operational safety procedures are also required.

Non-HFC –based synthetic extinguishing agents or ‘clean’ agents

This is where some confusion can arise.  Synthetic extinguishing agents (or ‘clean’ agents) include HFCs, but they also include others, such as perfluoroketones (FK 5-1-12), which are not subject to the new EU legislation.  In fact, evidence shows that one of the most ‘future proof’ synthetic solutions of all, FK-5-1-12 is not affected by the F-gas Regulation (nor any other current- or future international regulation or directive). 

By definition, clean agents do not leave a residue behind when they discharge, so they do not damage sensitive electronics. They are also electrically non-conductive. This means that fires involving energised electrical equipment can be extinguished without powering down, avoiding expensive service interruptions and data loss.

Synthetic extinguishing agents work by removing heat (rather than oxygen) and act fast (discharge within 10 seconds and the fire extinguished within 30 seconds).  In general, these systems operate at pressures significantly lower than inert gases (25b, 34b, 42b or 50b) and use significantly fewer cylinders.  Plus, as they can be strapped to walls or pillars, they take up less space than inert gas systems and typically release less pressure into the atmosphere when activated.

Benefits for hazardous environments

Taking hazardous environments such as the oil and gas market, there are more aspects to consider beyond the type of extinguishing agent: human safety, space and weight of the selected system, speed of extinguishing, installation and logistic flexibility.  Some products (FK 5-1-12) can be transported safely by air in bulk quantities, without restrictions.  Depending on the brand, systems can be charged and refilled locally, without having to move cylinders offsite.  This can be an especially important consideration for servicing offshore facilities, saving time and ensuring uninterrupted protection of assets.

Any downsides? Synthetic extinguishing agents may appear more expensive on face value, but it is more important to look at overall total cost-of-ownership (maintenance, power consumption, cost of cylinder space, etc.) over the life-time of the system. Clean agent systems typically take up less space compared to water and inert gas based systems.

With a history in fire protection systems going back nearly a century, Kidde Fire Protection is well aware of the impact legislation changes will have on its customers and offers guidance in suitable products to fulfil their needs while remaining within EU legislation. John Simpson, General Manager at Kidde Fire Protection commented, “We’ve already seen a trend that shows a shift in attitudes from HFC based systems towards clean agent systems within EU countries in the past few years.  In essence, each type of fire suppression system has its own key benefits.

“Synthetic extinguishing agents reduce the footprint required and are deployed at a lower pressure than inert gas systems, whereas the latter can be used over much greater distances and lend themselves to multi-zone arrangements (higher pressure systems using synthetic agents can be designed to a multi-zone arrangement but the distance covered is shorter compared to inert gases). Ultimately this trend shows that organisations are making more informed choices about their fire suppression needs, and have already made moves to lessen their environmental impact.”

With cost-effective substitutes readily available, so the transition away from HFCs could be more seamless than many organisations may realise.  What is clear is that in addition to all the usual factors that need to be considered – effectiveness of fire suppression, cost of ownership, health and safety – environmental legislation has now come to the forefront as a priority when selecting the appropriate fire suppression agent.

More information about the F-gas Regulation (Regulation (EU) No 517/2014 of the European Parliament and of the Council of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006.):

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