Flammability of fridge insulation foam produced with a hydrocarbon blowing agent Version 1.0 December 2012 Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 1 We are the Environment Agency. We protect and improve the environment and make it a better place for people and wildlife. We operate at the place where environmental change has its greatest impact on people’s lives. We reduce the risks to people and properties from flooding; make sure there is enough water for people and wildlife; protect and improve air, land and water quality and apply the environmental standards within which industry can operate. Acting to reduce climate change and helping people and wildlife adapt to its consequences are at the heart of all that we do. We cannot do this alone. We work closely with a wide range of partners including government, business, local authorities, other agencies, civil society groups and the communities we serve. 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Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 2 Contents 1 Summary ............................................................................................................. 4 2 Introduction .......................................................................................................... 4 3 Methodology ........................................................................................................ 5 3.1 Collection of samples .................................................................................... 5 3.2 Laboratory tests ............................................................................................ 7 4 Summary of Results ............................................................................................ 9 5 Conclusions ....................................................................................................... 10 6 5.1 Coding, classification and consignment of waste ........................................ 10 5.2 Safe handling, storage and treatment ......................................................... 11 5.3 Other wastes ............................................................................................... 12 Acknowledgments.............................................................................................. 12 Appendix 1 – Information recorded from sampled cooling appliancse ..................... 13 Appendix 2 – Results of burn rate tests for fridge foam samples ............................. 14 Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 3 1 Summary The aim of this study was to test the flammability of fridge1 insulation foam produced using a hydrocarbon blowing agent in order to assess potential implications for the prevention of accidents and incidents from the storage and treatment of waste fridges. This report would also be used to clarify and review appropriate classification and coding under the Duty of Care and Hazardous Waste Regulations2. The study found that all tested foam samples should be considered “highly flammable” under European Test Method A.10 Flammability (Solids)3 and concludes that all fridge insulation foam produced using a hydrocarbon blowing agent should be classified as hazardous waste, unless tested and demonstrated otherwise. The results of the study will be used to: - Identify options for minimising or preventing accidents and incidents - Ensure that fridges containing hydrocarbon blown foams are sent to appropriate permitted treatment facilities for storage and further treatment - Inform the classification/consignment of waste foam produced by fridge treatment activities; ensuring that a consistent approach is taken 2 Introduction Modern fridges often contain insulating foam that is blown with hydrocarbon (HC) blowing agents, usually cyclopentane but may also include n-pentane and i-pentane, collectively referred to in this report as “pentane”. These hydrocarbon blowing agents have replaced the use of chlorofluorocarbon (CFC) and Hydrochlorofluorocarbon (HCFC) blowing agents (ozone depleting substances (ODS)) and Hydrofluorocarbons (HFC) blowing agents (gases with high global warming potential (GWP)). HC blowing agents are not ODS and do not have a high GWP but pose greater fire risk due to their high flammability. Permitted fridge treatment facilities accept fridges (those containing CFC/HCFC/HFC/HC refrigerants and blowing agents) and process them to remove the oil and capture the refrigerant from the cooling circuit. Once this is done, in 1 The term “fridge” is used in this report to refer to cooling appliances that contain insulating foam; including fridges, fridge-freezers, freezers, chest-freezers and refrigerated displays. 2 See http://www.environment-agency.gov.uk/business/topics/waste/40047.aspx and http://www.environment-agency.gov.uk/business/topics/waste/32180.aspx for further information. 3 Test method specified in Annex V of Directive 67/548/EEC and Appendix C of Environment Agency Technical Guidance WM2 for the assessment of the flammability of a solid substance. Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 4 accordance with the WEEE Directive and associated Defra BATRRT guidance4, the degassed CFC, HCFC and HFC fridge carcasses must be treated in dedicated plant, which will ensure that the blowing agent is collected and sent for destruction (e.g. incineration). The WEEE Directive and Defra BATRRT guidance do not explicitly require the collection and destruction of hydrocarbon blowing agents; however appliances containing foam produced with these blowing agents must be treated in “intrinsically safe” plant. In addition to being processed in dedicated fridge plants, a number of operators currently co-process degassed hydrocarbon fridges in scrap metal shredders, whilst others process them in generic waste shredders. There has been uncertainty regarding the correct classification of degassed hydrocarbon fridges (containing foam with a hydrocarbon blowing agent) under Duty of Care/Hazardous Waste Regulations and they have often been classified and transferred as non-hazardous wastes (e.g. under European Waste Codes 16 02 14 (discarded equipment other than those mentioned in 16 02 09 to 16 02 13) or 20 01 36 (discarded electrical and electronic equipment other than those mentioned in 20 01 21, 20 01 23 and 20 01 35)). Pentane blowing agents that are used in the insulating foam of fridges have the R11 (highly flammable) risk phrase (note: term not to be confused with “R11” CFC refrigerant). The pentane is entrained within the foam and therefore the material should be assessed for flammability as a solid in accordance with Test Method A.10 Flammability (Solids). If the foam is assessed as being hazardous (i.e. under the R11 risk phrase) then it would be assigned the H3A (highly flammable) hazardous property and appliances that contain it as a component would be classified hazardous waste under European Waste Code 16 02 13* (discarded equipment containing hazardous components other than those mentioned in 16 02 09 to 16 02 12) or 20 01 35* (discarded electrical and electronic equipment other than those mentioned in 20 01 21 and 20 01 23 containing hazardous components). 3 Methodology 3.1 Collection of samples The fridge appliances used to obtain the samples of insulation foam were provided by European Metal Recycling Ltd at their Darlaston facility. A sample of fridge foam was taken from 20 fridge appliances that had been identified as containing a hydrocarbon (pentane) blowing agent. Each foam sample was cut from the side panel of the appliance using a reciprocating saw and cut to the following approximate dimensions: 200mm x 400mm (Figure 1). The height/depth of the 4 http://archive.defra.gov.uk/environment/waste/producer/electrical/documents/weee-batrrtguidance.pdf Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 5 sample depended upon the thickness of the foam panel, which was generally between 40-100mm. Once cut, each sample was numbered, recorded and doublebagged. For each sample, the following information was also obtained from the corresponding appliance, where available: Blowing agent type Manufacturer and model Fridge type and capacity/volume Refrigerant type and charge The information obtained from each appliance is summarised in Appendix 1. Figure 1 Cutting of foam panel and collection of fridge information The blowing agent type was recorded from markings stamped on the exterior of the appliance and the other information (fridge type, refrigerant charge etc) was taken from the appliance name plate (e.g. as shown in Figure 2). Figure 2 Blowing agent marking and appliance name plate Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 6 3.2 Laboratory tests The samples of fridge insulation foam were tested by the Environment Agency National Laboratory Service (NLS), Nottingham, following Test Method A.10 Flammability (Solids). The blowing agent contained in each of the samples was analysed and confirmed using gas chromatography mass-spectrometry (GC MS). Figure 3 Double-bagged samples of foam in laboratory Following the test method, test samples were cut as unbroken strips from the foam panels to the following dimensions: 250mm long, 20mm wide by 10mm high. The test samples were cut to the required shape using a hacksaw blade and an aluminium cutting guide (shown in Figure 4). Figure 4 Cutting of test sample from foam panel Test method A.10 requires all substances to be subjected to a preliminary screening test, prior to the burning rate test. All samples satisfied the requirements of the Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 7 preliminary screening test (in terms of substance ignition and propagation of combustion) and were therefore passed on to the burning rate test. For the burning rate tests, the samples of foam were placed on non-combustible plates inside a fume cupboard and lit at one end using a gas burner. The propagation of the flame along the length of the sample was recorded using a digital stopwatch. Test method A.10 states that a substance should be considered highly flammable when the burning rate over 100mm of any test sample is less than 45 seconds. The method requires the rate of burning over 100mm of the sample to be measured after the flame has burned an initial distance of 80mm. These two distances were marked out on the non-combustible plates positioned below the test samples so that the burning rate of the flame over the required 100mm could be timed using the stopwatch (as shown in Figure 5). 1) Ignition of test sample Markers 2) Flame propagation reaches 80mm marker, stopwatch started 80mm 3) Flame propagation reaches 180mm marker, stopwatch stopped 180mm Figure 5 Trial run of burning rate test The test method requires that the test is performed six times unless a positive result is observed earlier. All test samples provided a positive result, however the burn rate test was repeated on three test samples cut from each panel (i.e. 60 tests were carried out in total, with 3 test samples taken from each of the 20 foam panels). Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 8 4 Summary of Results The results of the burn rate tests and GC MS analysis carried out on the samples cut from the fridge insulation panels are tabulated in Appendix 2. Blowing agent type The GC MS analysis of the blowing agent(s) contained in the foam panels confirmed that each panel contained a hydrocarbon blowing agent, as had been marked on the exterior of the appliances (see Appendix 1). The results also confirmed that cyclopentane was the principal hydrocarbon blowing agent used in the foam panels. However, 9 foam panels also contained iso-pentane as a minor constituent (with cyclopentane identified as the main constituent), and 2 panels contained iso-pentane as the main constituent. Burning rates All foam samples burned the required distance (100mm) in a time under 20 seconds. The slowest burn rate recorded was 19.3 seconds (test sample 3, fridge 1) and the fastest recorded was 2.8 seconds (test sample 1, fridge 8). The average burning rate time across all 60 samples was 9.4 seconds. The fastest and slowest burning samples both contained cyclopentane blowing agent. The type of hydrocarbon blowing agent did not appear to have a significant effect on the burning rate of the foam samples, with the average burning rate between the 3 types (i.e. those containing a) cyclopentane, b) cyclopentane and isopentane (as minor constituent) and c) iso-pentane (as main constituent)) being 9.7, 9.3 and 9.2 seconds respectively. Therefore, variability in burning rate between samples was possibly due to variability in hydrocarbon blowing agent content (quantity), rather than type. Test method A.10 states that a substance should be considered as highly flammable when the time of burning in any tests carried out according to the test procedure is less than 45 seconds. As illustrated in Figure 6, the burning times recorded for all 60 test samples were significantly less than 45 seconds (all were below 20 seconds) and therefore all tested material were considered “highly flammable” in accordance with the test procedure. Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 9 60.0 50.0 Burn rate (seconds) 45 second threshold specified by test method A.10 40.0 30.0 20.0 10.0 0.0 Fridge number Figure 6 Average burn times of foam panel samples taken from each fridge 5 Conclusions As stated in section 4, based upon the test data obtained from this investigation, it was concluded that all fridge panels tested should be considered as highly flammable solid materials. As a result of this, we believe that all fridge insulation foam produced using a hydrocarbon blowing agent should be considered highly flammable, unless tested and demonstrated otherwise. This conclusion has the following potential implications: 5.1 Coding, classification and consignment of waste When assessing waste electrical equipment, such as fridges, it is the presence or absence of hazardous components that determines if they are classed as hazardous waste or not. Insulation foam that has been blown with a hydrocarbon blowing agent (pentane) has been demonstrated to posses the hazardous property H3A (highly flammable). This means it is a hazardous component and would, amongst other components, make a fridge a hazardous waste. On the basis of this, degassed fridges (appliances that have had the refrigerant/compressor removed) that contain insulation foam produced with a hydrocarbon blowing agent should be classified and consigned under one of the following hazardous waste codes: 16 02 13* or 20 01 35*. Similarly, foam panels Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 10 mechanically cut and removed from fridges that contain a hydrocarbon blowing agent should be classified and consigned under the 19 12 11* waste code. Waste residues resulting from waste shredding or fragmentising activities that coprocess degassed fridge carcasses that contain insulation foam produced with a hydrocarbon blowing agent should be classified as hazardous waste under code 19 02 04* (premixed wastes composed of at least one hazardous waste), unless it can be demonstrated that the hydrocarbon blowing agent has been removed from the foam by the shredding process5. The requirements of the revised Waste Framework Directive (2008/98/EC), specifically regarding the ban on the mixing of hazardous wastes (Article 18), will apply to the management of these hazardous wastes. 5.2 Safe handling, storage and treatment In Defra’s WEEE BATRRT guidance, it is stated that appliances containing hydrocarbons must be processed in intrinsically safe equipment. Many pentane blown fridges are currently processed in dedicated fridge plant where the foam is separated, milled and heated to release and collect the blowing agent. Typically, this is done under a nitrogen inerted atmosphere to meet the BATRRT criteria. However, not all dedicated treatment plant are currently inerted and it is unclear how these plants will operate with the changing proportions of ODS to pentane fridges (i.e. as the proportion of fridges that contain pentane increases). A small number of other operators currently co-process pentane blown fridges in light iron shredders, which could potentially pose a risk if the shredding process releases the pentane (although we understand that the air dilution provided might be adequate to keep gas concentration below the explosive limit) or if a spark ignites the foam material. We also understand that some operators are using general waste shredders to process pentane fridges, which may cause greater safety concerns. We are currently in discussions with the HSE to confirm the definition of “intrinsically safe equipment”. It must be ensured that at sites accepting or producing wastes consisting of or containing hydrocarbon-blown fridge foam appropriate measures are provided for their safe storage and handling to prevent fire initiation and escalation/propagation (i.e. appropriate measures for waste separation/segregation (e.g. fire breaks/walls) and the prevention of flammable atmospheres). 5 See Environment Agency guidance Classifying and coding wastes from physico-chemical treatment facilities HWR06 for further information on the principles of treating and classifying hazardous wastes, available from http://www.environment-agency.gov.uk/business/topics/waste/104765.aspx Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 11 5.3 Other wastes This investigation has focussed on the flammability of hydrocarbon-blown fridge insulation foams. However, the same potential issues/implications may apply to the classification/consignment, storage and treatment of other similar waste foam materials that contain a hydrocarbon blowing agent (e.g. building insulation foam, insulation foam contained in other types of appliances, furniture foam and packaging materials). Under the requirements of the Duty of Care and Hazardous Waste Regulations, it is the responsibility of the waste producer to ensure that all wastes are described and classified correctly, taking into account any relevant hazardous properties. 6 Acknowledgments We wish to acknowledge the help provided by: European Metal Recycling, Darlaston - for providing and assisting with the collection of the fridge foam samples. The National Laboratory Service, Nottingham - for assisting in the design and implementation of the testing methodology. For further information, please contact National Operations, Waste Technical Services. Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 12 Appendix 1 – Information recorded from sampled cooling appliancse Fridge 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Manufacturer/model Electrolux / ERN2821 BEKO / TLDA5215 Bosch / KSV24214B/02 LEC / EL550BW Unidentified Bosch / unidentified Hotpoint / RLA18G LEC / T350CW Electrolux / ER6641T Whirpool / RPT531-1/H Scandinova Indesit / RGV1142UK Unidentified Whirlpool / RE128 Proline PLF140W Hotpoint Kyoto KU96FF Hotpoint / FFA71P BEKO / T3DA524FW Hotpoint / FZA50P Description Fridge freezer Fridge (large) Fridge freezer Fridge Fridge Fridge freezer Fridge freezer Fridge freezer Fridge Fridge freezer Fridge Fridge Freezer Fridge Fridge Freezer Freezer Fridge freezer Freezer Freezer Type/capacity Type 2 / 283l Type 2 / 260l Type 2 / 222l Type 1 / 13l Type 1 Type 2 / 315l Type 2 / 353l Type 2 / 190l Type 1 / 159l Type 2 / 189l Type 2 Type 1 / 91l Type 1 Type 1 / 118l Type 1 / 110l Type 2 Type 2 / 260l Type 2 / 292l Type 2 / 197l Type 2 175l Blowing agent mark on appliance Pentane C-Pentane/ I-pentane n-Pentane Pentane Pentane Pentane Pentane Pentane Pentane C-Pentane Cyclopentane Cyclo / Iso pentane Cyclopentane Cyclopentane Cyclopentane Pentane Pentane Pentane C-pentane I-Pentane Pentane Refrigerant type & charge R600A 80g R600A 28g R600A 56g R600A 20g Unidentified * R600A * R600A 30g R134A 70g R134A 55g R600A 52g R134A * R134A 60g R600A * R600A 30g R600A 25g R600A * R600A 60g R600A 43g R600A 44g R600A 37g * Charge (quantity of refrigerant in cooling circuit) not stated on appliance Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 13 Appendix 2 – Results of burn rate tests for fridge foam samples Fridge 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Burn times (100mm in secs) Sample 1 Sample 2 Sample 3 7.5 12.8 19.3 10.7 9.8 9.7 12.6 16.0 13.6 7.1 11.7 8.9 15.7 7.9 8.0 6.2 11.7 5.8 8.2 12.4 15.1 2.8 5.5 6.7 10.9 4.8 10.7 4.3 4.4 4.1 10.1 5.0 9.1 9.8 8.2 5.4 5 13.5 10.4 9.8 15.9 12.8 5 8.4 3.9 4.4 10.2 8.4 11.3 16.1 15.8 10.3 12.1 9.8 9.2 9.3 7.6 8 9.2 7.7 Average Average burn time 13.2 10.1 14.1 9.2 10.5 7.9 11.9 5.0 8.8 4.3 8.1 7.8 9.6 12.8 5.8 7.7 14.4 10.7 8.7 8.3 9.4 Identified blowing agent(s) from GC analysis Cyclopentane Major constituent cyclopentane, minor iso-pentane Major constituent cyclopentane, minor iso-pentane Cyclopentane Major constituent iso-pentane, minor pentane Major constituent iso-pentane, minor pentane Major constituent cyclopentane, minor iso-pentane Cyclopentane Cyclopentane Major constituent cyclopentane, minor iso-pentane Cyclopentane Major constituent cyclopentane, minor iso-pentane Cyclopentane Cyclopentane Cyclopentane Major constituent cyclopentane, minor iso-pentane Cyclopentane Major constituent cyclopentane, minor iso-pentane Major constituent cyclopentane, minor iso-pentane Major constituent cyclopentane, minor iso-pentane Flammability of fridge insulation foam produced with a hydrocarbon blowing agent LIT 7627 14
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