4>EPA
United States
Environmental Protection
Agency
Air and Radiation
(6205J)
EPA430-B-01-001
February 2001
www.epa.gov/ozone
Guidance for the EPA Halon
Emission Reduction Rule
(40 CFR Part 82, Subpart H)
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Guidance for the EPA Halon Emission
Reduction Rule (40 CFR Part 82, Subpart H)
Covering compliance with technician training
and proper disposal requirements
Overview of guidance
I. Introduction 1
What does this guidance cover?
The training and disposal provisions of EPA's halon regulation
Why is this guidance being offered?
To respond to questions raised by the regulated community
Who should read this guidance?
Entities subject to the training and disposal requirements of the regulation
Other entities interested in the use or handling of halon
II. Complying with the Technician Training Requirement 2
What should halon technician training cover?
Explanation of why training is required
Overview of halons and environmental concerns with halons
Review of relevant regulations concerning halons
Specific technical instruction relevant to each individual facility
III. Proper Disposal and Recycling Guidance 6
What are the requirements for disposing of halon and halon-containing equipment?
Non-emergency venting of halon is prohibited
Halon in equipment must be recovered
What can be done to minimize losses of halon during recycling?
Appendix A. Definitions 9
Appendix B. Resources 10
Appendix C. Other Relevant Regulations, Codes, and Standards 13
Acknowledgements
This guidance was prepared by the Global Programs Division (GPD) of the U.S. Environmental
Protection Agency with the support of GPD's contractor, ICF Consulting, Inc. GPD gratefully acknowl-
edges the comments of two technical experts who reviewed a draft of this guidance. In addition, GPD grate-
fully acknowledges the assistance of the Halon Recycling Corporation (HRC) in coordinating a stakeholder
review in which members of the fire protection and halon recycling community provided comments.
Comments from both the technical review and stakeholder review were incorporated as appropriate.
Guidance for the EPA Halon Emission Reduction Rule
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, Introduction
This section describes the origin and intended audience for this guidance.
What does this guidance cover?
The training and disposal provisions of EPA's halon regulation
A U.S. Environmental Protection Agency (EPA) regulation published in the Federal Register on
March 5, 1998, (63 FR 11084) and codified in the Code of Federal Regulations (CFR) at 40 CFR
Part 82, Subpart H Halon Emissions Reduction regulated certain practices involving halons
with the purpose of minimizing their unnecessary release and maximizing their recovery and recy-
cling. See the information under references 9 and 12 in Appendix B of this guidance on how to get
a copy of the EPA regulation and an EPA summary of the regulation. This guidance
addresses two of the regulation's requirements: the technician training requirement
(40 CFR 82.270(c)) and the proper disposal requirement (40 CFR 82.270(d) and (e)).
EPA recognizes that technicians may perform multiple functions and may undergo
training for other purposes or requirements. The aim of EPA's technician training require-
ment is to ensure that technicians who service halon systems are trained to minimize
unnecessary releases of halons, and to maximize their recovery and recycling. The aim of
this guidance is to identify elements and topics that could be covered in such training.
This training may take the form of a stand-alone course, or may take the form of a unit or
session of existing training requirements. This document suggests an outline for training
but should not be considered the training itself. Each facility or organization, working with
this guidance, should develop training suitable to its particular situation.
Why is this guidance being offered?
To respond to questions raised by the regulated community
Following publication of the March 5, 1998, EPA rule, EPA received requests for clarification of
the training and disposal provisions of the regulation. This document, developed with input from
stakeholders, responds to these requests.
EPA intends for this document to be used solely as guidance. It does not substitute for EPA's reg-
ulations or those of any other agency, nor is it a regulation itself. Thus, it does not impose legally
binding requirements, and may not apply to a particular situation based upon the circumstances. In
addition, EPA may change this guidance in the future, as appropriate.
Who should read this guidance?
Entities subject to the training and disposal requirements of the regulation
Other entities interested in the use or handling of halon
Such entities include those that employ technicians who test, maintain, service, repair, or dispose
of halon-containing equipment, but may also include owners of halon-containing equipment as well
as others. For the purposes of this guidance, the definitions of halon, halon-containing equipment,
disposal of halon, disposal of halon-containing equipment, and technician are as stated in 40 CFR
82.260. Those definitions are reproduced in Appendix A for reference.
Guidance for the EPA Halon Emission Reduction Rule
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II, Complying with the
Technician Training
Requirement
Section II identifies key areas that EPA recommends be covered in the halon technician training
required under 40 CFR 82.270(c). EPA recommends that technician training be designed so that
general and environmental issues, including topics covered in the first three subsections below, cover
a time period of 1-3 hours. In addition, each facility should determine a suitable time period for
covering any additional technical instruction relevant to its particular situation, such as topics cov-
ered in the fourth subsection below. EPA also recommends that facilities document that personnel
have undergone this training. For example, local personnel records can be annotated, indicating
where and when the training occurred. Finally, EPA recommends that facilities provide periodic
refresher training at least every 2 years.
What should halon technician training cover?
Explanation of why training is required
Overview of halons and environmental concerns with halons
Review of relevant regulations concerning halons
Specific technical instruction relevant to each individual facility
The remainder of Section II discusses each of these areas. In each of the following boxes, we
describe in general terms the material that can be covered in a training program. For each topic, we
also identify references and resources that are available to the public. This information should help
you comply with the technician training requirement of the March 5, 1998, rule by indicating
appropriate topics and material you may find helpful in developing your training materials.
Explanation of why training is required
Trained technicians can better prevent halon emissions
Technicians are a key element in any effort to control unnecessary emissions of ozone-destroying
chemicals. Training technicians in the significance of, and procedures for, minimizing unintentional
halon releases is a vital part of EPA's effort to reduce emissions.
It is federal law
EPA's regulation published on March 5, 1998, requires that organizations that employ technicians who
test, maintain, service, repair, or dispose of halon-containing equipment must ensure that these techni-
cians are trained regarding halon emissions reduction (40 CFR 82.270(c)). Technicians should be trained
regarding control of the process to ensure minimum losses of halon to the atmosphere.
Guidance for the EPA Halon Emission Reduction Rule
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Overview of halons and environmental concerns with halons
Technicians should be aware of the broad environmental and regulatory con-
cerns that give rise to halon control. Technician training should include an
overview of these concerns, including the following key points:
Halons are effective fire protection agents
Halons are very effective fire and explosion suppression agents that are electri-
cally non-conductive and leave no residue. As such, they are extremely valuable
for certain applications. The halons covered by 40 CFR Part 82, Subpart H are
Halon 1211 (CF2ClBr), Halon 1301 (CF3Br), and Halon 2402 (C2F4Br2).
Sources of background information include references 17 and 18 in Appendix B.
Halons play an important role in stratospheric ozone (O3) depletion
The halons covered by 40 CFR Part 82, Subpart H contain the chemical element bromine (Br)
and also, in the case of Halon 1211, chlorine (Cl). Br and Cl both contribute to stratospheric ozone
destruction. The earth's stratosphere is a layer of the atmosphere that begins between 5 and 11 miles
above the earth's surface and extends up to about 30 miles above the earth's surface. Ninety percent
of the ozone in the earth's atmosphere is found in the stratosphere. The characteristics of halon and
other human-made chemicals that can deplete ozone (e.g., chlorofluorocarbons, or CFCs) enable
them to reach the stratosphere, where they break down and the Cl and Br
from them can destroy ozone. Halons are a major source of bromine in the
stratosphere. General information on stratospheric ozone depletion can be
found in references 6, 19, 32, and Web site 1 in Appendix B.
Stratospheric ozone destruction is a human health risk
Ozone in the earth's stratosphere protects the earth from the penetration
of harmful ultraviolet (primarily UV-B) solar radiation by absorbing most
of this harmful UV-B, allowing only a small amount to reach the earth's
surface. Without the filtering action of the ozone layer, more of the Sun's
UV-B radiation would penetrate the atmosphere and reach the earth's sur-
face. Increased UV-B radiation can lead to increased incidence of certain
skin cancers and cataracts, as well as other human health and environmen-
tal consequences. Further information on these subjects can be found in
references 6, 7, 30, and Web site 1 in Appendix B.
There is a limited supply of halon
Due to concerns about stratospheric ozone layer destruction, many
countries have, under the landmark international agreement known as the
"Montreal Protocol on Substances that Deplete the Ozone Layer," ended
or plan to end production of ozone-depleting substances. The Montreal
Protocol was first negotiated in 1987 and now involves more than 162
countries. In the United States, halon production ended in 1994, and recy-
cled halon and inventories produced before January 1, 1994, are now the
only sources of supply. References 5 and 8 in Appendix B describe U.S.
government and industry programs that were developed in response to the
ban on halon production to store ("bank") and trade halon.
Halon 1301 total flooding system cylinders held in
storage. Cylinders such as these are collected from
decommissioned systems, and the halon is recycled
and banked for critical government and industry
programs. Photo courtesy of U.S. Department of
Defense (DOD), Defense Logistics Agency (DLA),
Ozone Depleting Substance (ODS) Reserve.
Guidance for the EPA Halon Emission Reduction Rule
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There are alternative agents for most current halon applications
EPA has, under its Significant New Alternatives Policy (SNAP) program, listed several acceptable
alternative agents and technologies for halon total-flooding and streaming applications. The SNAP
program goal is to ensure that industry and consumers have ample alternatives to applications for
which ozone-depleting substances, including halons, are currently used; and that these alternatives
reduce the overall risk to human health and the environment. References 14, 15, 18, 26 and 27, and
Web site 1 in Appendix B describe halon alternatives and EPA's SNAP program.
Review of relevant regulations concerning halons
EPA's regulation published March 5, 1998 (40 CFR Part 82, Subpart H):
In addition to requiring technician training, this regulation makes it
unlawful to:
Vent halons during testing, maintaining, servicing, repairing, or disposing of
halon-containing equipment.
Vent halons during the use of halon-containing equipment for technician
training purposes.
Allow halon releases from halon-containing equipment to occur as a result of
failure to maintain equipment.
Dispose of halon-containing equipment except by sending it for halon recov-
ery to facilities operating in accordance with National Fire Protection
Association (NFPA) 10 and NFPA 12A standards.
Dispose of halon except by sending it for recycling to a recycling facility oper-
ating in accordance with NFPA 10 and NFPA 12A standards or by arranging
for its destruction by an EPA-approved process.
Manufacture halon blends, due to the inability to economically recycle and
reuse such blends.
The prohibitions on venting do not apply to the emergency release of halons for
the legitimate purpose of fire extinguishing, explosion inertion, or other emergency
applications for which the equipment or systems were designed.
Certain limited exemptions are identified in the regulation. Please refer
to the text of the regulation for more detail on specific provisions and
exceptions.
Other regulations that currently cover halons in the U.S.
Technicians should be aware that other federal, state, and local regula-
tions, and industry and professional codes may exist that might affect work
on halon systems. These may include, but are not limited to, other EPA
regulations, U.S. Department of Transportation (DOT) regulations,
Occupational Safety and Health Administration (OSHA) regulations,
codes and standards of NFPA, and other federal, state, or local fire, build-
ing, safety, and environmental codes and standards. Appendix C contains a
discussion of some of these other regulations and codes.
One example of halon-
containing equipment. This is
a hand-held Halon 1211 fire
extinguisher containing a 20 Ib
charge. See Appendix A for a
definition of halon-containing
equipment. Photo courtesy of
U.S. DOD/DLA CDS
Reserve.
This "Non-Flammable Gas" label is one of
the requirements when shipping halon.
U.S. Department of Transportation
(DOT) regulations for shipment of haz-
ardous materials apply to halon ship-
ments. Photo courtesy of U.S.
DOD/DLA ODS Reserve.
Guidance for the EPA Halon Emission Reduction Rule
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Specific technical instruction relevant to each individual facility
Losses of halon may occur if halon-containing equipment is handled improperly. Thus, to prevent
unnecessary losses of halon, technicians should receive training on equipment that they use daily.
Key resources in this section of your training program might include:
Manufacturer manuals and training materials
EPA Safety Guide for Decommissioning Halon Systems
Unnecessary losses of halon can occur if halon systems are improperly decommissioned (removed
from service). The EPA Safety Guide for Decommissioning Halon Systems (reference 13 in
Appendix B) was prepared to assist personnel involved in decommissioning halon cylinders with the
identification and safe handling procedures for the most readily available cylinders. It contains man-
ufacturer's specifications and instructions for handling specific equipment, as well as generic instruc-
tions for safe decommissioning of halon systems. It contains diagrams of cylinder and/or valve con-
figurations from the following halon system manufacturers: Ansul, Chemetron, Fenwal, Kidde, Fike,
Ginge Kerr, Pyrotronics, and Wormald.
Demonstration equipment
Cut-away valves, cylinders, and connections can further assist technicians in
their understanding of the causes of halon emission.
Coverage of key issues
Risks associated with high pressure cylinders. Unintended losses of halon
may occur when high pressure cylinders are not handled properly. In addi-
tion, for safety reasons, experts stress that any decommissioning of high-
pressure cylinders, such as those containing halon, must be performed only by
properly trained personnel. Serious injury or death can occur from improper
handling of high-pressure cylinders.
Use of manufacturer manuals for all procedures including arming/disarming,
power up/down, decommissioning.
Equipment field inspections to detect leaks and loss of agent.
Procedures for the safe and legal transport and storage of halon cylinders
(e.g., properly securing containers, protection of container fittings).
Safeguards for injury and leak prevention during recharging operations.
Use of appropriate equipment during recharging.
List of documentation and resources available to technicians
Technicians should know where to find key references concerning halons and halon-containing
equipment at your facility. These may include copies of NFPA, American Society for Testing and
Materials (ASTM), International Organization for Standardization, EPA, DOT, and military specifi-
cations (if relevant); OSHA regulations, codes, or standards; copies of manufacturers' equipment
and/or servicing manuals; and copies of materials used or referenced during training. These may also
include log books for maintenance and service, contact information for repair contractors, informa-
tion referenced in this guidance, and log books for halon recovery and recycling jobs.
Cut-away of the valve from a
halon 1301 total flooding system
cylinder. Training aids such as this
can be used in technician training
courses to provide an under-
standing of how the systems
work. Photo courtesy of U.S.
DOD/DLA ODS Reserve.
Guidance for the EPA Halon Emission Reduction Rule
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Proper Disposal and
Recycling Guidance
Section III reviews the halon and halon-containing equipment disposal requirements (82.270(d)
and (e)) of the March 5, 1998, rule. This Section also discusses recommended practices affecting
halon recycling and reclamation equipment.
What are the requirements for dispos-
ing of halon and halon-containing
equipment?
Non-emergency venting of halon is pro-
hibited
See discussion under "Review of relevant regula-
tions concerning halons," page 4.
Halon in equipment must be recovered
The EPA regulation published on March 5, 1998,
requires that when you dispose1 of any equipment
containing halon, you must arrange for recovery of
the halon by sending the equipment to a facility that
operates in accordance with NFPA standards 10 and
12A (references 23 and 24 in Appendix B, and
Appendix C) (82.270(d)).
The EPA regulation further requires that halon itself can only be disposed of by:
Sending the halon for recycling to a facility operating in accordance with the NFPA standards
mentioned above, or
Arranging for its destruction by a destruction process that meets relevant regulations
(82.270(e)).
There are six processes that have been identified as suitable for destruction by the Parties to the
Montreal Protocol. These are (1) liquid injection incineration, (2) reactor cracking, (3)
gaseous/fume oxidation, (4) rotary kiln incineration, (5) cement kiln, and (6) radiofrequency plasma
destruction. In addition, destruction technologies that achieve destruction efficiencies of 98 percent
or greater may be approved by EPA.
In the United States, very few destruction facilities for ozone-depleting substances (ODSs) such as
halons currently exist. This is due in part to technical difficulties in destroying halons and other
ODSs, and the costs of doing so. EPA continues to monitor technological developments in the
Technician connecting hose to a halon storage cylinder from a halon
recycling unit operated in accordance with NFPA standards. EPA reg-
ulations prohibit disposal of halon except by sending it for recycling
to a recycler operating in accordance with NFPA standards - or by
arranging for its destruction via approved processes. Photo courtesy
of U.S. DOD/DLA ODS Reserve.
The definition of "disposal" as originally provided in 40 CFR Part 82, Subpart H, is reproduced in Appendix A.
Guidance for the EPA Halon Emission Reduction Rule
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United States and other countries for the
destruction of ozone-depleting substances.
What can be done to minimize
losses of halons during
recycling?
EPA does not impose specific performance
requirements for equipment used to recycle
halon (see references 10 and 11 in Appendix
B). Our research shows that all such com-
mercially available equipment already meets
certain targets for recovery and overall
process efficiency, and is capable of restoring
halon to high industry standards for chemical
purity. For the purposes of the discussion in
this subsection, "What can be done to mini-
mize losses of halons during recycling?" the
definition of the terms in the box may be
useful.
To ensure that halon recycling continues
to occur with minimal losses of halon to the
atmosphere, you should:
Operate and maintain recovery and
recycling equipment in strict accor-
dance with manufacturer specifications
to ensure that it performs as specified
Recovery, recycling
The terms "recovery" and "recycling" in the
context of halons have been defined in several
ways. For the purposes of the discussion in this
subsection, "What can be done to minimize
losses of halons during recycling?" these terms
can be understood as follows. The term "con-
trolled substance" below includes halons.
Recovery
The collection and storage of controlled sub-
stances from machinery, equipment, contain-
ment vessels, etc., during servicing or prior to
disposal.
Recycling
The application of a basic cleaning process
such as filtering or drying to a controlled sub-
stance. For the purposes of the discussion fol-
lowing this box, "recycling" also includes what
has also been termed "reclamation," defined as
the reprocessing and upgrading of a recovered
controlled substance through such mechanisms
as filtering, drying, distillation and chemical treat-
ment, in order to restore the substance to a
specified standard of performance.
Ensure that cross-contamination does
not occur through the mixing of halons and/or refrig-
erants that may be contained in similar cylinders.
When a given halon is recycled, it is essential that the
recovery and recycling equipment be purged of other halons
and/or refrigerants that may have been previously recycled
using the same equipment. It is expensive to purify a halon
that has been contaminated with other halons or CFCs, and
such contaminated mixtures typically have to be destroyed.
The principal objective of recycling equipment is to remove
contaminants of residue, suspended matter, water, oils, etc.,
and to return the halon to one of the purity standards listed
in the box on page 8. Either at time of resale, or on a period-
ic basis, a sample of recycled halon should be tested by gas
chromatography to ensure that the purity standard is being
maintained.
Technician taking a sample of Halon 1301. Recycled halon
should be tested by an independent laboratory to ensure
product conformance to specifications. Photo courtesy of
U.S. DOD/DLA ODS Reserve.
Guidance for the EPA Halon Emission Reduction Rule
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Chemical purity
standards
Guidance on test
conditions
Sampling/laboratory
methods
Halon 1211
ISO 720I
ULC/ORD-CI058.5-I993
Mil-B-3874!
UL 2006
UL2006(§4I)
ULC/ORD-CI058.5-I993
UL2006(§4I)
ULC/ORD-CI058.5-I993
These standards may be periodically revised.
Halon 1301
ISO 720I
ULC/ORD-CI058.5-I993
ASTM D5632-95
NFPA I2A
UL 2083
UL 2083 (§42)
ULC/ORD-CI058.5-I993
UL 2083 (§42)
ULC/ORD-CI058.5-I993
ASTM D5632-95
Acronyms and abbreviations:
ISO: International Organization for Standardization
ASTM: American Society for Testing and Materials
NFPA: National Fire Protection Association
UL: Underwriters' Laboratories
ULC: Underwriters' Laboratories of Canada
"Mil" signifies a U.S. military specification
For further information:
Appendix B Resources provides a list of references, information on how to obtain many of
the references, and a list of Web sites for several organizations mentioned in this guidance, includ-
ing EPA's Stratospheric Ozone Web site. For further copies of this guidance, as well as for answers
to questions on EPA's stratospheric ozone protection programs and regulations, please contact:
U.S. Environmental Protection Agency
Stratospheric Protection Hotline
800 296-1996
8
Guidance for the EPA Halon Emission Reduction Rule
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Appendix A, Definitions
Reproduced from 40 CFR 82.260:
Halon means any of the Class I, Group II substances listed in subpart A, Appendix A of 40 CFR
Part 82. This group consists of the three halogenated hydrocarbons known as Halon 1211, Halon
1301, and Halon 2402, and all isomers of these chemicals.
Halon-containing equipment means equipment used to store, transfer, and/or disperse halon.
Disposal of halon means the process leading to and including discarding of halon from halon-
containing equipment.
Disposal of halon-containing equipment means the process leading to and including: (1) The
discharge, deposit, dumping, or placing of any discarded halon-containing equipment into or on
any land or water; (2) the disassembly of any halon-containing equipment for discharge, deposit, or
dumping or placing of its discarded component parts into or on any land or water; or (3) the disas-
sembly of any halon-containing equipment for reuse of its component parts.
Technician means any person who performs testing, maintenance, service, or repair that could
reasonably be expected to release halons from equipment into the atmosphere. Technician also
means any person who performs disposal of equipment that could reasonably be expected to release
halons from the equipment into the atmosphere. Technician includes but is not limited to installers,
contractor employees, in-house service personnel, and in some cases, owners.
Guidance for the EPA Halon Emission Reduction Rule
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Appendix B. Resources
References
[I] ASTM, 1994. Standard Practice for Handling Transportation and Storage of Halon 1301
Bromotrifluoromethane (CF3BR). ASTM standard designation D563I -94.
[2] Andersen, S.O., Metchis, K.L, and Rubenstein, R., 1995. "The History of the Halon Phaseout and
Regulation of Halon Alternatives," Chapter 2 IN: Halon Replacements: Technology and Science,
American Chemical Society (ACS) Symposium Series 611, ACS, Washington, DC.
[3] Cook, E. (Editor), 1996. Ozone protection in the United States - Elements of Success. World Resources
Institute, Washington, D.C.
[4] Environment Canada, 1996. Code of Practice on Halons. Code of Practice Environmental Protection
Series (EPS) I/RA/3E, July 1996.
[5] EPA, 1993. Halon: Recycling and Banking to Help Protect the Ozone Layer. EPA 430-F-92-034. February,
1993. Brochure sponsored by EPA in cooperation with the Halon Alternatives Research Corporation
(HARC). Brief background on halons' role in stratospheric ozone depletion and the relation of stratos-
pheric ozone and human health, as well as EPAs regulatory response. Describes cessation of halon
production and the need for halon recycling; the role of the Halon Recycling Corporation, and the
role of fire equipment distributors. Available by calling the EPA Stratospheric Protection Hotline at
800296-1996.
[6] EPA, 1995. Ozone Depletion. U.S. EPA 430-F-95-OOI. April, 1995. Fact sheet produced by the U.S. EPA
and available by calling the EPA Stratospheric Protection Hotline at 800 296-1996.
[7] EPA, 1995. UV Radiation. U.S. EPA 430-F-95-006. April 1995. Fact sheet produced by the U.S. EPA and
available by calling the EPA Stratospheric Protection Hotline at 800 296-1996.
[8] EPA, 1995. CFC and Halon Banking: Government Programs to Protect the Ozone Layer. EPA 430- F-
95-112. September, 1995. Brochure prepared by the EPA Stratospheric Protection Division and U.S.
DOD/Defense Logistics Agency Defense General Supply Center. Brief background on halon's role in
stratospheric ozone depletion and the relation of stratospheric ozone and human health. Describes the
inception and functioning of the U.S. Department of Defense (DOD) ozone-depleting substance
(ODS) reserve. Available by calling the EPA Stratospheric Protection Hotline at 800 296-1996.
[9] EPA, 1998. Final rule published at 63 Federal Register (FR) 11084. Protection of Stratospheric Ozone:
Manufacture of Halon Blends, Intentional Release of Halon, Technician Training and Disposal of Halon
and Halon-Containing Equipment. Available on the EPA Stratospheric Ozone Web site
(www.epa.gov/ozone) and from the EPA Stratospheric Protection Hotline at 800 296-1996.
[10] EPA, 1998. Direct final determination published at 63 FR 42728. Protection of Stratospheric Ozone:
Halon Recycling and Recovery Equipment Certification. Available on the EPA Stratospheric Ozone Web
site (www.epa.gov/ozone) and from the EPA Stratospheric Protection Hotline at 800 296-1996.
[II] EPA, 1998. Summary of Determination: Halon Recovery/Recycling Equipment Certification. August,
1998. Summary of EPA Direct final determination published at 63 FR 42728 (Protection of
Stratospheric Ozone: Halon Recycling and Recovery Equipment Certification). Available on the EPA
Stratospheric Ozone Web site (www.epa.gov/ozone) and from the EPA Stratospheric Protection
Hotline at 800296-1996.
[12] EPA, 1998. Final Rule Summary: Halons/Halon Blends. March, 1998. Summary of the EPA final rule pub-
lished at 63 FR 11084 (Protection of Stratospheric Ozone: Manufacture of Halon Blends, Intentional
Release of Halon, Technician Training and Disposal of Halon and Halon-Containing Equipment).
Available on the EPA Stratospheric Ozone Web site (www.epa.gov/ozone) and from the EPA
Stratospheric Protection Hotline at 800 296-1996.
10 Guidance for the EPA Halon Emission Reduction Rule
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[13] EPA, 1999. Safety Guide for Decommissioning Halon Systems. Volume 2 of the U.S. Environmental
Protection Agency Outreach Report, "Moving Towards a World Without Halon." Available on the
Internet at www.harc.org.
[14] EPA, 1999 (periodically updated). Halon Substitutes Under SNAP as of June 8, 1999. This fact sheet is
periodically updated to reflect current listings of halon substitutes as reviewed by EPAs Significant
New Alternatives Policy (SNAP) Program. This fact sheet is available on EPAs Stratospheric Ozone
Web site at www.epa.gov/ozone and is also available from the EPA Stratospheric Protection Hotline at
800296-1996.
[15] EPA, 1999 (periodically updated). Questions and Answers on Halons and their Substitutes. Revision 14.
Fact sheet providing an overview of regulations governing the production and use of halon and the
development of substitute agents for fire suppression and explosion protection. This fact sheet is peri-
odically updated and available on EPAs Stratospheric Ozone Web site at www.epa.gov/ozone and is
also available from the EPA Stratospheric Protection Hotline at 800 296-1996.
[16] Friends of the Earth (FOE), 1999. Ozone - Re-ignite The Effort: Halon Recovery to Protect the Earth's
Ozone Layer. Brochure produced by Friends of the Earth and available at www.foe.org.
[17] Gann, R.G. (editor), 1975. Halogenated Fire Suppressants. American Chemical Society (ACS)
Symposium Series, Gould, R.F (series editor), ACS, Washington, DC. 453 pp.
[18] Grant, C.C., 1994. Halon and beyond: Developing new alternatives. National Fire Protection
Association (NFPA) Journal, November/December 1994: 41 -54.
[19] Halon Alternatives Research Corporation (HARC). The ozone layer and halons. Brochure prepared by
HARC and available by contacting HARC at www.harc.org.
[20] Halon Recycling Corporation (HRC) Code of Practice for Halon Reclaiming Companies. Halon
Recycling Corporation, Arlington, VA.
[21] Halon Technical Options Committee (HTOC), 1997 Halon emission reduction strategies. HTOC
Technical Note #2. The most current versions of the HTOC Technical Notes are available on the
Internet at www.teap.org. This is a technical document that describes general practices for minimizing
unnecessary emissions of halons to the atmosphere.
[22] Mitchell, M.D, 1991. Feasibility of Systematic Recycling of Aircraft Halon Extinguishing Agents. U.S.
Department of Transportation (DOT) Federal Aviation Administration (FAA) report DOT/FAA/CT-
91/21. FAA Technical Center, Atlantic City International Airport. Final Report. Available from the
National Technical Information Service (NTIS), Springfield, VA.
[23] NFPA 10. Standard for Portable Fire Extinguishers. 1998 Edition. National Fire Protection Association,
Quincy MA.
[24] NFPA I2A. Standard on Halon 1301 Fire Extinguishing Systems. 1997 Edition. National Fire Protection
Association, Quincy, MA.
[25] NFPA 2001. Standard for Clean Agent Fire Extinguishing Systems. 2000 Edition. National Fire
Protection Association, Quincy, MA.
[26] Scott, D, 1997 Halon -the hunt for alternatives. National Fire Protection Association (NFPA) Journal,
July/August, 1997: 62-65.
[27] Seaton, M., 1995. Halon: Searching for solutions. NFPA Journal, November/December, 1995: 47- 53.
[28] Underwriters' Laboratories of Canada (ULC), Inc., 1993. The servicing of halon extinguishing systems.
ULC/ORD-C1058.18-1993.
[29] United Nations Environment Programme (UNEP), 1994. Montreal Protocol on Substances that
Deplete the Ozone Layer - Report of the Halon Fire Extinguishing Agents Technical Options
Committee. December, 1994. UNEP Ozone Secretariat. Nairobi, Kenya.
Guidance for the EPA Halon Emission Reduction Rule 11
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[30] UNEP, 1998. Environmental Effects of Ozone Depletion: 1998 Assessment. Copies of this report are
available from the U.S. Global Change Research Information Office, CIESIN, Columbia University, P.O.
Box 1000, 61 Route 9W, Palisades, NY 10964 (USA), Phone: (914) 365-8930, Fax: (914) 365-8922,
e-mail: help@gcrio.org
[31] UNEP, 1998. Montreal Protocol on Substances that Deplete the Ozone Layer - Technology and
Economic Assessment Panel, April, 1998 Report. UNEP Ozone Secretariat. Nairobi, Kenya.
[32] World Meteorological Organization (WMO), 1998. Scientific Assessment of Ozone Depletion: 1998.
WMO Global Ozone Research and Monitoring Project - Report No. 44.
Additional Web sites:
[ I ] www.epa.gov/ozone
The U.S. Environmental Protection Agency Web site provides listings of U.S. EPA regulations pertinent
to ozone-layer protection, including all those dealing with halons, and accompanying summaries and
fact sheets. This site also provides extensive background scientific information on ozone depletion and
ozone-layer protection, and provides many links to additional scientific and environmental sites. The
Web page www.epa.gov/ozone/title6/snap/hal.html provides a series of questions and answers on EPA
regulations governing the production and use of halons and the development of substitute agents for
fire suppression and explosion protection. The Web page www.epa.gov/ozone/title6/snap/lists/halo.pdf
provides a list of halon substitutes.
[2] www.nfpa.org
Web site of the National Fire Protection Association, 617 770-3000
[3] www.nafed.org
Web site of the National Association of Fire Equipment Dealers, 312 923-8500
[4] www.harc.org
Web site of the Halon Alternatives Research Corporation, 703 524-6636
[5] www.unep.ch/ozone
Comprehensive documentation and reports surrounding the Montreal Protocol and its implementation.
[6] www.teap.org/html/halons.html
Home page of the Halons Technical Options Committee of the United Nations Environment
Programme, Montreal Protocol Technology and Economic Assessment Panel.
Other contact information:
Halon Recycling Corporation, 800 258-1283.
12 Guidance for the EPA Halon Emission Reduction Rule
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Appendix C, Other relevant
regulations, codes, and
standards
This appendix briefly discusses several other agencies' and organizations' regulations, codes and
standards. This appendix is not meant to be an exhaustive list, but rather a brief reference to some
other regulations, codes, and standards of potential importance to technicians who handle halons
and halon-containing equipment.
U.S. Environmental Protection
Agency
Title VI of the Clean Air Act (CAA) requires the U.S.
Environmental Protection Agency (EPA) to develop and imple-
ment regulations and programs to protect the stratospheric
ozone layer. Major elements of EPA's program include regula-
tions to end production and import of ozone-depleting sub-
stances (ODSs), including halons, and a set of requirements
banning intentional venting of ODSs, minimizing their unnec-
essary emissions, and maximizing their recycling. EPA has also
prescribed certain service practices in certain key sectors (e.g.,
refrigeration, motor-vehicle air conditioning). The ban on pro-
duction and import of halon became effective in 1994, making
recycled halon and inventories produced before January 1,
1994, the only sources of supply (40 CFR Part 82, Subpart A).
Specific requirements designed to minimize halon emissions
and maximize their recycling became effective on April 6, 1998
(40 CFR Part 82, Subpart H). This guidance document focuses
on the halon technician training requirement and on the proper disposal requirements of 40 CFR
Part 82, Subpart H. As noted earlier in this guidance, 40 CFR Part 82, Subpart H also includes
other provisions. See the guidance section, "Review of relevant regulations concerning halons," page
4. EPA has also mandated that all containers of and products that contain or are manufactured with
Class I ozone-depleting substances be labeled to this effect. This labeling requirement (40 CFR Part
82, Subpart E) also applies to halon products and containers. Finally, under section 612 of the
Clean Air Act, EPA established the Significant New Alternatives Policy (SNAP) program (40 CFR
Part 82, Subpart G). SNAP's mandate is to identify alternatives to ozone-depleting substances,
including halons, and to publish lists of acceptable and unacceptable substitutes. The SNAP lists are
periodically updated and are available for online reading or for downloading (see Web site 1 and ref-
erences 14 and 15 in Appendix B). The following summarizes key EPA regulations relating to halon
and halon substitutes:
40 CFR Part 82, Subpart A Production and Consumption Controls.
Guidance for the EPA Halon Emission Reduction Rule
13
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40 CFR Part 82, Subpart E - The Labeling of Products Using
Ozone-Depleting Substances.
40 CFR Part 82, Subpart G - Significant New Alternatives
Policy Program.
40 CFR Part 82, Subpart H - Halon Emissions Reduction.
In addition, Halon 1301 is listed under EPA's Emergency Planning
and Community Right-to-Know Act (EPCRA) Section 313, the Toxic
Chemical Release Reporting program, commonly called the Toxics
Release Inventory orTRI. For more information on any of EPA's envi-
ronmental release reporting requirements, including more information
on the TRI program under EPCRA Section 313, call the EPA RCRA,
Superfund, and EPCRA Hotline at 800 424-9346.
U.S. Department of Transportation
The U.S. Department of Transportation (DOT) regulations relate to the transportation of haz-
ardous materials. Under 49 CFR Part 172, bromotrifluoromethane (known as both R 13B1 and
Halon 1301) is classified as a hazardous material because it is a compressed gas and is therefore sub-
ject to the requirements of DOT hazardous materials regulations and procedures. Halon 1301 and
Halon 1211 are classified as Division 2.2 hazardous material. Division 2.2 refers to a non-flammable,
nonpoisonous compressed gas.
Under Part 172, Special Provision 18 of Section 172.102 contains additional requirements when
using the shipping description "fire extinguishers" for transportation. Section 172.700 specifies
requirements for hazardous materials training and function-specific training as related to handling
and transportation of hazardous materials, and requalification of hazardous materials packaging.
Two other Parts of 49 CFR are of central importance:
49 CFR Part 173, DOT Specifications, Shippers General Requirements for Shipping and
Packagings.
49 CFR Part 178, DOT Specifications, Specifications for Packagings.
Part 173-34 specifies requirements for the qualification, maintenance, and use of cylinders used to
transport hazardous materials. Sections 173-309a and 173-309b specify
requirements for nonspecification and specification cylinders as related
to fire extinguishers. Part 178 prescribes the manufacturing specifica-
tions for DOT specification packaging and containers used for the
transportation of hazardous materials in commerce.
The full text of these regulations is available at http://www.text-
trieve.com/dotrspa.
Two other organizations under DOT the Federal Aviation
Administration and the U.S. Coast Guard have issued regulations or
guidance pertinent to the use and handling of halons. Please see the
other sections of this appendix addressing halon-related requirements
for these organizations.
A truck being loaded with a Halon 1301 sys-
tem cylinder The U.S. Department of
Transportation (DOT) regulates transporta-
tion of compressed gases, including halons.
Photo courtesy of U.S. DOD/DLA ODS
Reserve.
14
Guidance for the EPA Halon Emission Reduction Rule
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Federal Aviation Administration
The most effective and commonly used fire protection systems currently used on aircraft are
halon systems. The Federal Aviation Administration (FAA) has issued regulations to establish fire
detection and suppression standards with the purpose of providing protection from possible in-flight
fires. Several relevant sections of FAA regulations are listed below. These regulations establish aircraft
requirements for fire fighting and extinguishing agents. FAA inspectors also generally require that
NFPA and DOT guidance relevant to these systems is followed. In addition, FAA Order 1015-18
(CFC and Halon Use at FAA Facilities) is used by FAA employees and contractors when servicing
FAA facilities. It should be noted that FAA is engaged in both developing minimum performance
standards for alternative agents and systems for aircraft fire protection, as well as evaluating specific
alternative agents for certification.
14 CFR Part 23 Airworthiness Standards: Normal, Utility, Acrobatic, and Commuter
Category.
14 CFR Part 25 Airworthiness Standards: Transport
Category Airplanes.
14 CFR Part 27 Airworthiness Standards: Normal Category
Rotorcraft.
14 CFR Part 29 Airworthiness Standards: Transport
Category Rotorcraft.
14 CFR Part 121 Operating Requirements: Domestic, Flag
and Supplemental Operations.
14 CFR Part 135 Operating Requirements: Commuter and
On-Demand Operations.
U.S. Coast Guard
The U.S. Coast Guard (USCG) originally published inspecting and testing requirements of ship-
board fixed halon fire extinguishing system cylinders under 46 CFR. In 1995, the USCG published
a Navigation and Vessel Inspection Circular (NVIC 3-95) that provided alternative testing require-
ments for fixed halon fire extinguishing system steel storage cylinders. Technicians responsible for
halon cylinders that may be covered under this USCG Circular and the regulations cited therein
should be familiar with these materials.
Occupational Safety and Health Administration
Three areas of Occupational Safety and Health Adminstration (OSHA) regulations pertain to the
use of halons or halon-containing equipment. Entities that use halons or halon-containing equip-
ment may wish to be familiar with the following areas of concern. These areas are (1) safety con-
cerns related to use of and work with compressed gases, (2) workplace fire protection standards, and
(3) toxicity concerns related to exposure to hazardous gases. All relevant OSHA regulations can be
found in 29 CFR part 1910. Because halons are often contained, transported, or stored in pressur-
ized cylinders, Subpart H may be of interest. Furthermore, because halons are used in workplaces as
fire protection agents, Subpart L may be of interest.
Guidance for the EPA Halon Emission Reduction Rule 15
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29 CFR Part 1910, Subpart H Hazardous Materials. This subpart concerns hazardous
materials, with Section 101 addressing compressed gases.
29 CFR Part 1910, Subpart L Fire Protection . This subpart concerns workplace fire pro-
tection standards. In particular, Sections 157, 160, and 162 address portable extinguishers
and gaseous agents (including Halon 1301 and 1211) for fixed extinguishing systems,
respectively.
29 CFR Part 1910, Subpart Z Toxic and Hazardous Substances. This subpart concerns
permissible exposure limits (PELs) in Section 1000 and hazard communication standards in
section 1200.
National Fire Protection Association standards
The National Fire Protection Association (NFPA) is an international, nonprofit, membership fire
protection organization with a role as a leading worldwide authority on the topics of fire safety and
protection. NFPA fire codes and standards are used throughout the world, with some local or feder-
al authorities adopting by reference NFPA codes or standards. Two NFPA standards of key impor-
tance for technicians working with halons or halon-containing equipment are:
NFPA 12A. Standard on Halon 1301 Fire Extinguishing Systems. 1997 Edition. This stan-
dard contains minimum requirements for total flooding Halon 1301 fire extinguishing sys-
tems and is prepared for the use and guidance of those charged with purchasing, designing,
installing, testing, inspecting, approving, listing, operating, maintaining, decommissioning,
and removing Halon 1301 systems. This standard states, among many other things, that the
charging or recharging of cylinders or the removal or transfer of agent should be done using
a closed loop system, which permits transfer of halon between supply cylinders, system
cylinders, and recovery cylinders, with only minor loss of halon to the atmosphere.
NFPA 10. Standard for Portable Fire Extinguishers. 1998 Edition. This standard applies to
the selection, installation, inspection, maintenance, and testing of portable extinguishing
equipment (including halon type portable extinguishers). NFPA 10 states, among other
things, that the removal of Halon 1211 from fire extinguishers shall be done only using a
listed halon closed recovery system. The removal of agents from other halogenated agent fire
extinguishers shall be done using only a closed recovery system. A closed recovery system is
defined as a system that provides for the transfer of halogenated agents between fire extin-
guishers, supply containers, and recharge and recovery containers so that none of the halo-
genated agent escapes to the atmosphere.
Furthermore, NFPA 10 requires periodic hydrostatic testing of portable fire extinguishers, includ-
ing halon extinguishers. Hydrostatic testing is pressure testing of an extinguisher to verify its
strength against unwanted rupture. The standard also requires that halon extinguishers be torn
down every 6 years and the condition of the internal cylinder walls be examined for corrosion. It
should be noted that these procedures require that all extinguishing agents be removed from the
extinguisher. To accomplish the removal of halon from the extinguisher, the standard requires the
use of a closed recovery system. The standard requires that these maintenance activities be per-
formed by trained persons. It should be noted that opportunities for halon losses might arise during
these procedures. Under EPA regulations, such losses must be minimized
In addition, a third NFPA standard addresses minimum requirements for total flooding, clean
agent fire extinguishing systems. This standard was established to address the need for how to
16 Guidance for the EPA Halon Emission Reduction Rule
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design, install, maintain, and operate systems using the new total flooding clean agents that were
being developed to replace Halon 1301.
NFPA 2001. Standard on Clean Agent Fire Extinguishing Systems. 2000 Edition.
Halon Recycling Corporation
The Halon Recycling Corporation (HRC) is a nonprofit
information clearinghouse established to assist sellers wishing
to dispose of halon in a responsible manner, and to help buy-
ers with "critical uses" of halon locate supplies of Halon 1301
and Halon 1211 for recharging their existing systems. HRC
has developed a "Code of Practice for Halon Reclaiming
Companies." This Code of Practice identifies a set of volun-
tary measures to assure safe and environmentally responsible
halon reclamation that sellers of halon enrolled in HRC have
agreed to observe. The Code of Practice covers reclaiming
operations, safety, equipment, and customer service issues.
Other federal, state, or local fire,
building, industry, or safety codes and standards
Technicians should also be aware of other local, state, federal, or professional codes, regulations,
and standards that might impact their work on halon systems.
Guidance for the EPA Halon Emission Reduction Rule
17
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