'ICF Market Characterization of the U.S. Defense Spray Industry Prepared for: Stratospheric Protection Division Office of Air and Radiation U.S. Environmental Protection Agency Washington, D.C. 20460 Prepared by: ICF 2550 S Clark St. Suite 1200 Arlington, VA 22202 February 2021 ------- Table of Contents 1. Summary 1 2. Introduction 1 3. Market Characterization 1 3.1. Overview of Defense Sprays 2 3.2. Major Manufacturers 2 4. Subsector Background and HFC Use 2 4.1. Current Propellants in Defense Sprays 2 4.2. Projected HFC Use in the Defense Spray Subsector 5 4.3. Imports and Exports of Defense Spray Products in the United States 7 5. References 8 2 ------- 1. Summary Defense Sprays are aerosol-based sprays intended for self-defense, including pepper spray and animal sprays. The defense spray industry historically used chlorofluorocarbons (CFCs) as a propellant. The defense spray industry transitioned to hydrofluorocarbon (HFC) propellants as replacements to CFCs in the mid-1990s, specifically HFC-134a. In 2020, approximately 125 metric tons (MT) of HFC-134a propellant was contained in defense sprays sold in the United States. The use of HFC-134a propellant in defense sprays in the United States is expected to continue due to its non-flammability and physical properties to provide adequate spray distance for foam, fog, and vapor defense sprays (Safariland 2017a, EPW 2020c). Efforts to reformulate have not yet reached the exacting standards of the industry (EPW 2020a, EPW 2020b). In 2040, it is projected that approximately 154 MT of HFC-134a propellant will be used in defense sprays. 2. Introduction Defense sprays consist of aerosol-based sprays intended for self-defense, including pepper spray and animal sprays (e.g., bear and dog sprays). Defense sprays are utilized in situations involving law enforcement and/or where one's personal safety is at risk. These defense sprays must perform across a wide variety of scenarios and environments and maintain critical performance parameters including spray distance and volume, aerosol characteristics, and flammability. (EPW 2020a) Defense sprays utilize four different delivery methods, including streaming, foam, fog, and vapor sprays. Of particular interest are defense aerosol sprays delivered as a fog, such as those used by law enforcement and in bear sprays. Fog formulations provide area coverage, discharging a cone pattern of spray between the user and assailant, and cover a larger area without requiring precise aiming. In the case of defense against a bear, the spray distance and volume must be maximized to ensure public safety (Safariland 2017a). The defense spray industry utilizes HFC- 134a propellant due to its non-flammability, high vapor pressure, low boiling point, and solubility with the defense spray formulation. Manufacturers have found it challenging to replace HFC- 134a and maintain acceptable performance of the defense spray (EPW 2020a, EPW 2020b). The remainder of this report characterizes HFC use by the U.S. defense spray industry, including key market players and historical and current consumption of HFCs and other propellants in defense sprays. 3. Market Characterization This section provides an overview of defense spray products and applications as well as the current defense spray market and key manufacturers. 1 ------- 3.1. Overview of Defense Sprays Commercially available self-defense sprays contain a chemical irritant and a propellant. Self- defense sprays typically contain a lachrymator (i.e., an irritant that causes tearing) as the active ingredient, such as chloroacetophenone (mace), orthochlorobenzylidenemalononitrile (tear gas), or a pepper extract (Honeywell 2018). Pepper sprays utilize the oil oleoresin capsicum (OC) which is composed of several different capsaicinoids; the percentage of capsaicinoids determines the potency of the spray. Civilian and law enforcement sprays contain a range from 0.18% to 1.33% of capsaicinoids while bear sprays range from 1.0% to 2.0% of capsaicinoids (SABRE 2021). Concentrations of propellant in a defense spray can range from 15% to 80% (Honeywell 2018). 3.2. Major Manufacturers Manufacturers of defense sprays available in the United States are listed in Table 1 by product type. Table 1. Manufacturers of Defense Sprays in the United States Manufacturer Type of Defense Spray Manufactured Mace Security International Pepper Spray Bear Spray Dog Spray SABRE (Security Equipment Corporation) Pepper Spray Bear Spray Dog Spray UDAP Industries Inc Pepper Spray Bear Spray Defense Technology3 Pepper Spray Fox Labs International Inc Pepper Spray Zarc International Inc Pepper Spray Aerko International Pepper Spray Counter Assault Pepper Spray Bear Spray Cutting Edge Products, Inc. Pepper Spray Guardian Protective Devices, Inc Pepper Spray a Defense Technology was previously a business segment of The Safariland Group. In June 2020, The Safariland Group entered into an agreement to divest Defense Technology (Safariland 2020). The testimony given to the Senate Environmental and Public Works Committee by The Safariland Group was given prior to their divestment from Defense Technology. 4. Subsector Background and HFC Use 4.1. Current Propellants in Defense Sprays Historically, defense sprays utilized CFC-12 propellant, which transitioned to HFC-134a in the mid-1990s. HFC-134a remains a common propellant for aerosol defense sprays to perform across a wide range of scenarios and environments (Safariland 2017a). Environmental characteristics of the current HFC propellant in defense sprays are summarized in Table 2. 2 ------- Table 2. Environmental Characteristics of Current HFC Propellant for Defense Sprays Propellant ODPa GWPa HFC-134a 0 1,430 Note: GWPs are aligned with the exchange values used in the AIM act. a Ozone Secretariat (1987). According to Safariland, of the aerosol propellants listed as acceptable alternatives under EPA's Significant New Alternatives Policy (SNAP) program, the only feasible replacement for HFC- 134a in a fog delivery system is HFO-1234ze. The flammable propellants listed (e.g., hydrocarbons) were not considered due to safety concerns, and the compressed gases were deemed unsuitable due to their inability to provide sufficient pressure and spray pattern. (Safariland 2017b). Defense spray manufacturers have been testing HFO-1234ze as a replacement for HFC-134a in defense sprays. The main concerns from the manufacturers were: Flammability: Initial formulations developed using the alternate propellants failed flame extension tests. Further testing demonstrated flammability of neat HFO-1234ze. This is a concern because of possible interactions with electrical discharge weapons which can lead to an increased risk to both the subject the spray is being used on and the officer if the spray ignites. This is also a concern in the bear spray market because many users work near oil and gas pipelines where flammability is a large concern (EPW 2020a, EPW 2020b). Lower Vapor Pressure: HFO-1234ze propellants have a significantly lower vapor pressure than HFC-134a, with HFC-134a having a vapor pressure of 666 kPa at 25°C and HFO-1234ze having a vapor pressure of 490 kPa at 25°C (DuPont 2004, Honeywell 2008). This results in decreased spray distance and volume, essentially reducing the effective range of the sprays. Testing has shown a 35% reduction in deployment distance when formulated with HFO-1234ze in place of HFC-134a (EPW 2020a, EPW 2020b). Formulation Stability: The solubility of the liquid formation with the propellant is key in being able to form an effective fog, foam, or vapor discharge. HFO-1234ze does not form a stable solution with the formulation ingredients, leading to ineffective discharge characteristics that affect the content, pattern, and discharge of the spray (EPW 2020a) Boiling Point: The boiling point of HFC-134a is -26.1 and -19°C for HFO-1234ze (DuPont 2004, Honeywell 2008). This allows HFC-134a sprays to operate at lower temperatures than HFO-1234ze sprays. Given the need for a great range of environments where defense sprays need to be able to be deployed, this is a limitation. (EPW 2020b). In 2019, Counter Assault marketed a new bear deterrent that uses a propellant other than HFC- 134a (Counter Assault 2018). The name of the propellant is not publicly available. Four bear sprays are currently EPA pesticide registered; this product along with another is labelled as flammable. 3 ------- Security Equipment Corporation, which manufactures defense sprays under the SABRE product line, estimates the defense spray industry uses approximately 125 MT of HFC-134a annually.1 The Safariland Group estimated an annual average of 58 MT of HFC usage per year and estimates that the industry as a whole uses 5-10 times the usage of Safariland Group, which would correspond to 290 to 580 MT of HFCs (EPW 2020c). For this analysis, it is assumed that the defense spray industry used 125 MT of HFC-134a in 2020. Security Equipment Corporation indicated that HFC-134a use in the defense spray industry grew at approximately 5% over the last five years (i.e., 2015-2020). Table 3, Figure 1, and Figure 2 show the estimated amount of HFC-134a propellant used in defense sprays in the United States from 2015 through 2020. Table 3. Historic HFC-134a Propellant Use in Defense Sprays in the United States (2015-2020) 2015 2016 2017 2018 2019 2020 Amount HFC-134a Used in Defense Sprays (MT) 98 103 108 113 119 125 Amount HFC-134a Used in Defense Sprays (MMT CQ2Eq.) 0.14 0.15 0.15 0.16 0.17 0.18 Source: EPW (2020c), EPA (2020). Figure 1. Historic HFC Propellant Use for Defense Sprays in the United States (2015-2020) (MT) Source: EPW (2020c), EPA (2020). 1 In EPW (2020c), Security Equipment Corporation also estimated the defense spray industry uses 0.0006% of the 230,000 MT annually produced and imported in the United States or approximately 1.38 MT of HFC-134a; however, based on the magnitude of other supporting information provided (i.e., Safariland estimated annual usage of 58 MT of HFC-134a), it was assumed that the total market more likely uses 125 MT of HFC-134a annually. 4 ------- Figure 2. Historic HFC Propellant Use for Defense Sprays in the United States (2015-2020) (Million Metric Tons CO2 Equivalent (MMT CO2 Eg.)) 0.2 cr " 0.15 O i- 2 2 V 0.1 (A 3 O U. I 0.05 n U 2015 2016 2017 2018 2019 2020 ¦ HFC-134a Source: EPW (2020c), EPA (2020). 4.2. Projected HFC Use in the Defense Spray Subsector Industry estimates that demand for HFC-134a in defense sprays will experience modest growth over the next 15 years. Specifically, law enforcement and military usage of products would remain relatively constant or experience modest increases in demand and the bear spray market would be expected to increase over time as populations continue to encroach on bear habitats, increasing the incidence of encounters with bears (EPW 2020c). HFC-134a use was therefore assumed to grow at an average rate of 2% from 2020 through 2030, in line with the growth rate of technical aerosols in EPA (2020) and 0.8% per year from 2030 through 2040 to align with expected population growth based on projections from the U.S. Census (U.S. Census 2017, EPA 2020). The projected HFC propellant sold in defense sprays can be found in Table 4, Figure 3, and Figure 4. Table 4. Projected HFC-134a Propellant Use in Defense Sprays in the United States (2020-2040) 2020 2025 2030 2035 2040 Amount HFC-134a Used in Defense Sprays (MT) 125 138 152 153 154 Amount HFC-134a Used in Defense Sprays (MMT C02Eg.) 0.18 0.20 0.22 0.22 0.22 Source: EPW (2020c), EPA (2020). 5 ------- Figure 3. Projected HFC Propellant Use for Defense Sprays in the United States (2020-2040) (MT) Sources: EPA 2020, EPW 2020c Figure 4. Projected HFC Propellant Use for Defense Sprays in the United States (2020-2040) (MMT C02 Eq.) Sources: EPA 2020, EPW 2020c 6 ------- 4.3. Imports and Exports of Defense Spray Products in the United States Information about the import and export market for defense spray products in the United States was not available. 7 ------- 5. References Counter Assault. 2018. New 40 Foot Bear Spray from Counter Assault. [Press release] October 15, 2018. Available online at: https://www.counterassault.com/wp- content/uploads/2018/10/Counter-Assault-40-Foot-Bear-Spray-Press-Release.pdf. DuPont. 2004. DuPont HFC-134a Properties, Uses Storage, and Handling. Available online at: https://resource.bakerdist.com/is/content/Watscocom/Gemaire/dupont- suva d10130577 article 1366804064196 en uci.pdf#:~:text=When%20HFC- 134a%20and%20CFC- 12%20are%20mixed%20in%20certain,%28109%20psia%29%20the%20azeotrope%20contains %2046%20wt%25%20HFC-134a. Honeywell International Inc. 2008. Honeywell HFO-1234ze Blowing Agent. Available online at: http://www51.honeywell.com/sm/lgwp-fr/common/documents/FP LGWP FR Honeywell-HFO- 1234ze Literature document.pdf. Honeywell International Inc. 2018. Propellant and Self-Protection Compositions. World intellectual Property Organization (WIPO) publication number WO 2018/023077 A1. Available online at: https://patentimaqes.storaqe.qooqleapis.com/96/77/99/ab0919c1cde4ad/WQ2018023077A1.pdf Ozone Secretariat. 1987. The Montreal Protocol on Substances that Deplete the Ozone Layer. United National Environment Programme (UNEP). Available Online at: https://ozone.unep.org/treaties/montreal-protocol. SABRE. 2021. Pepper spray frequently asked questions. Available Online at https://www.sabrered.com/pepper-sprav-frequentlv-asked-questions-Q. Accessed January 15, 2021 Safariland. 2017a. Petition to Add Use Condition on Acceptability Listing for HFC-134a. Submitted to EPA July 3, 2017. Safariland. 2017b. Response to Additional Questions Regarding Safariland Petition. Submitted to EPA October 25, 2017. Safariland. 2020. The Safariland Group to Divest Defense Technology. June 9, 2020. Available Online at: https://inside.safariland.com/news/safariland-qroup-divest-defense-technoloqy/. Senate Environmental and Public Works Committee. 2020a S.2754, American Innovation and Manufacturing Act of 2019 Senate Testimony for The Safariland Group. Available online at: https://www.epw.senate.gov/public/ cache/files/7/5/75b02089-ac1c-4438-96a3- 98944d31c5ca/9ED178F833654134BCADB8C3183D783F.04.08.2020-safariland.pdf. Senate Environmental and Public Works Committee. 2020b S.2754, American Innovation and Manufacturing Act of 2019 Senate Testimony for Security Equipment Corporation. Available online at: https://www.epw.senate.gov/public/ cache/files/d/e/de21a266-3c5b-4e59-9223- 536fba2b9750/CD28EDEAB2F209EE2BC30764F667DD23.03.25.2020-sabre.pdf. 8 ------- Senate Environmental and Public Works Committee. 2020c. S. 2754, American Innovation and Manufacturing Act of 2019: Written Testimony and Questions for the Record. Available Online at: https://www.epw.senate.gov/public/ cache/files/6/6/66c5854f-72f6-42c0-9110- 924b251f0f2b/97F5EBC37BA4148AB9B9E1B79B72C946.all-hfc-gfr-responses-03.25.2020.pdf. U.S. Census. 2017. 2017 National Population Projections Tables: Main Series. Available online at: https://www.census.gov/data/tables/2017/demo/popproi/2017-summary-tables.html. U.S. Environmental Protection Agency (EPA). 2020. Vintaging Model. Version VM IO file v5.1 10.08.20. 9 ------- |