Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Protection Sector)
August 2008
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Acknowledgements
The Environmental Protection Agency is grateful for the input of URS Ireland Ltd.
to the first draft of this Guidance Note (November 2005). The Agency would also
like to thank the Fire Engineering Systems Association (FESA). This revised
version is based on the November 2005 draft.
© Environmental Protection Agency 2008
Although every effort has been made to ensure the accuracy of the material contained in this
publication, complete accuracy cannot be guaranteed. Neither the Environmental Protection
Agency nor the author accepts any responsibility whatsoever for loss or damage occasioned,
or claimed to have been occasioned, in part or in full as a consequence of any person acting
or refraining from acting, as a result of a matter contained in this publication. All or part of
this publication may be reproduced without further permission, provided the source is
acknowledged.
Environmental Protection Agency
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Halon Phase-Out (Fire Fighting Systems)
CONTENTS
Section
Page No
WHAT YOU NEED TO KNOW................................................................................................. 1
1.
INTRODUCTION ........................................................................................................... 2
2.
USES OF HALONS ...................................................................................................... 3
3.
ENVIRONMENTAL IMPACT ...................................................................................... 4
4.
IMPACT OF REGULATIONS ..................................................................................... 5
4.1.
Implementation .............................................................................................................. 5
4.2.
Phase-out Dates ............................................................................................................ 5
4.3.
Import and Export .......................................................................................................... 6
4.4.
Supply and Use of Ozone Depleting Substances .................................................. 10
Critical Users ............................................................................................................................. 10
Non-Critical Users..................................................................................................................... 11
4.5.
Training and Minimum Qualifications ....................................................................... 12
5.
ODS WASTE MANAGEMENT ................................................................................. 12
6.
REPORTING REQUIREMENTS............................................................................... 14
7.
SUMMARY OF ALTERNATIVES ............................................................................. 15
8.
ENFORCEMENT AND PROSECUTIONS .............................................................. 15
9
SOURCES OF INFORMATION ................................................................................ 16
Appendix A - Alternatives to Halons
Appendix B - Safety in Halon Decommissioning
Appendix C - ODS Waste Management Guidance
Appendix D - Halon Critical Users – Annual Report to EPA
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WHAT YOU NEED TO KNOW
This Guidance Note is intended for those involved in the handling
(decommissioning) of halon in the fire protection sector and specified critical uses
of halon1 in Ireland. The following summarises the main impacts of the
Regulation (EC) No. 2037/2000 on substances that deplete the ozone layer in
relation to supply and use of halons, further implemented in Ireland by the
Control of Substances that Deplete the Ozone Layer Regulations 2006 (S.I. No.
281 of 2006).
Impact
Guidance Note
Section No.
Use and sale of halon fire-fighting equipment for non-critical
users is prohibited since 31st December 2002. This includes
use and sale of recovered and recycled halons.
4.2/4.5
All halon fire-fighting equipment should have been
decommissioned by December 31st 2003. Following
decommissioning, all halons must be recovered for
destruction.
4.2/4.5
Import and placing on the market of halons and products and
equipment containing halons is prohibited, except for critical
uses, for use as a feedstock or processing agents or for the
purpose of destruction.
4.3
Exports from the EU of halons or products and equipment
containing halons is prohibited, with the exception of halons
exported for critical uses until 31st December 2009. Specific
provisions apply.
4.3
Those involved in handling/decommissioning of halon are
required to obtain a minimum qualification standard
4.6
Critical use for aircraft protection is permitted.
4.5
Waste halon should be managed and disposed of in line with
Irish and European waste management legislation in order to
minimise any potential environmental impact.
3.0/5.0
Those continuing to use halon for critical use must maintain
accurate records of use
6.0
Alternatives are available for replacement of halon. Critical
users should actively investigate suitable available
alternatives
7.0
Further details are provided in the main body of the Guidance Note.
1
Critical uses of halon allowed under the Regulation refer mainly to use for fire protection in civil
aviation and military uses, as well as the oil, gas and petrochemical sector and in existing cargo
ships and use by fire brigades.
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1.
INTRODUCTION
The stratospheric ozone layer acts as a protective barrier or ‘natural sunscreen’
in the upper atmosphere, preventing harmful ultraviolet radiation from reaching
the earth’s surface. Research during the 1970’s and 1980’s identified a hole in
this ozone layer at certain times of the year above the Antarctic, with CFCs
(chlorofluorocarbons) being identified as the cause of the depletion of
stratospheric ozone. In addition to CFCs a range of other Ozone Depleting
Substances (ODS) were identified as contributing to the depletion of the ozone
layer. Through the United Nations Environment Programme (UNEP) a Global
Convention was developed to protect the ozone layer, eventually resulting in the
development of the Montreal Protocol in the late 1980’s. Regulation (EC) No.
2037/2000 on substances that deplete the ozone layer is the European response
under the Montreal Protocol. The Protocol is under constant review and
amendments are agreed under the auspices of the United Nations (UN). Ireland
has ratified all amendments.
Regulation (EC) No. 2037/20002 established rules for the production, import,
export, placing on the market, use, recovery, recycling, reclamation and
destruction of substances, referred to as controlled substances, that deplete the
ozone layer. This covers a range of substances including:
•
Chlorofluorocarbons (CFCs);
•
Hydrochlorofluorocarbons (HCFCs);
•
Halons,
•
Hydrobromofluorocarbons (HBFCs);
•
Methyl Bromide;
•
1,1,1-Trichloroethane;
•
Bromochloromethane
•
Carbon Tetrachloride.
These substances are mostly used in refrigeration, air-conditioning (including
heat pump equipment), fire suppression and pest control. Furthermore, some
ODS are used as solvents, aerosol sprays and blowing agents. The Regulation
prohibits CFCs, halons, 1,1,1 trichloroethane, carbon tetrachloride, HBFCs, BCM
and methyl bromide (with some exceptions). In addition, gradual phase-out and a
medium term ban on HCFCs is introduced.
While Regulation 2037/2000 is directly binding on all Member States, certain
provisions of the Regulation are further implemented in Ireland by the Control of
Substances that deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of
2
A copy of the Regulation and other relevant information can be downloaded from the Commission’s
website at: http://ec.europa.eu/environment/ozone/index.htm
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Halon Phase-Out (Fire Fighting Systems)
2006). These Regulations officially designate the Environmental Protection
Agency as competent authority, while the Department of Agriculture and Food,
the Revenue Commissioners (Customs) and the Department of Transport
(Maritime Safety Directorate) are each designated as competent bodies. A copy
of the Regulations is can be downloaded from www.ozone.ie.
A series of Guidance Notes has been produced to cover the range of controlled
substances and their uses. This Guidance Note focuses on the main uses in
Ireland in relation to halon use in the fire protection sector.
2.
USES OF HALONS
The term ‘Halon’ is a shortened form of halogenated hydrocarbon. Halons have
been extensively used as fire suppressants in fire extinguishers and halon
flooding systems. Small amounts of halons have also been used as components
of solvents and pesticides.
Table 1 provides an overview of the halons controlled under Regulation (EC) No.
2037/2000.
Table 1
Halons Controlled under EC No. 2037/2000
Halon
Chemical
Formula
Trade
name
Atmospheric
lifetime
(years)
Ozone
Depleting
Potential3
Halon-1211
CF2BrCl
BCF
16
3.0
Halon-1301
CF3Br
BTM
65
10.0
Halon-2402
C2F4Br2
20
6.0
Halon-1011
CH2BrCl
0.37
0.12
Key characteristics of halons include:
3
•
They are non-conductive, which makes them ideal for use with electrical and
electronic equipment;
•
They do not leave a residue, thereby minimising damage to equipment;
•
They act very quickly in suppressing a fire; and
•
They can be used in occupied spaces as their toxicity is low (halon 1211 is
reported to be more toxic than halon 1301 hence halon 1301 is normally
used in occupied spaces).
ODP scale is based on an ozone depleting potential for CFC-11 (chlorofluorocarbon) of 1.0.
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Halons are used in both fire suppression flooding systems and hand held
extinguishers. Halon fire suppression systems have been commonly used in:
•
Electronic and electrical cabinets, and computer rooms;
•
Aircraft engine nacelles and dry bays;
•
Turbine or engine compartments, etc.
Halon 1301 is typically used as a flooding agent in occupied spaces due to its low
toxicity to humans (at recommended concentrations). Halon 1211 can also be
used in flooding systems but is more commonly used in hand held extinguishers.
Contact with the fire protection sector indicated that Halon 1301 was the only
halon known to be used in flooding systems in Ireland, while Halon 1211 was
employed in portable fire extinguishers. Alternatives to halons are discussed in
Section 7.
3.
ENVIRONMENTAL IMPACT
Halons are referred to as ozone depleting substances (ODS), because once such
gases are released into the environment and reach the stratosphere, they
interact with ozone and destroy ozone molecules. Some ODS can have lifetimes
in the stratosphere of hundreds of years, though in the case of halons the
reported atmospheric lifetime is up to 65 years (see Table 1). A molecule of halon
gas has the potential to destroy ozone molecules during its entire lifetime.
Various ODS are assigned Ozone Depleting Potentials (ODP) depending on their
potential4 to cause ozone depletion in the stratosphere (see Table 1).
Ozone is a gas composed of three bonded oxygen atoms (O3). In the Earth’s
atmosphere, ozone is formed from molecular oxygen (O2) in the reactions
initiated by UV light. Ozone can be found in two levels, at ground level and in the
Earth’s upper atmosphere, referred to as the stratosphere. At ground level, ozone
is a significant air pollutant, forming smog. In the stratosphere it is referred to as
the ozone layer. The ozone layer encircles the stratosphere at approximately 10
km above ground level. It filters ultraviolet (UV) radiation reducing the amount of
radiation reaching ground level.
The depletion of the ozone layer exposes living organisms to high levels of the
harmful UV-B radiation. Most importantly, this negatively impacts human health
causing increased occurrence of skin cancers, cataracts and weakened immune
system. Other negative impacts of depletion of the ozone layer are:
4
•
High levels of UV-B radiation causes sunburn and can potentially damage
DNA,
•
Changes in plant growth,
ODP scale is based on an ozone depleting potential for CFC-11 (chlorofluorocarbon) of 1.0.
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Halon Phase-Out (Fire Fighting Systems)
•
Degradation of building materials, particularly paints, rubbers, woods and
plastics.
While many ozone depleting substances also have potential health and safety
impacts the objective of the Regulation and of this Guidance Note relates to the
potential for depletion of the ozone layer due to release of these compounds. The
most significant ozone layer depletion occurs over Antarctica, where the ozone
concentration is approximately 30% of its pre-1970s concentration. Ozone
concentration is still decreasing, but at a lower rate since implementation of the
Montreal Protocol in 1989. It is estimated that the ozone layer above Antarctica
will recover after 2050. Further information on ozone depletion and international
action is available from the United Nations Environment Programme website
(http://ozone.unep.org/index.asp).
4.
IMPACT OF REGULATIONS
4.1.
Implementation
Under the Control of Substances that Deplete the Ozone Layer Regulations 2006
(S.I. No. 281 of 2006), the Environmental Protection Agency is the designated
competent authority for implementation and enforcement of Regulation
2037/2000. Three competent bodies have also been assigned official
responsibility under the Regulations: Department of Agriculture and Food, the
Revenue Commissioners (Customs Division) and the Maritime Safety
Directorate.
Specific requirements, such as minimum qualifications, have also been
introduced in Ireland under the Control of Substances that Deplete the Ozone
Layer Regulations 2006 (S.I. No. 281 of 2006). This is discussed further in
Section 4.5.
4.2.
Phase-out Dates
Under the Montreal Protocol Halon 1301, Halon 1211 and Halon 2402 production
was required to have ceased by 31st December 1993.
Under the Regulation (EC) No. 2037/2000 all use5 and sale of halon fire-fighting
equipment for non-critical users is prohibited from 31st December 2002. This
includes recovered and recycled halons and is applicable to hand-held fire
extinguishers in vehicles and buildings. All halon fire-fighting equipment should
have been decommissioned by December 31st 2003. Following
decommissioning, all halons must be recovered for storage for critical uses or
destruction. Guidance on the decommissioning of obsolete halon systems and
halon waste management and is presented in Section 5 and Appendix B and C.
Table 2 lists the phase-out dates for halon-containing equipment.
5
Use is defined as “the utilisation of a substance in the production or maintenance, in particular
refilling, of products or equipment or in other processes except for feedstock and processing agent
uses”.
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Table 2
Halon equipment phase-out dates
Date
Action
31st December 1993
Halon 1301, Halon 1211 and Halon 2402
production ceased.
31st December 2002
Use and sale of Halon fire-fighting equipment for
non-critical users is prohibited.
31st December 2003
All Halon fire-fighting equipment for non-critical
users should have been decommissioned.
31st December 2009
Export of recovered, recycled and reclaimed
halon stored for critical uses prohibited6.
The only legitimate use of halon now remaining is the critical uses listed in Annex
VII of Regulation 2037/2000.
Contact with industry indicates that non-critical halon fire protection systems may
be still in use beyond the decommissioning deadline.
These must be
decommissioned immediately according to Article 4(4)(v) and Article 16 of the
Regulation. Failure to decommission such systems may result in prosecution. A
range of alternatives are available and are discussed in Section 7.
4.3.
Import and Export
Import and export in the context of Regulation (EC) No. 2037/2000 refers only to
trade with non-EU countries and does not refer to movement of ODS within the
European Community. The shipment of waste ODS within the EU is governed by
other national and EU legislation. Figure 1 illustrates the relationships in the ODS
import and export reporting requirements etc. The import and export of ODS is
subject to strict limitations as detailed in the Import and Export Declaration
documents which can be downloaded from the Commission ODS website at:
http://ec.europa.eu/environment/ozone/ods.htm.
The import and export of the majority of ODS is effectively prohibited, with limited
exceptions for authorised essential uses, use as a feedstock or processing agent,
and import for destruction (this is not applicable for Ireland as no destruction
facilities are available in Ireland). The import and export of equipment and
products containing ODS is also severely restricted. Imports are allowed for
authorised essential uses. Products and equipment shown to be manufactured
6
The European Commission may decide to prohibit such exports before this time on completion of
an export review in January 2005.
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Halon Phase-Out (Fire Fighting Systems)
prior to the entry into force of the Regulation (i.e. before 1 October 2000) are not
subject to import prohibitions.
The export prohibition does not apply to halons exported for critical uses if
obtained from recovered, recycled and reclaimed halons stored in facilities
authorised or operated by the Competent Authority until 31 December 2009.
However, the European Commission export authorisation procedures for ODS
must be followed.
Further limitations are applicable to trade with countries which are not party to the
Montreal Protocol, with trade only being allowed under very limited
circumstances.
The import and export of ODS into/out of the European Community require
authorisation from the Commission under Regulation (EC) No. 2037/2000.
Import Licenses and Export Authorisation Numbers can be obtained via the
Commission’s ODS website by following the correct procedures. It is the
responsibility of the importer/exporter to apply to the Commission via their
http://europa.eu.int/comm/environment/ozone/ods.htm.
All
website
correspondence with the Commission should be directed to:
Ozone Layer Protection
European Commission
Directorate - General Environment
Unit ENV.C.2 – Climate Change
B 1049 Brussels
Fax: + 32 22 99 8764
Email: [email protected]
Where an import request is approved, a copy of the import licence will be sent to
the Competent Authority of the Member State. Similarly, for authorised exports
from the EU, the exporter is issued with an Export Authorisation Number (EAN).
Exports cannot be carried out without an EAN issued by the Commission.
Applications for import and export authorisation must be renewed on an annual
basis. Importers and exports are required to report annually to the Commission
according to Article 19 of Regulations 2037/2000, with specified data on import
and export of methyl bromide. A copy of the report must be submitted to the
Environmental Protection Agency:
Ozone Depleting Substances
Office of Licensing and Guidance
Environmental Protection Agency
P.O. Box 300
Johnstown Castle Estate
Co. Wexford
Or via e-mail to [email protected]
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In addition, stamped used licence documents (import licences and export
authorisation numbers) must be provided to Customs (www.revenue.ie) at the
point of import or export. Further guidance on import and export procedures can
also be obtained from Customs.
It is recommended that any person wishing to carry on trade of ODS or ODS
containing equipment with countries outside the European Community should
carefully consult the Regulation 2037/2000 and S.I. No. 281 of 2006 and the
guidance provided on the Commission ODS website prior to making an
application to the Commission.
It should also be noted that the Regulation 2037/2000 prohibits the transportation
of all ODS in disposable containers, except for essential uses.
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Customs
Information
for Art
20(3) report
Used licence
documents
(import licenses
and export
authorisations)
Copies of import
licences and export
authorisations and
Art 19(1) and 19(3)
reports
Environmental
Protection Agency
Stamped used
licence documents
(import licenses
and export
authorisations)
Copies of import
licences and export
authorisations
Copy
European Commission
1. Declare intent to
import or export
2. Request import
licence or export
authorisation
Issue import
licences and
export
authorisations
Report under Article
19(1) and 19(3)
(copy to EPA)
Importers &
exporters
Figure 1 Guidance for importers and exporters
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Halon Phase-Out (Fire Fighting Systems)
4.4.
Supply and Use of Ozone Depleting Substances
Critical Users
Annex VII of Regulation 2037/2000 defines those critical halon uses which are
currently permitted. However, it should be noted that this list is currently being
revised by the Commission and it is likely that end-dates for critical use
exemptions will be introduced. Critical uses identified in Ireland are:
Halon 1301
•
In aircraft for the protection of crew compartments, engine nacelles, cargo
bays and dry bays, and fuel tank inerting.
Halon 1211
•
In hand-held fire extinguishers and fixed extinguisher equipment for engines
for use on board aircraft.
•
In aircraft for the protection of crew compartments, engine nacelles, cargo
bays and dry bays.
•
In fire extinguishers essential to personal safety used for initial extinguishing
by fire brigades.
•
In military and police fire extinguishers for use on persons.
The Department of Communications, Marine and Natural Resources issued a
Marine Notice (Marine Notice No. 38) in 2003 to all owners, masters, skippers,
surveyors, shipyards, boatyards and repairers of ships and fishing vessels7. This
indicated that the Department was not aware of any Irish vessels to which the
critical use exemptions allowed under the Regulation would apply and has
therefore urged all vessels to comply with the requirements of the Regulation by
decommissioning halon systems. Any halon systems or halon-containing fire
extinguishers remaining on ships or other vessels should therefore be
decommissioned immediately.
Any critical users who have not been contacted by the EPA in relation to the
Regulation should contact the EPA as soon as possible.
The Regulation requires that all precautionary measures practicable are taken to
prevent and minimise leakages of halons. This requires an effective maintenance
and inspection programme, perhaps in conjunction with leak detectors. Such
detectors identify increased halon concentrations in a given space. Personnel
involved in handling halon are required to meet minimum qualification
requirements. This is further discussed in Section 4.5.
Critical users must estimate their future needs and arrange for procurement and
storage of appropriate volumes of halons. The EPA, as competent authority for
7
Responsibility for this sector is now under the remit of the Department of Transport.
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implementation and enforcement, must report annually to the Commission, under
Article 4(4)(iv) of the Regulation, detailed information in relation to the quantity of
halon installed and stored for critical uses. Critical users in Ireland must report
this information to the EPA on an annual basis. This is further discussed in
Section 6.
There are currently no halon banks in Ireland. However critical users may be able
to source halons from surplus stocks in storage by other critical users in Ireland
or by direct contact with the fire sector that may be carrying out decommissioning
of halon systems of extinguishers.
The Halon clearing houses that were set up in the past outside Ireland for the
movement of halon stocks appear now to be inactive. These clearing houses
were as follows:
•
Halon Users National Consortium (HUNC – www.hunc.org);
•
United Nations Environment Programme Halon Trader web portal –
www.halontrader.org;
There are currently no commercial facilities in Ireland for the recycling or
reclamation of Halons. Recovery of halons from fire protection systems for use in
critical use systems should only be carried out by suitably qualified personnel to
minimise the potential for inadvertent halon release to the atmosphere. Refer to
Section 4.6 below on Training and Minimum Qualifications.
General guidance and best practice measures for decommissioning of halon
systems is presented in Appendix B. This is taken from the UNEP publication:
Eliminating Dependency on Halons – Self-Help Guide for Low Consuming
Countries.
Non-Critical Users
All non-critical halon flooding systems and extinguishers should be immediately
decommissioned by qualified personnel (see Section 4.6). Use of halon other
than for critical used outlined in Annex VII of the Regulation8 is an offence under
the Control of Substances that Deplete the Ozone Layer Regulations 2006 (S.I.
No. 281 of 2006) and may lead to prosecution.
Those requesting a fire systems contractor to decommission an installed flooding
system should ensure that the contractor has obtained the minimum qualification
as outlined below and that the decommissioned halon is either taken by a critical
user or is sent for destruction according to Article 16 of the Regulation and in
compliance with national and European waste legislation. Under no
circumstances should halon from decommissioned systems be released to
atmosphere
8
Use as feedstock or as a processing agent is also permitted but such uses are considered unlikely in
Ireland.
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4.5.
Training and Minimum Qualifications
The minimum qualification for persons whose business or employment involves
the installation, servicing, maintenance, dismantling or disposal of fire protection
systems and fire extinguishers, in which controlled substances are used is the
British Fire Protection Systems Association Competence Certificate Course Class
1, or equivalent9. This requirement is made mandatory by Article 9 of the Control
of Substances that Deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of
2006), addressing Article 16 of Regulation 2037/2000.
This course was developed by the British Fire Protection Systems Association10
to address Regulation 2037/2000 following its publication. The course took place
in Dublin in April 2007 and a small number of companies and personnel are now
appropriately qualified in Ireland.
In addition, there are two Irish Standards which are applicable to this sector and
should be taken into account by operators when hadling halons:
•
I.S. EN 27201-2:1994. Fire Protection – Fire Extinguishing Media –
Halogenated Hydrocarbons – Code of Practice for Safe Handling and
Transfer Procedures;
•
I.S. EN 27201-1: 1994: Fire Protection – Fire Extinguishing Media –
Halogenated Hydrocarbons – Part 1: Specifications for Halon 1211 and 1301.
General guidance and best practice measures for decommissioning of halon
systems is presented in Appendix B. This is taken from the UNEP publication:
Eliminating Dependency on Halons – Self-Help Guide for Low Consuming
Countries.
5.
ODS WASTE MANAGEMENT
Detailed guidance on management of waste ODS is provided in Appendix C,
while a general introduction is provided in this section.
Halons can only be destroyed by approved methods, for example liquid injection
incineration. There are currently no facilities in Ireland for the destruction of
halons. However, cylinders can be exported for destruction or recovery in
accordance with the existing EU and national legislation.
The fire protection company decommissioning the system is typically able to
arrange for disposal of halons via a waste management contractor.
Decommissioning and transport of cylinders should only be carried out by
qualified personnel. Valve protection caps should be employed while the
cylinders are in transit to minimise the potential for accidental release of the
9
Any decision on equivalent qualifications will be made by the Environmental Protection Agency.
Now known as the Fire Industry Association, following the merger of the British Fire Protection Systems
Association and the Fire Extinguisher Trades Association. Refer to http://www.fia.uk.com/ for further information.
10
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cylinder contents, as the high storage pressure means that accidental release
from a cylinder can result in the cylinder acting as a ‘projectile’.
Waste ODS, including waste halons (and also, potentially, used ODS containers)
are considered a hazardous material and are subject to the requirements of the
relevant EU and Irish waste management legislation including:
•
Waste Management Acts 1996 to 2008;
•
Waste Management (Hazardous Waste) Regulations 1998;
•
Waste Management (Movement of Hazardous Waste) Regulations, 1998;
•
Waste Management (Shipment of Waste) Regulations, 2007;
•
The Carriage of Dangerous Goods by Road Regulations, 2001;
•
Waste Management (Collection permit) Regulations, 2007;
•
Waste Management (Collection Permit) (Amendment) Regulations, 2008;
It is important to note that the legislative references detailed in the text are
subject to ongoing review both at EU and national level and may change in time.
For movement of hazardous waste within Ireland, the movement of the waste
must be recorded by means of a consignment note, known as a C1 form (which
are obtained from local authorities).
Export of hazardous waste is subject to Transfrontier Shipment (TFS)
requirements. Dublin City Council operates the National TFS Office, which can be
contacted as follows:
Dublin City Council
National TFS Office
Eblana House
68-71 Marrowbone Lane
Dublin 8
Administration Department
Technical Department
(01) 222 4411
(01) 222 4374
(01) 222 4601
(01) 222 4235
(01) 222 4634
(01) 222 4467
(01) 222 4249
Fax: (01) 411 3440
Email: [email protected]
Web: www.dublincity.ie
The collection and movement of waste, returned and recovered halons (and other
fire suppression agents that are either ozone depleting substances or fluorinated
greenhouse gases) is subject to requirements outlined in the Collection Permit
Regulations. Special provisions have been made to allow the collection and
movement of halons either by waste collection permit holder or by a person that
has submitted a Prior Annual Notification to the EPA. Refer to the EPA website
for further information on waste ODS collection: www.ozone.ie.
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Prior Annual Notifications must be made to the EPA, providing information
specified in the Fifth Schedule of the Regulations, and can only be made where
the following conditions are met:
•
the activity is incidental to the main business
•
the activity is small-scale, leading to environmentally beneficial
operations
•
the quantity transported does not exceed 2 tonnes
•
no mixing of different gases occurs
•
the material is brought to an authorised facility11
•
handling and transport should prevent venting or leakage
•
the material is
requirements
recycled or
destroyed according to relevant
The movement and disposal of hazardous waste is a relatively complex and
specialised area, and it is therefore recommended that the services of a licensed
hazardous waste contractor is employed to dispose of any consignments of
hazardous waste. A list of licensed contractors is available on the Irish EPA
website at www.epa.ie (A search facility for waste licences is available on the
home page).
Upon ultimate disposal of the waste a certificate of disposal will be issued to the
producer of the waste. A copy of all waste documentation (e.g. C1 forms, TFS
documents) should be kept by the producer of the waste and maintained (along
with other related waste documentation) for a minimum of 7 years.
6.
REPORTING REQUIREMENTS
Producers, Importers and Exporters
Producers, importers and exporters of ODS are required to report annually to the
Commission, according to the requirements set out in Article 19 of Regulation
2037/2000, copying any such report to the Environmental Protection Agency.
There are no known halon producers in Ireland and its use is now limited to a
relatively small number of critical use applications.
Critical Use
11
An authorised facility is a facility that has been granted an waste/site authorisation in the form of a waste
licence, a waste facility permit or a certificate of registration
Environmental Protection Agency
Page 14
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
The EPA, as competent authority, is also required to submit annual reports to the
Commission on critical use of halon in Ireland under Article 4(4)(iv) of the
Regulation. To this end, the EPA conducts an annual survey of the critical users
to gather this information and prepare the annual report. An example of the
reporting table required to be submitted to the EPA is included in Appendix D to
this Guidance Note.
Operators in the Fire Protection Sector
There are also specific reporting requirements for the EPA in relation to reporting
annually to the Commission on the quantity of controlled substances recovered,
recycled, reclaimed or destroyed. To this end, the EPA conducts an annual
survey of operators in the fire protection sector in Ireland to gather information on
halon decommissioned from fire protection systems and extinguishers in the
preceding calendar year, if any.
7.
SUMMARY OF ALTERNATIVES
Alternatives to halon fire extinguishers and flooding systems are available.
However, the choice of alternative depends on many factors such as the type of
hazard, the characteristics of the alternative method (e.g. ability to extinguish
solid and/or liquid fuel fires), and the risk assessment of use. The toxicity of the
alternative method should also be considered if there is potential for human
exposure.
Contact with the fire sector in Ireland indicated that FM200 (a trade name for
HFC227ea) is the most popular replacement for Halon 1301 in flooding systems.
Nitrogen flooding systems have also been installed in some cases. Controls on
the use of HFCs have recently been introduced by European legislation on
certain fluorinated greenhouse gases12.
The European Commission (2000) recommended that alternatives be selected
on the basis of lowest possible environmental impact consistent with personnel
safety, speed of suppression, volume, weight and cost for protecting life and the
environment from fire.
Information on alternatives is available on the Commission’s website:
http://ec.europa.eu/environment/ozone/alternatives.htm.
A
summary
of
alternatives for fixed systems and portable fire extinguishers is provided in
Appendix A to this Guidance Note.
8.
ENFORCEMENT AND PROSECUTIONS
The Environmental Protection Agency has been officially designated as
competent authority for the implementation and enforcement of Regulation (EC)
No. 2037/2000 by Article 6 of the Control of Substances that Deplete the Ozone
12
Regulation 842/2006 on certain fluorinated greenhouse gases.
Environmental Protection Agency
Page 15
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Layer Regulations 2006 (S.I. No. 281 of 2006). In addition, supporting roles have
been assigned to three competent bodies as follows:
•
Department of Agriculture and Food
•
The Revenue Commissioners
•
The Maritime Safety Directorate
With the support of relevant competent bodies, the EPA will continue, and expand
where necessary, its current contacts with the fire protection sector with the view
to ensuring compliance and gathering data to meet reporting requirements.
Any breaches of the Regulation will be regarded seriously by the Agency and the
competent bodies. Prosecution is provided for under Article 12 of the Control of
Substances that Deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of
2006).
9
SOURCES OF INFORMATION
Competent Authority - Environmental Protection Agency
Ozone Depleting Substances
Office of Licensing and Guidance
Environmental Protection Agency
PO Box 3000
Johnstown Castle Estate
Co. Wexford
Phone: 053 9160600
Website: www.ozone.ie
Government Body - Department of the Environment, Heritage and Local
Government
Air/Climate Section
Department of the Environment, Heritage and Local Government
Customs House
Dublin 1
Phone: 01 8882000
Website: www.environ.ie/en/Environment/Atmosphere/ProtectionoftheOzoneLayer/
Environmental Protection Agency
Page 16
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Competent Bodies –
Department of Agriculture and Food
Pesticide Control Service
Department of Agriculture and Food
Laboratories
Backweston Campus
Young's Cross
Celbridge
County Kildare
Phone: 01 6157552
www.pcs.agriculture.gov.ie/
Forest Service
Department of Agriculture and Food
Agriculture House
Kildare Street
Dublin 2
Phone: 1 6072000
www.agriculture.gov.ie/index.jsp?fil
e=forestry/pages/index.xml
Revenue Commissioners (Customs Division)
Office of the Revenue Commissioners
International and Trade Security Branch
Customs Division
Nenagh
Co. Tipperary
Phone: 067 63400
Website: www.revenue.ie
Maritime Safety Directorate
Maritime Safety Directorate
Department of Transport
Leeson Lane
Dublin 2
Phone: 01 6786400
Website: www.transport.ie/marine/MaritimeSafetyDirectorate/index.asp?lang=ENG&loc=1933
Other Useful Contacts
Fire Engineering Systems Association
Fire Engineering Systems Association Ltd.
8 Willbrook Road
Dublin 14
Website: www.fesa.ie
National Standards Authority of Ireland
Glasnevin
Dublin 9
Phone: 01 8073800
Website: www.nsai.ie
Environmental Protection Agency
Page 17
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Useful Websites
•
www.uneptie.org/ozonaction/
•
http://ozone.unep.org/
•
http://ec.europa.eu/environment/ozone/index.htm
•
www.euro.who.int/globalchange/topics/20020627_1
Environmental Protection Agency
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Appendix A -
Environmental Protection Agency
Alternatives to Halons
Page 19
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Table A1: Summary of the Existing Alternatives for Fixed Halon Systems
The information in the table below is taken from the following publication which was published in 2001.
Information provided should therefore be taken only as a guide and a thorough investigation of
alternatives should be undertaken prior to choosing an alternative.
•
United Nations Environment Programme, 2001. Standards and Codes of Practice to Eliminate
Dependency on Halons.
ALTERNATIVE
ADVANTAGES
DISADVANTAGES
Halocarbons. Alternatives include
HCFCs, HFCs and PFCs. FM200,
a common replacement for Halons
in Ireland is a trade name for HFC
227ea.
Electrically non-conductive;
All (except CF3I) are less efficient fire
extinguishers than Halon 1301 in terms of storage
volume and weight, hence the use of these
agents requires increased storage capacity;
Clean agents (no residue);
Can be stored and discharged from
fire protection systems that are
similar to that used for Halon 1301.
All (except CF3I) produce more decomposition
products (primarily HF) than Halon 1301;
Are more expensive than Halon 1301;
Use of HCFCs as a Halon replacement in fire
protection systems is limited under the
requirements of Regulation (EC) No. 2037/2000
(such as the HCFC supplier must cover 70 % of
the destruction costs) under Article 5(3). The
commission therefore expects that use of HCFCs
as alternatives to Halons in the EC will be
negligible (European Commission, 2000);
HFCs and PFCs are greenhouse gases and are
regulated under the Kyoto Protocol and will also
be regulated under the proposed ‘Regulation of
the European Parliament and of the Council on
Certain
Fluorinated
Greenhouse
Gases,
COM(2003)492 Final’.
Inert Gases. Common inert gases
used in fire protection systems
include:
Nitrogen;
Argon;
Nitrogen/argon
blend;
and
Nitrogen/argon/CO2 blend.
Electrically non-conductive;
‘Clean’ fire suppressants (i.e. no
residue);
Are
not
subject
to
thermal
decomposition and hence form no
by-products;
Have no global warming or ozone
depletion properties.
Fine Water Mist. This technology
involves the release of water in
small
droplets
(10
–
200
nanometres).
Types of system
include:
Single fluid systems (i.e. water
only) at low – moderate pressure (3
Environmental Protection Agency
Water
application
rates
are
approximately 100 times less than
conventional sprinkler systems. The
mists do not conduct electricity as
readily as solid water streams and
hence can be considered for use on
electrical equipment;
Are stored as high pressure gases. This results
in increased storage volume requirements, health
and safety requirements and increased weight;
Discharge time for these systems is of the order
of 1 – 2 minutes.
This may limit some
applications involving very rapidly developing
fires;
Some concerns in relation to reduced oxygen
concentration when these gases are released in
occupied spaces.
Do not always guarantee extinguishment of fires.
Small obstructed fires may require response team
intervention;
The droplet size must be sufficiently small to
ensure adequate distribution and of water
throughout the compartment;
These systems are still relatively new and have
20
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
ALTERNATIVE
ADVANTAGES
DISADVANTAGES
– 50 bar);
Reasonably weight efficient;
not been as rigorously tested or developed as
other traditional systems.
Single fluid systems
pressure (> 50 bar);
at
high
Reported to be safe for use in
occupied areas;
Dual fluid systems (which use
nitrogen or another gas to atomise
water at the nozzle).
No ozone depletion
warming properties.
Inert Gas Generators.
This
system utilises a solid material
which oxidises rapidly to produce
large quantities of CO2 and/or
nitrogen.
Have been used in military
applications (particularly aircraft)
Fine
Particle
Aerosol
Generators. This technology is
still under development. It relies on
the properties of solids particles to
suppress fires, however the
‘collateral’ damage due to use of
these
generators
would
be
considerably lower than traditional
dry powder technologies.
Considered to be a relatively low
cost/low technology technique
Development is still ongoing and at present these
generators are not considered a viable
replacement for Halon systems.
Detection
and
Manual
Intervention. This involves the
use of highly sensitive smoke
detection and aspiration systems,
which allow early detection of the
fire and manual intervention (hand
held extinguishers or hose reels)
before the fire is out of control, or to
minimise fire spread while waiting
for the fire services.
Early detection and
reduces fire damage;
Potentially increase health and safety risk to staff;
or
global
Their use in non-military applications is limited at
presented as further development is required.
Have no ozone depletion or global
warming properties
intervention
Hand held extinguishers can be
employed which have no ozone
depleting
or
global
warming
potential;
Cheaper than installation of complex
suppression
systems,
lower
maintenance.
If the fire goes out of control, there is no option
but to wait for the fire services to intervene,
unless a manual backup flooding system is
available;
Use of some portable extinguishers can result in
significant collateral damage (e.g. use of water on
electrical equipment);
This methodology is suitable only for a certain
types of hazard and should be examined carefully
in terms of the types of fires that are likely to
occur in a given application.
Can be a significant change where previous
methods
have
involved
automatic
fire
suppression systems.
Water Sprinklers.
Traditional
water sprinkler systems
are
commonly employed in Ireland in a
number of different types of
applications.
These systems
simply release a deluge of water to
extinguish the fire.
Systems are very reliable and are
highly
unlikely
to
discharge
accidentally.
They can also be
designed to activate only after two
separate detection systems have
been activated, thus further reducing
the potential for accidental releases;
Systems have been proved effective
in extinguishing fires, but the
potential types of fires should be
examined carefully as not all fire
types are effectively extinguished
(see disadvantages).
Environmental Protection Agency
Not ideally suited for use on live electrical
equipment, flammable liquid fires, or in any area
where materials may react violently with water;
Systems are likely to result in significant water
damage to equipment, however this must be
weighed against the potential damage which
would result from an unhindered fire;
Fires which occur in enclosed spaces such as
computer or electrical cabinets may not be
effectively extinguished unless a nozzle is
installed in the enclosed area.
21
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
ALTERNATIVE
ADVANTAGES
DISADVANTAGES
Carbon Dioxide.
This method
involves flooding the area with CO2
gas to extinguish the fire and has
been successfully employed for a
number of years in varied
applications. Suitable applications
include:
CO2 is a ‘clean’ fire suppressant;
CO2 is toxic and an asphyxiant, and so should not
be used in occupied spaces, or should be locked
off when protected spaces are occupied. CO2 is
also odourless and so malfunctions may not be
detected.
CO2 gas
conductive;
is
electrically
non-
CO2 gas has good penetration into
obstructed areas.
Telecommunications facilities;
Computer and control rooms;
Transformer rooms, switchgear
rooms and machinery spaces;
Record storage
heritage facilities;
and
CO2 is stored at high pressure.
High
concentrations are required to ensure effective
fire suppression. This has storage volume and
weight implications for the design of suppression
systems;
CO2 is controlled under the Kyoto Protocol as it is
known to cause global warming.
cultural
Flammable liquid hazards;
Foam Systems. These systems
operate by forming a barrier
between the fire and the supply of
oxygen as well as having a cooling
effect.
Different types of foam
include low, medium and high
expansion foams.
Dry powder systems. Operate by
releasing powder onto the fire to
prevent
oxidation
thus
extinguishing the fire.
Different
types of dry powder systems are
available including:
Formulations based on sodium
bicarbonate are suitable for fires
involving flammable liquids and
gases;
Low/medium expansion foams are
most suited to liquid pool fires, while
high expansion foam is more suitable
as a flooding agent for areas such as
document storage facilities;
Risk of suffocation if discharge occurs in occupied
areas;
Not suitable in applications where materials may
act violently with water as the foam solution
contains water;
May be capable of being delivered
through traditional water sprinkler
equipment, thus increasing the
extinguishing efficiency;
Care must be taken in selection of the foam
agent, as certain liquids (such as alcohols) can
destroy some foam blankets;
No ozone depleting
warming potential.
May not be effective in extinguishing fires in
enclosed spaces such as cabinets unless a
dedicated nozzle is installed in these areas.
or
global
Electrically
non-conductive
and
hence can be used safely in areas
containing electrical equipment;
No ozone depleting
warming potential.
or
global
Residues are left after application of dry powders;
As mentioned above, some dry powders may not
be suitable for all fires. The types of powder
being used should be examined closely;
Powders are ineffective once the powder has
settled;
Some powders exhibit toxic effects. This should
be investigated prior to release in occupied areas.
The release of powders will also obscure visibility.
Multipurpose dry powder systems
are based on formulations of
ammonium dihydrogenphosphate
and are also suitable for use on
fires
involving
ordinary
combustibles such as wood or
paper in addition to flammable
liquids and gases.
Environmental Protection Agency
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Table A2: Replacement Agents in Portable Extinguishers
The information in the table below is taken from the following publication which was published in 1999.
Information provided should therefore be taken only as a guide and a thorough investigation of
alternatives should be undertaken prior to choosing an alternative.
•
United Nations Environment Programme, 1999. Eliminating Dependency on Halons: Self Help
Guide for Low Volume Consuming Countries
Type
Ordinary
Combustibles
Flammable
liquids
Electrically
non-conductive
Ability to permeate
concealed spaces
Stream
Range
Effective
Weight
Secondary
Damage
CO2
Poor
Fair
Yes
Good
Fair
Poor
Good
Dry Powder
Good
Good
Yes
Fair
Very Good
Good
Poor
AFFF
Good
Fair
No
Poor
Good
Poor
Poor
Water Stream
Good
Ineffective
No
Poor
Good
Poor
Poor
Water Fog
Good
Fair
Yes
Fair
Fair
Fair
Fair
Halocarbons
Good
Good
Yes
Good
Good
Good
Good
Halon 1211
Good
Good
Yes
Good
Good
Good
Good
Environmental Protection Agency
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Appendix B -
Environmental Protection Agency
Safety in Halon Decommissioning
24
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
The guidance presented below is taken from the UNEP publication: Eliminating
Dependency on Halons – Self-Help Guide for Low Consuming Countries, which
was published in 1999. Information provided should therefore be taken only as a
guide and only appropriately trained technicians should attempt to decommission
halon system.
B.1 Introduction
Decommissioning is the process of removing a halon system from service. This
must be done in order to recover the halon so it can be made available for other
uses. As a logical and natural outcome of the decision to phase-out production in
Non-Article 5(l) countries, the rate at which halon systems are being
decommissioned is increasing around the world. This is because recycled halon
is now the only source for the remaining Essential Uses in Non-Article 5(l)
countries, and in most Article 5(l) countries as well. Because safety is such an
important aspect of decommissioning, it is becoming a more significant issue for
the fire protection industry as more systems are being removed so their halon
can be used elsewhere.
Halons are pressurised gases. Therefore, the cylinders containing them are
under pressure and must be handled with great care. If the pressure is released
in an uncontrolled way, the cylinder will become a projectile and can cause
serious injury or death to people working on the cylinder, or to bystanders. It is of
utmost importance that proper safety procedures be followed at all times when
handling halon cylinders. There are basically two ways halon bottles can become
dangerous. One is by damaging the valve and the other is to activate the
discharge mechanism. It can be easy to accidentally activate these bottles, and
cause serious injury or death. In Canada last year, a service technician was
killed while preparing to remove halon from a cylinder. His death occurred
because proper safety procedures were not being followed. In the US, the Fire
Suppression Systems Association (FSSA) has received a number of reports of
incidents involving cylinders that accidentally discharged in an uncontrolled way
when they were being removed from service or during handling. In all cases, the
cause was improper handling of the cylinders by untrained and unqualified
people.
Today, the remaining needs for halons in all Non Article 5(l) countries, and most
Article 5(l) countries is being met with recycled halon. This halon becomes
available to the market when an owner of a halon system removes the system
from service and makes the halon available to another buyer. Before the phaseout when halon was widely available, halon systems were decommissioned at a
much slower pace than is occurring today. With the process taking place so
much more frequently, the temptation to hire untrained and inexperienced people
is increasing. This situation can occur when the market demand for service
professionals exceeds the capacity of the local industry, or because of a need to
acquire halon quickly.
Halon systems components have been manufactured for over 20 years, in many
places around the world, and by many different companies. As a result, many
Environmental Protection Agency
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
different types and models of valves and activation mechanisms are installed on
halon cylinders. Because of this, it can be difficult to know exactly how a
particular valve mechanism works, or the proper procedures for safe
decommissioning. This can even be true for professionals who may not have
encountered a particular design before. Ideally, the people who decommission a
system should be those who installed and serviced it, however this is not always
possible. In any case, the procedures outlined in the Operations and
Maintenance Manuals, Owners Manuals, Service Manuals, etc., that are
provided by the manufacturer for the specific type of equipment installed must be
followed.
Some of the key steps that would be considered as mandatory in any procedures
manual are detailed below:
B.2 Secure Cylinders
Before any steps are taken to disconnect any piping from a halon cylinder, it
must first be firmly secured to an immovable object. If this is not done, and the
valve becomes damaged, the cylinder could become a projectile. Cylinders
connected to installed systems are usually adequately secured to a system
manifold.
B.3 Disable Actuation Devices
Once the cylinder is firmly secured, the first step in decommissioning is to
disable the actuation devices so the cylinder cannot accidentally fire. The
actuation device triggers the valve to open. The valves holding the pressure in
the cylinder are designed such that when activated, they go from a fully closed to
fully open position instantly, and the cylinder will be fully emptied in
approximately 10 seconds. When this happens, the cylinder depressurises
rapidly. If the cylinder is not safely secured in place when this occurs, it will
become a projectile. This is why the first thing the technician must do when
decommissioning (after securing to an immovable object) is to disable the
actuation mechanism.
Actuation mechanisms can be either electrical, pneumatic or mechanical.
However, simply disconnecting the device from its electrical or pneumatic source
is not enough to deactivate the device. In the case of pneumatic systems, there
is usually a small pin exposed that must be covered with a safety cap. Failure to
do this could result in accidental discharge. On electrically activated valves,
disconnecting the electrical leads to the solenoid valves is acceptable. However,
if the electrical connection is to an explosive initiator, it is very important to
remove the initiator. This is a very important safety practice, because static
electricity can cause the explosive to detonate, firing the valve. These actions
must be taken before any further dismantling is done.
B.4 Install Anti-Recoil Devices
At this point, it is now safe to carefully disconnect any discharge piping from the
discharge port. Immediately upon disconnection of the piping, an anti-recoil
Environmental Protection Agency
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
device must be installed. The anti-recoil device prevents the cylinder from
becoming a projectile in the event the cylinder activates or if the valve becomes
damaged. Most fire suppression system cylinders are furnished with valve outlet
anti-recoil devices, and in some cases cylinder protection/safety caps. DO NOT
disconnect cylinders from the piping system, or move or ship the cylinders if the
anti-recoil devices or safety caps are missing.
Obtain these parts from the Distributor or the Manufacturer. These devices are
provided for safety reasons, and must be installed at all times, except when the
cylinders are connected to the piping system, or being filled. All control heads,
pressure operating heads, initiators, discharge heads, or other type of actuation
devices must be removed; and anti-recoil devices or safety caps must be
installed before disconnecting the cylinders from the system piping. Fire
suppression system equipment varies according to manufacturer, therefore it is
important to follow the instructions and procedures provided in the
manufacturer’s manuals. Decommissioning should only be undertaken by
qualified fire suppression system service company personnel.
A safety cap is a device to prevent recoil. It is simply a cap which is secured over
the discharge port to disperse a sudden release of halon and prevent the
cylinder from becoming a projectile. It is important that the caps designed and
manufactured for the specific model of valve be used. This is because the
threads are not standardised, and if the wrong size is used they may not hold the
pressure of the halon release.
If the proper manufacturers caps cannot be obtained, pipe caps, plugs or plate
can be substituted, but must be installed correctly. If pipe caps, plugs or plates
are used, at least four opposing holes must be drilled in the cap, plug or plate so
that in the event of a discharge, the pressure is dispersed in a way that balances
the forces exerted on the cylinder. Anti-recoil device safety caps, plugs or plates
must always be properly installed before handling the cylinders.
B.5 Packing Cylinders for Shipment
Complying with the above safety practices is paramount before removing any
cylinders from the mounting position. Once the safety devices are in place,
cylinders can be moved with relative safety. However, it is always important to
remember that these are high pressure compressed gas cylinders, and must be
handled according to all the safety procedures applicable to any other high
pressure gas cylinder. At this point, with the actuating mechanism removed or
disabled and the anti-recoil device correctly installed, the cylinder may be moved
to the location where the halon will be removed. Sometimes the halon is
removed on site, but usually the cylinders are secured onto pallets or packed in
crates and shipped to a central point.
B.6 Receiving Shipped Cylinders
At the receiving point for the cylinders, there are a number of safety procedures
that must be followed. When opening the shipping container, a “halon sniffer”
should be used to determine if there has been an accidental discharge or
Environmental Protection Agency
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
leakage during transit. If there is a reading, people should move away and allow
any heavy concentrations of halon to dissipate.
Technicians should then look carefully at each cylinder to determine which one
of the following devices is present:
•
Burst disk/initiator
•
Mechanical/cutter valve
•
Shraeder valves/pilot check valves
If there is no initiator present and the safety cap is in place, the cylinder may be
safely unloaded and stored.
If the burst disk/initiator valve is present, look for initiators and safety caps and
proceed as follows:
If the initiator and safety cap are both in place, the cylinder may be carefully
unloaded, but the initiator must be disabled immediately by a qualified
technician. It is important not to discharge any static electricity to the initiator or
the initiator wiring during unloading. This could cause the valve to discharge.
If the initiator is in place and there is no safety cap in place, first connect an
electrical ground strap to the cylinder, the vehicle the containers were shipped in,
and the person unloading the cylinder. Then install an anti-recoil device (safety
plug, plug or plate) over the outlet, taking care not to release any static electricity
to the initiator or its wiring. After the anti-recoil device is installed, the initiator
must be immediately disabled by a qualified technician.
If the valve is of the mechanical/cutter type, look for the safety caps/plugs and
proceed as follows:
If the cutter mechanism is removed and the safety cap is in place, or if the cutter
mechanism is in place with a safety cap or plug in place, the cylinder may be
safely unloaded and stored.
If the cutter mechanism is in place and no safety plug is installed, DO NOT
INSTALL A SAFETY PLUG. Make sure the cylinder is secured to a pallet, and is
handled in a safe manner. Cutter valves are activated by a sharp edge which
cuts into the disk sealing the cylinder opening. Be careful that the cylinder and
pallet are not hit hard against anything since this could cause the cutting edge of
the mechanism to cut into the disk and discharge the cylinder. Hold the cylinders
in a safe location until a qualified technician can take action.
If the valve type has a Shraeder core, look for safety caps and proceed as
follows:
•
If the safety caps are installed and the release valve or mechanism is
secured, the cylinder may be safely unloaded and stored.
Environmental Protection Agency
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Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
•
If the safety cap is not in place and the release mechanism is not
secured, install the appropriate safety caps and secure the release
mechanism before unloading the cylinder.
The procedures for actually removing the halon differ depending on the type of
valve the cylinder has connected. There are many different types, manufactured
by many different companies around the world.
B.7 Measures to Improve the Safety of Decommissioning
The Halons Technical Options Committee recommends fire protection industry
associations, regulatory agencies of government with cognisant authority, and
system manufacturers work together to make sure only qualified people work on
halon systems, and that all necessary literature for the safe decommissioning be
made widely available throughout the industry, anticipating a greater than usual
demand for this information.
Owners of halon systems wishing to make the halon available to other buyers
should first turn to the company that installed the system originally, or the
company which provided service to the system to have the system
decommissioned. If these companies are no longer available, a company with
experience with the specific system should be contacted. HTOC suggests that
the following options might form some appropriate guidelines:
B.7.1 For Consideration by Governments:
Governments which regulate their domestic fire protection industries should be
aware that decommissioning will be taking place much more frequently than they
have in the past. Governments can use the same methods they now use to
communicate regulatory requirements to industry to increase awareness about
the importance of safety during decommissioning, and to distribute technical
information. It would also be prudent at this time to review the adequacy of
existing rules and Regulations governing the qualifications of people who
perform this work and the procedures to be followed, and make adjustments as
necessary.
B.7.2 For Consideration by Halon System Owners:
It is in the interest of the halon system owners that the removal of the system
proceed without incident. Once the decision to sell halon has been taken, the
owner should first determine whether a halon bank is operating in their country.
This information can usually be obtained from the ozone protection, or Montreal
Protocol unit of the national government’s environment ministry, department, or
agency. The halon banking organisation may also be able to locate a buyer,
arrange for testing of the material to protect both buyer and seller, negotiate a
price, and identify companies competent to remove and recycle the halon.
B.7.3 For Consideration by Repository Operators, Halon Recyclers, and
Halon Service Professionals:
Environmental Protection Agency
29
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Be aware of the increasing pace of halon decommissioning. Develop awareness
and training materials for use by the industry. The guide to different valves and
some of the safety information in this report would serve as a good start to
awareness material targeted to the service professionals. In a number of
countries in which halon banks operate, a surcharge has been placed on the
halon transactions brokered. Such a scheme could finance the development,
publishing and distribution of such safety material for the industry.
B.7.4 For Consideration by All Interested Groups:
The US DOD through their ODS Reserve Program Office has assembled a halon
system valve types and safety issues manual. The ODS Reserve Office has
kindly agreed to make this manual available on a case by case basis to parties
engaged in the decommissioning of halon systems. In addition, they have
volunteered to expand this document as additional technical information is
submitted by other companies, individuals, or fire protection organisations. The
Halon Technical Options Committee would appreciate it if fire protection
professionals reading this report would submit technical information on cylinders,
valve assemblies and actuators not included in this manual so they may be
added to future updates. Please send information and requests for to the
following address:
DOD ODS Reserve (DSCR-RP)
Defense Supply Center Richmond
8000 Jefferson Davis Highway
Richmond, VA 23297-5100
www.denix.osd.mil
Environmental Protection Agency
30
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Appendix C -
Environmental Protection Agency
ODS Waste Management
Guidance
31
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
1.
WASTE CLASSIFICATION
13
Most waste ODS and used ODS containers are classified as hazardous substances. Waste
is classified across the EU according to the European Waste Catalogue and Hazardous
14
Waste List . Most of the ODS are covered under the following chapters of the catalogue:
ODS substances (gases, solvents, etc.)
Chapter 07
Wastes from organic chemical processes (this section includes codes
for solvents used in a wide range of organic chemical industries)
Chapter 08
Wastes from the manufacture, formulation, supply and use (MFSU)
of coatings (paints, varnishes and vitreous enamels), sealants and
printing inks
Chapter 14
Waste organic solvents, refrigerants and propellants (except 07 and
08)
For equipment containing ODS
Chapter 16
Wastes from electrical and electronic equipment (including CFC,
HCFC and HFC)
Chapter 20
Municipal wastes (household waste and similar commercial,
industrial and institutional wastes) including separately collected
fractions
The European Waste Catalogue and Hazardous waste list can be downloaded from the
following web site: http://www.epa.ie/whatwedo/resource/nwr/
2.0
COLLECTION AND TRANSPORT OF WASTE
2.1
Waste Collection Permits
In general, waste may only be collected and transported by holders of waste collection
permits. Waste collection permits are granted by local authorities. However, special
provisions have been made in the revised Waste Collection Permit Regulations to allow the
collection of waste, returned or recovered refrigerant gases to be carried on by persons that
have made a Prior Annual Notification to the EPA. Further information is available on
www.ozone.ie.
13
Containers that were used to transport ODS that are now empty or are nominally empty and are to be
disposed of.
14
EPA,
European
Waste
Catalogue
and
Hazardous
waste
List
http://www.epa.ie/OurEnvironment/Waste/WasteClassificationandCharacterisation/
Environmental Protection Agency
(2002)
See
32
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
The special provisions referred to above can only be made by persons meeting the following
conditions:
2.2
•
the activity is incidental to the main business
•
the activity is small-scale, leading to environmentally beneficial operations
•
the quantity transported does not exceed 2 tonnes
•
no mixing of different gases occurs
•
the material is brought to an authorised facility
•
handling and transport should prevent venting or leakage
•
the material is recycled or destroyed according to relevant requirements
15
Transport of Hazardous Waste within Ireland (C1 form)
The movement of hazardous waste point to point within Ireland must be accompanied by a
C1 form in accordance with the Waste Management (Movement of Hazardous Waste)
16
Regulations, 1998 . However, a number of exemptions apply, under Article 35 of the
17
Collection Permit Regulations .
In practical terms, the C1 form must be completed at each stage of a journey. The form has
five carbon copies. By the time the shipment is ended, one copy will be with the originator of
the waste, one copy will be with the authorised destination facility, one copy will be with the
local authority that issued the blank C1, one copy will be with the destination local authority
and one copy will be retained by the carrier.
C1 forms may be obtained from the local authority in whose area the waste is collected. For
more information on C1 forms, contact your local authority.
2.3
Export of Waste outside of Republic of Ireland
Any movement of waste from a point within Ireland to a point outside of Ireland is governed by
18
the EU Transfrontier Shipment of Waste Regulation (1013/2006) . For the export of
hazardous waste, a transfrontier shipment (TFS) notification must be made, and
15
An authorised facility is a facility that has been granted an waste/site authorisation in the form of a
waste licence, a waste facility permit or a certificate of registration
16
S.I. No 147 of 1998 Waste Management (Movement of Hazardous Waste) Regulations, 1998
17
S.I. No. 820 of 2007 Waste Management (Collection Permit) Regulations, 2007, amended by S.I. No.
87 of 2008
18
Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on
shipments of waste
Environmental Protection Agency
33
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
authorisation to proceed obtained, prior to the export of waste taking place. No export of
waste should take place without the appropriate authorisations having been received from the
19
competent authorities in Ireland, the destination country and transit countries .
Dublin City council is designated as the National Competent Authority for export, import and
transit of waste shipments under the Waste Management (Shipment of Waste) Regulations
20
2007 . Further information can be obtained from the National TFS Office in Dublin City
Council: www.dublincity.ie.
A TFS notification is consists of two parts:
1) Notification form, which must be completed before waste is moved. This form
provides all the information necessary to obtain the advance consent of the
competent authorities.
2) Movement Tracking Form, which accompanies the shipment when it is moved. It
provides information on the actual movement of each waste load.
When the waste is received at its destination, the “consignee” issues a certificate of receipt
confirming that the waste has reached its authorised destination. Upon disposal of the waste,
the consignee issues a certificate of disposal confirming that the waste has actually been
destroyed.
3.0
STORAGE, TREATMENT, RECYCLING, DISPOSAL (AUTHORISED FACILITIES)
Waste may only be stored, treated, recycled or disposed of at authorised facilities. Depending
on the type and scale of activity, authorisation may be in the form of an EPA waste licence or
a local authority waste facility permit.
A waste licence is typically required for any facility where hazardous waste is stored, treated,
recycled or disposed of. This will include any transfer station for ODS in the form of packaged
chemical waste, for example, bottles of waste CFC or drums of waste solvent being shipped
abroad for disposal by incineration or other means. A list of all licensed facilities in Ireland
may be found at: http://www.epa.ie/terminalfour/wasteApril/index.jsp
Waste may only be stored, treated, recycled or disposed of at authorised facilities. Depending
on the type and scale of activity, authorisation may be in the form of an EPA waste licence or
a local authority waste facility permit.
19
For example, an export of waste from Ireland to Germany is likely to pass through the Netherlands. In
this case the competent authority of destination will be located in Germany and the competent
authority of transit will be located in the Netherlands.
20
S.I. No. 419 of 2007 Waste Management (Shipment of Waste) Regulations, 2007.
Environmental Protection Agency
34
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
A waste facility permit is typically required for non-hazardous waste recycling facilities. This
typically includes any facility that handles fridges and freezers and general electrical and
electronic equipment. Waste Facility Permits are issued by local authorities.
For specified waste activities, certain facilities can operate under a Certificated of Registration
issued by a local authority or the EPA.
Further information on licensing, permitting and certificates of registration can be obtained
from the EPA website: http://www.epa.ie/whatwedo/licensing/waste/
Before you use any facility for the storage, treatment, recycling or disposal of waste for which
you are responsible, ask for a copy of the facility’s authorisation. If you have any doubts about
the facility, check with the appropriate regulator (EPA or local authority) and do not use the
facility unless you have seen and are wholly satisfied with the authorisation in place.
3.1
Practicalities of Collection, Transport, Storage, Treatment, Recycling and
Disposal
In practical terms, the generator/owner of waste ODS may decide to dispose of the waste in
either of two ways:
1)
Recover and transport the waste to an authorised waste facility for storage and
treatment,
or
2)
Employ the services of a waste contractor to collect the waste on the owner’s
behalf and transport it to an authorised waste facility.
There are a large number of waste contractors authorised to handle the collection and
transport of hazardous waste. These companies will typically provide a full service and deal
with all authorisation processes for the transport, storage and export of waste.
As above, do not use any waste contractor that cannot provide evidence of waste collection
permits (in respect of any collection and transport of waste) and waste facility permits or
licences (in respect of any facility in Ireland to which the waste will be delivered). If exporting
waste, ensure that the contractor complies with all transfrontier shipment of waste legislation.
If you intend using a waste broker or dealer to handle your waste, you must ensure that the
broker is registered with the National TFS Office. A waste broker arranges to handle,
transport, dispose of or recover controlled waste on behalf of others. Waste brokers include
21
waste dealers who acquire waste and sell it on .
There are also “Duty of a holder of waste” requirements under Section 32 (1) of the Waste
Management Act 1996, that one must be aware of regarding the holding, collection and
movement of waste;
21
S.I. No. 113 of 2008 Waste Management (Registration of Brokers and Dealers) Regulations, 2008
Environmental Protection Agency
35
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
32 (1) “A person shall not hold, transport, recover or dispose of waste in a manner that
22
causes or is likely to cause environmental pollution”.
With regards to the storage of waste, The Waste Management Act 1996 defines 'temporary
storage' as the storage of waste for a period not exceeding 6 months. The storage of waste
greater than 6 months would be deemed a waste disposal or waste recovery activity and
would require authorisation from the relevant local authority or the EPA.
Note that the use of unauthorised waste contractors may leave you liable for prosecution if
your waste was found to have been handled illegally.
22
Section 32 (1) of the Waste Management Act 1996
Environmental Protection Agency
36
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Appendix D -
Environmental Protection Agency
Halon Critical Users – Annual
Report to EPA
37
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Each column is labelled A to J and your attention is drawn to the corresponding explanatory notes provided on the next page
Halon
type
A
Critical use
exemption
Brief description of the
critical Use
B
Environmental Protection Agency
C
Total kg
installed in the
equipment on
31 December
2006
D
Total kg used in
the period 1 Jan
2006 to 31 Dec
2006
E
Total kg emitted
from this use from
1 Jan 2006 to 31
Dec 2006
F
38
Total kg
of stored
halon
Has an alternative
replaced this use
since the last
reporting? Please
indicate alternative
(and when
replaced)
Briefly
describe any
measures
taken to
minimise
emissions
G
H
I
Other
comments
J
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
Explanatory notes
Column A: Please indicate whether the halon is of type 1301 or 1211.
Column B: Please indicate the applicable critical us exemption from those critical use
exemptions listed in Annex VII of Regulation (EC) 2037/2000 on substances that deplete the
ozone layer.
Column C: Please provide a brief description of the critical use as it applies to your
operations i.e. expand on the critical use exemption wording to describe/justify how it applies
to you.
Column D: Please provide the total quantity (in kg) of halon installed in the equipment at a
point in time i.e. 31 December 2006.
Column E: Article 2 of Regulation (EC) 2037/2000 defines “use” as the utilisation of
controlled substances in the production or maintenance, in particular refilling, of products or
equipment or in other processes except for feedstock and processing agent uses. If any of the
halon system were used during the reporting period (i.e. calendar year 1 January – 31
December 2006), please provide the total quantity of halon used (in kg) in that period.
Column F: If there were any emissions from halon systems during the reporting period (i.e.
calendar year 1 January – 31 December 2006), please provide the total quantity of halon
emitted (in kg) in that period.
Column G: Please provide the total quantity (in kg) of stored halon at a point in time i.e. 31
December 2006. Please include all halon stored (e.g. mobile cylinders, bulk storage tanks
etc.) This information is not mandatory under Regulation (EC) 2037/2000 but is considered
useful.
Column H: If any alternatives have been used to replace halon in particular systems, please
provide the information here (e.g. name of alternative, when it was introduced etc). This
information is not mandatory under Regulation (EC) 2037/2000 but is considered useful.
Column I: Please provide a brief description here of any measures taken to minimise
emissions/leakages.
Column J: If you have any further comments to make/information to provide which you think
might be useful, please use this column.
Page 39 of 43
Revised Guidance Note for Ozone Depleting Substances
Halon Phase-Out (Fire Fighting Systems)
USER COMMENT FORM
Completed forms to be sent to:
Ozone Depleting Substances
Office of Licensing and Guidance
Environmental Protection Agency
PO Box 3000
Johnstown Castle Estate
County Wexford
Ireland
Fax: 053 60699
Web: www.ozone.ie and www.epa.ie
E-mail: [email protected]
_________________________________________________________________
CONTENTS
_________________________________________________________________
STYLE:
_________________________________________________________________
INFORMATION:
_________________________________________________________________
SUGGESTIONS FOR FUTURE REVISIONS:
_________________________________________________________________
NAME…………………………….ORGANISATION……………………………………
ADDRESS…………………………………………………………………………………
DATE……………………….PHONE……………………….FAX………………………
E-MAIL………………………WEB……………………………
Page 40 of 43