U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Atmospheric Programs
Washington, DC 20460
THE SIGNIFICANT NEW ALTERNATIVES POLICY (SNAP) PROGRAM
INFORMATION NOTICE INSTRUCTION MANUAL
EPA Form No. 1264-14 (Rev. July 2020)
The U.S. Environmental Protection Agency (EPA) has prepared this instruction manual to help you in
submitting information on alternatives to the Significant New Alternatives Policy (SNAP) program. This
manual provides instructions on submitting the SNAP Information Notice form, asserting confidentiality
claims, and submitting test data and optional information. However, please note that in the event of any
discrepancies between this document and the Code of Federal Regulations (CFR), the CFR requirements
are legally binding and take precedence.
This revised form has been updated to clarify the information requested by EPA. In addition, a response
checker has been added that, in the Excel version of the form, can identify questions that are missing
responses. Also, for those submitting an alternative that contains one or more chemicals that the SNAP
program has not listed, the form now includes a new Part XII with lists of recommended toxicological
studies to include with your submission.
Part I: Introduction and Confidentiality Claims
Section A: Introduction
All submitters must complete all of Part I: Introduction and CBI, Part II: Contact Information, Part III:
General Information, Part XIV: Attachments, and Part XV: Certification. If you are submitting an
alternative that contains one or more chemicals that the SNAP program has not listed, you must also
complete Part XII: Toxicology Studies. For each sector for which the alternative is being submitted,
submitters must also complete the corresponding sector-specific data requirements found in Parts
IV to XI, outlined below for your submission to be accepted for review under SNAP.
• Part IV: Refrigeration and Air Conditioning
• Part V: Foam Blowing
• Part VI: Cleaning Solvents
• Part VII: Fire Suppression
• Part VIII: Aerosols
• Part IX: Sterilants
• Part X: Adhesives, Coatings, and Inks
• Part XI: Tobacco Expansion
Enter any additional information in Part XIII. Before submitting the Notice form, you may review the
completeness of the form using the Response Checker, which can be found prior to Part XV:
Certification.
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Please select the appropriate box on the Introduction and CBI tab indicating the type of submission:
new alternative not previously listed under SNAP or new end-use or application of substitute currently
listed under SNAP.
Section B: Identification of Alternatives
Please identify the name of the alternative, as well as the sector(s), end-use(s), and application(s) (if
applicable) for which the form is being submitted in Part I, Section B. Sectors, end-uses, and
applications are defined in Parts IV through XI.
Section C: Confidentiality Claims
If you submit information for which you would like to request Clean Air Act (CAA) Confidential
Business Information (CBI) status, you must make a claim of confidentiality at the time of submission
and substantiate that claim.
EPA will treat all claims of confidentiality consistent with 40 CFR Part 2, Subpart B. To claim information
as CBI, bracket the specific information you claim as confidential and mark the confidential box in the
column on the right-side of the page in the corresponding row.
To ensure that no confidential information is disclosed to the public, you must submit an additional
copy of the notice form, including attachments, which does not contain confidential information. This
version ("sanitized," "redacted") will be placed in the public docket. It must contain all non-confidential
information. To assert confidentiality claims for information in attachments to the form, provide a
complete copy of the attachment that clearly indicates (e.g., by circling or bracketing) the information
you wish to claim as confidential. Bracket only the specific information you claim as confidential.
Provide a Statement of Data Confidentiality Claims in Part I, Section C based on the instructions provided
in the form. Provide the following information:
1. Please provide the reasons why the cited passages qualify for confidential treatment.
2. If you assert that disclosure of this information would be likely to result in substantial harmful
effects to you, describe those harmful effects and explain why they should be viewed as
substantial.
3. Indicate the length of time - until a specific date or event, or permanently - for which the
information should be treated as confidential.
4. Identify the measures you have taken to guard against undesired disclosure of this information.
5. Describe the extent to which the information has been disclosed, and what precautions have
been taken in connection with these disclosures.
6. Please provide copies of any determinations of confidentiality previously made by EPA, other
Federal agencies, or courts concerning this information.
EPA requires substantiation of all CBI claims under SNAP or a submission will be considered incomplete.
Part II: Contact Information
Section A: Submitter Contact Information
All contacts listed in Part II will be granted access to CBI, unless otherwise noted and substantiated in
Part I, Section C.
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1. Person Submitting Notice - Enter information for the primary submitter ofthe notice. The
person submitting the notice form must sign the certification in Part XV-Certification.
2. Agent - Complete only if you authorize an agent to assist you in preparing this notice. The agent
must also sign the certification in Part XV: Certification.
3. Technical Contact - Identify a person who can provide EPA with additional technical information
on the substitute during the review period if that contact is different than the "Person
Submitting Notice" and the "Agent." The technical contact identified should be located within
the U.S. and be available to be reached by telephone during normal business hours.
4. Joint Submitter - Identify the joint submitter, if any, who is authorized by the primary submitter
to provide some ofthe information required in the submission form. A submission will not be
considered complete until EPA receives all information.
If you have a Joint Submitter who is authorized to provide information directly to EPA (e.g., a
foreign manufacturer or supplier), indicate which information will be supplied by the other
person in Part XIII: Additional Information. A letter in support of your submission should be
provided by the Joint Submitter on their company letterhead. An example of where this could
apply would be in situations where alternative formulation information is held confidentially by
a foreign manufacturer. A submission will be considered incomplete until this information is
provided. Whenever possible, use the same name for the alternative (e.g., generic name) to link
this information to your submission.
Part III: General Information
Section A: Alternative-Specific Information
EPA must receive a complete and unambiguous identification of the new substitute. If the alternative is
not adequately identified, we will consider the submission incomplete. If you are an importer of an
alternative and do not know the chemical identity of a substitute because it is confidential, you must
contact the manufacturer or supplier and have the specific chemical identity provided directly to EPA. In
this way, manufacturers can protect confidential business information. This information may be
provided in a letter on company letterhead from the supplier.
1. Identify Proposed Substitute - (a-d) Enter the specific name of the chemical substance, the
percent ofthe composition, the Chemical Abstracts Service (CAS) registry number, and the
molecular formula of the alternative. In describing chemical substances, EPA prefers that
International Union of Pure and Applied Chemistry (IUPAC) nomenclature be used for
identification purposes. If the substitute is a blend of chemicals, you must provide the exact
composition and/or the range of percent composition of all components of the blend. In
addition to active ingredients, you must also list other chemical substances in blends, such as
solvents, inhibitors, etc., that may also be present in the alternative. If your substitute is a
technology or process change, rather than a chemical substitute, then provide the name of the
alternative technology or process in (a) and proceed to (e).
(e) For alternative technologies and/or processes, provide a detailed description and diagram of
the technology or process and information on any chemical constituents.
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(f) If you have applied for or hold a U.S. patent on the substitute, provide the patent name,
number (if available), and information on topics covered in the patent. It is not necessary to
provide the patent.
2. Commercial/Trade name(s) of alternative - Indicate the name(s) under which the alternative
would be marketed.
3. Generic name - If the identity of a substitute and the commercial/trade name are claimed as
confidential, provide a generic name that is specific enough to identify the substance uniquely.
The generic name may be published in the Federal Register document announcing EPA's
acceptability determination of your alternative. If the name seems more generic than
necessary, EPA will contact you and assist you in developing an adequate name.
The generic name should provide sufficient information for the public by indicating the classes
of chemicals which the alternative contains without revealing specific information about the
product's composition. For example, it may be necessary to reveal that a refrigerant blend
contains an HCFC in order to allow users or importers to comply with regulations issued under
sections 604, 605 or 608 of the CAA.
4. Impurities - (a-d) Identify by name, weight percent, CAS Registry number (where available), and
molecular formula each impurity that you reasonably anticipate will be present in the
alternative as manufactured for commercial purposes. An impurity is any chemical substance
that is unintentionally present in the alternative. List all impurities, regardless of weight
percent. If the substance contains some unidentified impurities, also enter "unidentified". Do
not include substances that are mixed with the new substance after manufacture of the primary
ingredients. If there are no impurities, enter "None." For alternative technologies and/or
processes, mark "N/A" in (a) and proceed to 6.
5. Byproducts- (a-e) Identify any byproducts that you reasonably anticipate will result from the
manufacture or processing of the alternative both at sites you control and in end-use. Identify
these byproducts by specific name or class or range of structures (e.g., HF or other acid gases
formed during the production of halocarbon compounds via dehalogenation, HFC-143a and/or
HCFC-124 formed during the production of HFC-134a), CAS Registry number (where available),
when the byproduct is formed (e.g., during manufacture), and the estimated amount formed
(grams) relative to the amount of proposed substitute manufactured.
6. Degradation Products- (a-e) Identify any degradation products that you reasonably anticipate
will result from the use or disposalcfthe alternative both at sites you control and in end-use.
Identify these degradation products by specific name or class or range of structures (e.g., HF
or other acid gases formed from the combustion of halocarbon compounds), CAS Registry
number (where available), when the degradation product is formed (e.g., during end-use, in
the event of a fire, following disposal), and the rate of formation (grams/second).
7. Test Marketing - Indicate if a test marketing notification was previously submitted to EPA.
8. Physical and Chemical Properties - (a-l) Provide the following physical and chemical properties
for chemical alternatives: molecular weight, physical state, melting point, boiling point, specific
gravity, bubble point (for blends), and dew point (for blends). If the alternative is flammable,
provide the lower flammability limit, upper flammability limit, and flash point. The properties
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included in this section are illustrative and are not an exhaustive list of potential data. The
physical characteristics requested in this section apply to all sectors; Parts IV through XI request
additional sector-specific physical and chemical properties. For alternative technologies and/or
processes, mark "N/A" in (a) and proceed to 12.
(m) If you are extracting this information from a public reference source (e.g., CRC Handbook
of Chemistry and Physics, Merck Index), please provide copies of the references. If references
include copyrighted materials, mark as CBI.
(n) If you have performed chemical analysis and testing on the substitute (e.g., fractionation
testing, ASTM E681 for flammability limits in air) to derive the properties, attach copies of all
test reports and specify the protocol used.
9. Ozone depletion potential (ODP) - (a) Provide information on the predicted 100-year ODP of
the alternative relative to CFC-11. If the substitute is a blend, provide the ODPs of the individual
constituents. You should also provide supporting documentation indicating how and by whom
this value was calculated.
For purposes of calculating ODP, EPA recommends the methodology used in the Scientific
Assessment of Ozone Depletion prepared for the United Nations Environment Programme
(UNEP) by the World Meteorological Organization (WMO). The ODP refers to the amount of
ozone destroyed by a gas over its entire atmospheric lifetime (e.g., at a steady state) relative
to that due to emissions of the same mass of CFC-11. It is defined in modeling calculations as
follows:
Global AOo caused by x
ODPx =
Global A03 caused by CFC — 11
Calculations should reflect ground level emissions. For aircraft applications, be sure to also
include the ODP of emissions of the substitute at cruising altitude.
(b-c) You should also include any other related data available to you, such as information on the
substitute's chlorine or bromine loading potential. See the 2018 WMO Scientific Assessment of
Ozone Depletion for additional information on calculating ODP and related information.
10. Global Warming Characteristics - (a-b) Provide information on the 100-year global warming
potentials (GWPs) of the proposed substitute relative to C02, as well as atmospheric lifetime
(ATL) of the proposed substitute. If the substitute is a blend, provide the GWPs of the individual
constituents and an estimate of the blend at its nominal composition.
Provide GWPs as listed in the 2007 Intergovernmental Panel for Climate Change Fourth
Assessment Report (IPCC AR4). Alternate sources may include the 2018 WMO Scientific
Assessment of Ozone Depletion or the peer-reviewed literature. IPCC defines GWP of the
emissions of a greenhouse gas as the time integrated commitment to climate forcing from the
instantaneous release of 1 kg of a trace gas expresses relative to that from 1 kg of C02.
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GWP =
J0 aicidt
Jo aco2cco2dt
Where:
a, = the instantaneous radiative forcing due to a unit increase in the concentration of trace gas,
i c, = the concentration of trace gas, i, remaining at time, t, after its release, and
n = the number of years over which the calculation is performed.
Corresponding values for C02 are in the denominator.
For GWP values that do not come from IPCC AR4 or WMO 2018, you should also include the
data used to calculate these potentials such as atmospheric lifetime, infrared adsorption
spectrum, and infrared absorption capacity. Provide all supporting documentation.
(c) If the alternative is captured as a byproduct of another manufacturing or industrial process,
indicate the source of the alternative. This information is important in assessing the effects of
the new use of the substitute versus those effects occurring strictly because of the release of a
byproduct.
11. VOC Status Information - (a-d) Indicate whether the alternative is considered to be a volatile
organic compound (VOC) and is subject to regulation under Title I of the CAA (40 CFR 51.100(s))
or exempt as a VOC, due to low photochemical reactivity. If a petition for VOC exemption has
been submitted to EPA under Title I, please provide information on that submission and the
current status of that request and provide the information on reactivity below in (d). For
compounds that are not VOC exempt, provide information on the reactivity of the compound in
the atmosphere, such as the maximum incremental reactivity (MIR) in grams of 03 (ozone) per
gram of VOC and the kOH (298 K) value. Include the reference for each reported value.
12. Cost of Proposed Substitute - Estimate the cost of the chemical substitute. Information on costs
of the alternative for a specific use is requested in Parts IV through XI. Specify the units used.
13. Toxicity Limits (a-d) - For the proposed substitute (and constituents if the proposed substitute
is a blend), impurities, and/or byproducts, provide all available concentration-based exposure
limits that have been set, such as Permissible Exposure Limits (PELs), occupational exposure
limits including Short-Term Exposure Limits (STELs), Threshold Limit Values (TLVs),
Recommended Exposure Limits (RELs), or Workplace Environmental Exposure Limits (WEELs), or
acceptable exposure limits (AELs) set by the manufacturer. Submit any supporting
documentation, including public literature and information previously submitted to the SNAP
program for a differentsubmission. If the submission includes one or more chemicals that the
SNAP program has not listed, please reference Part XII Recommended Toxicity Studies in this
SNAP Information Notice to see a list of toxicological studies, for each sector, that are
recommended for a critical toxicity review of chemicals submitted to the SNAP program.
(e) If available, summarize the acute and chronic toxicity of the proposed substitute and of its
constituent chemicals on any organism (e.g. human and/or other mammals, fish, wildlife, and
plants). Attach all complete test reports that are reasonably available to you.
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(f) If the proposed substitute is a blend, indicate if the acute and chronic toxicity of the
proposed substitute has been evaluated on a blend basis.
(g) If the proposed substitute is a blend and the acute and chronic toxicity of the proposed
substitute has not been evaluated on a blend basis (and therefore, only on a component basis),
please explain why and provide supporting documentation as applicable.
14. Safety Documents - Please attach a copy of any hazard warning statement, warning labels,
safety data sheet (SDS), or other information which will be provided to any person who is
reasonably likely to be exposed.
15. Environmental Regulations - List any environmental statute (such as those included in the
form) applicable to the manufacture, use, and disposal of the proposed substitute. Provide
citations for implementing regulations and a brief explanation of the nature of the regulatory
requirement (for example, 40 CFR part 63 subpart T, National Emission Standards for Hazardous
Air Pollutants for Halogenated Solvent Cleaning).
16. Health and Safety Regulations - Describe whether and how occupational, consumer, or general
population exposure to the proposed substitute is regulated under health and safety related
statutory authorities, such as those listed in the form. Provide regulatory citations where
available, e.g., 29 CFR 1910.132.
Parts IV to XI: Sector-Specific Information
Due to the unique uses and exposures of alternatives for each of the SNAP industrial sectors, the
submission form includes individual tabs for each sector. You are only required to complete those
sections for which you are submitting to SNAP. Below are instructions for Parts IV-X. Instructions are
organized by Section, beginning with instructions for the common elements. Instructions for questions
that are unique to a specific sector, are noted below the common elements or within the instructions for
each Section.
If you are submitting the substitute for several end-uses or applications, you must provide the
requested information for each. Part XI: Tobacco Expansion does not require the submission of any
additional data; therefore, no instructions are provided. For an explanation of each end-use and
application visit the SNAP website: https://www.epa.gov/snap/snap-substitutes-sector.
Information claimed as confidential should be placed in [brackets] and marked as CBI. If information is
claimed as CBI, then a public version must be submitted with the bracketed information redacted or
removed.
Section A: Use Profile
• Specific End-use - Identify the specific end-uses and applications (if applicable) within the sector
in which the alternative is to be used. Specify the ozone-depleting substance (ODS) (and/or other
alternatives) used in the end-use and/or application, and include an estimate of the quantity of
alternative (lb) needed to replace the ODS (and/or other substance) for each end-use. This is
known as the replacement ratio. For example, if 100 lb of a new refrigerant will replace 150 lb of
CFC-12, the replacement ratio is 1:1.5.
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• Additional End-Use Description - Provide a written description of the specific uses for which you
are submitting.
• Technology Changes and Cost - Describe any new equipment technology changes and
associated costs that will be necessary in order to use the proposed substitute.
• Production - Provide estimated information on production of the proposed substitute or
equipment using the proposed substitute. Indicate when you anticipate the substitute or new
equipment using the substitute will enter the marketplace. Include the value for total production
anticipated during the first year of production in kg. If you are submitting the substitute for several
end-uses, you must provide this information for each end-use.
• Market Share - Provide information on the levels of market penetration that you expect for the
substitute or new use of an existing substitute. Include estimates for the number of years you
anticipate until the substitute reaches its maximum market penetration for those uses included in
submission, and the total production level that you anticipate for the substitute when it reaches the
point of market saturation. Finally, if possible, estimate the percentage of the market held by the
substance(s) being replaced that will be captured by this substitute at the maximum market
penetration. If you are submitting the substitute for several end-uses, you must provide this
information for each end-use.
• Application of Proposed Substitute - Provide information requested in each sector-specific section
on the specific application of the substitute. These questions are related to both manufacturing and
use.
• Consumer Use - Where requested, indicate whether the proposed substitute will be used for
consumer use. If consumer use is expected, pleasedescribe the anticipated consumer applications.
• End-Use Specific Standards - List any standard-setting organizations that will evaluate the
proposed substitute or will set requirements or guidelines for the substitute from a health and
safety perspective in the proposed end-use(s). Examples include Underwriters Laboratories (UL),
the American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE), the
Society of Automotive Engineers (SAE), the National Fire Protection Association (NFPA), or the
International Organization for Standardization (ISO).
Refrigeration and Air Conditioning
• Energy Efficiency - Provide the alternative's impact on energy efficiency relative to the substance it
is replacing for each end-use. Attach and describe the results of any energy efficiency testing or
modeling performed. Laboratory testing of equipment should evaluate the proposed substitute vs.
the substance(s) being replaced. Values should be given as a percent difference relative to the
substance(s) being replaced or a similar measure. Also address refrigerant/oil solubility. Computer
models should account for compressor efficiency, refrigerant transport properties, and mass flow
rates for given tubing geometry, capillary tube/suction line heat transfer, and liquid and vapor
specific heats.
• Refrigerant Oil - Provide information on the chemical class of refrigerant oil you anticipate will be
used (e.g., polyalkylene glycol, polyolester, mineral oil) and information on the refrigerant/oil
solubility.
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Foam Blowing
• Energy Efficiency - Provide the alternative's impact on energy efficiency relative to the substance(s)
it is replacing for each end-use. Attach and describe the results of any energy efficiency testing or
modeling performed. Laboratory testing of equipment should evaluate the proposed substitute vs.
the substance(s) being replaced. Values should be given as a percent difference relative to the
substance(s) being replaced or a similar measure.
Cleaning Solvents
• Compatibility - Provide information on the compatibility of the solvent with metals and plastics
with regards to its use as a cleaning solvent (e.g., is the solvent corrosive to some materials).
Fire Suppression
• Weight and volume equivalence replacement ratio (c): To respond to Section A, Number 1(c),
use the following information for determining weight and volume equivalence:
Weight and volume equivalents are calculated using a single, fuel-specific design concentration
(heptane); therefore, they do not represent the exact weight or volume of the agent needed to
protect any specific space against any specific hazard. The information used to calculate the
equivalents is provided from agent manufacturers and NFPA 2001, "Standard for Clean Agent Fire
Extinguishing Systems." Equivalents are included in SNAP rulemakings for general comparison and
informational purposes only.
EPA understands that fire suppression agents must be evaluated in the context of the fire
extinguishing system equipment with which they are used. Design concentration, and weight and
volume equivalents are only meaningful when evaluated in specific system hardware
configurations. This is especially important when comparing storage volume where storage
container fill density varies with the equipment used. Agent fire suppression performance will
vary with the system used and the detailed design of the system. Therefore, fire suppression
agent manufacturers do not generally recommend design concentrations as these are also a
function of the system hardware in which they are used. Hence, these data are provided for
general guidance only and do not reflect a recommendation for system design or a basis for
rigorous quantitative comparison.
(1) Weight and volume equivalent data should be presented relative to Halon 1301 at 120 per
cent of cup burner as well as at 5 percent, a typical use concentration;
(2) Weight and volume equivalents should be based on agent concentrations at standard
temperature and pressure;
(3) Weight and volume equivalents should be done at both the manufacturer's recommended
design concentration and at 120 per cent of the cup burner value where the values are notthe
same;
(4) Volume equivalents will be based on agent volume only (exclusive of container volume, fill
density, etc.) at 70 degrees Fahrenheit and the storage pressure specified by the manufacturer
since this varies widely and the required agent mass determined in item (5) below; and
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(5) The required agent weight equivalents should be determined by the following equation:
V ( C \
W = -
SV100-C7
Where:
W = weight of clean agent (lb),
C = design concentration (% volume),
V = one cubic foot, and
S = agent specific vapor volume at 70 degrees F (ft3/lb).
(6) Appropriate references to the technical literature on which the data are based should be
provided.
(d) Indicate the type (i.e., occupied or unoccupied) and purpose (e.g., engine room, machinery
space, cargo room) of space in which the extinguisher will be used.
Section B: Physical and Chemical Properties
• Physical and Chemical Properties - Include data on the physical or chemical properties of
the alternative that are relevant to evaluating the proposed substitute in a specific sector.
The properties included in each section are illustrative and are not an exhaustive list of
potential data.
Refrigeration and Air Conditioning
• ASHRAE Designation - Please identify whether the proposed substitute has been submittedto
and/or published by the ASHRAE Standing Standard Project Committee 34 (SSPC 34). If it has
been published, specify the ASHRAE designation and classification.
Foam Blowing
• Manufacture and Degradation Products - Provide a study on the catalyst used in the
manufacture of the foam blowing agent and the degradation products under different external
conditions (e.g., temperature) during use to assess potential hazards of breakdown/degradation
products of foam during use.
Fire Suppression
• Degradation Products - Provide information on the degradation products of the alternative
following discharge in a fire situation. Explain the conditions used in determining these products
(e.g., flame temperature, time required to extinguish the fire, amount of O2 present,
combustible material).
Section C: Flammability (Required for Refrigeration and Air Conditioning; Foam Blowing;
Cleaning Solvents; Aerosols; Sterilants; and Adhesives, Coatings, and Inks Sectors)
• Flammability-Related Physical and Chemical Properties - Provide information on the
physical and chemical properties relevant to evaluating the flammability of the proposed
substitute.
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Flammability Assessments and Test Data - For flammable substitutes, please include as an
attachment the results of ASTM E681 Flammability Limits in Air. The numerical values for the
upper and lower flammability limits are requested in Part III.
For flammable refrigerants, please provide information on the maximum pressure of
combustion, the maximum rate of pressure increase during combustion, and the minimum
ignition energy. If you have conducted any analyses on flammability, please provide them.
For refrigeration and air conditioning, if an alternative is flammable (this applies to both blends
and neat chemicals), you must analyze the risk of fire resulting from the use of the substitute in
each proposed end-use/application through a risk assessment. For refrigeration and air
conditioning, a Fault Tree Analysis (FTA) or Failure Mode and Effects Analysis (FMEA) is also
required. An FTA should include, but not be limited to, a description of typical scenarios in which
the substitute is used, potential leak scenarios, sources of ignition, and quantified probabilities
of ignition. It should also assess the likelihood of injury within each scenario. An FMEA should
describe identified failures that could result in a spark, flame, explosion, or other fire risk and
mitigation measure for each failure mode. Significant differences exist both in the design and in
the ambient conditions for various end-uses. Thus, risk assessments are extremely sensitive to
end-use. Low risk in one end-use does not, in general, imply low risk in another end-use.
For refrigerant blends that contain one or more flammable components, provide information on
fractionation during leakage, including flammability test results on the worst-case formulation
and the worst-case fractionation formulation for the blend.
• Flammability Concerns and Mitigation - Provide all test data regarding flammability of the
substitute, including the procedures used for determining flammability and any other
information on flammability concerns. If a substitute is flammable under the conditions
expected in the proposed end-use/application, describe any abatement techniques being used
to minimize the risks associated with use of a flammable substance (e.g., equipment design
modifications or alternate labeling).
For flammable foam blowing agents used in spray foam, provide a training program that
addresses flammability concerns specific to the substitute. For foam blowing agent blends that
contain one or more flammable components, provide information on the range of composition
that would render the blend nonflammable (for example, using at least 5% of the nonflammable
component in the blend is expected to make the blend nonflammable).
Section C: Fire Suppression Agent Toxicity and Hazard Information (Required for
Fire Suppression Only)
• Inhalation Toxicity Studies - Provide an inhalation toxicity study if workers are exposed tothe
chemicals during manufacture or long-term exposure levels have not been determined by
Occupational Safety and Health Administration (OSHA), National Institute for Occupational
Safety and Health (NIOSH), American Conference of Industrial Hygienists (ACGIH), or
American Industrial Hygiene Association (AIHA).
• Genotoxicity Studies - Provide genotoxicity studies (e.g., Ames assays, forward mutation
assays, cytogenetic assays) to determine the potential for the agent to induce DNA damage.
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• In-kind Halon Alternatives (Gaseous Halocarbons) - Provide the extinguishing concentration
and design concentration. Provide a cardiac sensitization study and acute, sub-acute, and
subchronic toxicity inhalation studies with rats for halocarbon steaming agents or flooding
agents used in occupied spaces.
• In-kind Halon Alternatives (Non-Halocarbon Gaseous) - Provide the extinguishing
concentration and design concentration.
• Not-in-kind Halon Alternatives (Powdered Aerosols or Foam) - Provide the extinguishing
application density and design application density. For foam streaming agents, provide an
acute toxicity inhalation study and an ocular irritation study (Draize test). For powdered
aerosol flooding agents proposed for use in occupied spaces, provide a static acute toxicity
inhalation study with rats at the design application density. For any powdered aerosol fire
suppression agent used in occupied spaces, provide a dermal irritation study.
• Powdered Aerosol Flooding Agents Used in Occupied Spaces (a-j) - The use of powdered
aerosol flooding agents in occupied spaces requires special considerations of the physical
properties and toxicity of the agent and visibility in the protected space. Identify the likelihood
that the fire extinguisher will accidentally discharge (reported as the number of accidental
discharges in 1 million); the number of extinguishing devices (i.e., generators) installed in a room
and the location of these devices within the space; the discharge rate (g/s) of the fire
extinguishing device; the length of time it takes for the particles to become distributed
throughout the space and the particle size distribution over time; the mass median aerodynamic
diameter (MMAD) (nm) and concentration (mg/m3) of the effluent released from the nozzle; the
settling rate of the particles; the maximum egress time for personnel from the space and several
approaches to facilitate safe egress (e.g., training, installation guidelines); and the composition
of flooding agent before and after discharge (including the amounts and weight percentages of
all effluent gases and particulates that may not be filtered).
Section D: Exposure
Provide the information requested within the Information Notice form related to potential exposure
scenarios. This section requires information on typical and maximum potential exposure scenarios
during manufacturing, use, and disposal. If provided exposures are based on proxy compounds or
blends, please identify the proxy compound or blend and explain why they are appropriate for
comparison to the proposed substitute. If the substitute and equipment using the substitute are
manufactured outside of the United States, information on exposure during manufacturing is not
required. However, if the information is readily available, please submit it.
Examples of the type of information required to be submitted are provided within the form.
• Exposure Media and Release Information: Provide the requested information regarding the
media(s) to which the proposed substitute could be released (e.g., indoor air, outdoor air, water,
land), potential contact pathways, and engineering controls and protective equipment to reduce
or prevent releases or exposures.
• Potential Exposure Activities: Identify the activities during manufacture, use, servicing and
disposal during which the potential for exposure is highest. Provide information on typical and
maximum potential exposure concentrations during these activities.
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• Training Materials: Provide information on training materials related to manufacture,
installation and servicing, and disposal. If the proposed substitute is flammable, describe how
these guidelines differ from training for non-flammable substances.
Refrigeration and Air Conditioning
• Information on Recovery Practices: Section 608 of the Clean Air Act prohibits the intentional
release (venting) of ozone-depleting refrigerants and their substitutes while maintaining,
servicing, repairing, or disposing of air conditioning or refrigeration equipment unless
exempted by EPA. Please provide information on how the substitute will be recovered.
Foam Blowing
• Maximum Annual Emissions Rate: For each end-use, provide maximum annual emission rates
for blowing agent leaks from foam application during the foam's lifetime (i.e., after
manufacturing and before disposal) as a percentage of the original total amount of blowing
agent used to produce the foam. Please also specify the anticipated number of years for which
the blowing agent would be leaking from the foam (i.e., the emissive lifetime). For reference,
the following are annual emission rates that EPA uses as defaults.
o Polyurethane (PU) and Polyisocyanurate Rigid Boardstock: 1%
o PU Rigid Appliance Foam: 0.25%
o Rigid PU Spray Foam: 1.5%
o Commercial Refrigeration Foam: 0.25%
o PU Rigid Slabstock: 0.875%
o PU Integral Skin Foam: 2.5%
o PU Rigid: Sandwich Panels: Continuous and Discontinuous: 0.5%
o XPS: Sheet Foam: 25%
o XPS Boardstock Foam: 0.75%
o Polyolefin Foam: 2.5%
o Phenolic Foam: 0.875%
Section E: Additional Information for Submission of Requirements for Blends of Foam Blowing
Agents (Foam Blowing Only)
For the following end-uses, a submission is required for blends of blowing agents, including blends with
blowing agents that are already listed as acceptable:
• Polyolefin
• Polystyrene: Extruded Boardstock and Billet
• Rigid Polyurethane and Polyisocyanurate Laminated Boardstock
• Rigid Polyurethane: Spray Foam*
• Phenolic Insulation Board and Bunstock
*For spray foam, if any components of the blend are flammable, then an additional submission
is required for the blend.
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For the following end-uses, it is permissible to blend blowing agents that are already listed as acceptable
without an additional submission for the blend:
• Rigid Polyurethane: Appliance
• Rigid Polyurethane: Commercial Refrigeration
• Rigid Polyurethane: Sandwich Panels
• Rigid Polyurethane: Spray Foam*
• Rigid Polyurethane: Slabstock and Other
• Flexible Polyurethane
• Integral Skin Polyurethane
• Polystyrene: Extruded Sheet
*For spray foam, if all components of the blend are acceptable and non-flammable, then it is
permissible to blend those blowing agents without an additional submission for the blend.
Part XII: Toxicology Studies
Provide any available toxicology studies related to the end-use/application of the proposed substitute.
This section of the form should be used as guidance on recommended studies for each sector:
• Refrigeration and Air Conditioning
• Foam Blowing; Aerosols; Solvents; Adhesives, Coatings, and Inks; Sterilants
• Fire Suppression
"Required" studies are required in order for your submission to be complete and in order for EPA to
review your substitute. "Needed for complete database" are studies that provide EPA with information
allowing them to use less conservative assumptions when assessing toxicity of the substitute. "Useful
but not always required" studies will give EPA the most complete understanding of the substitute's
toxicity; if you have this information available, please include it in your submission.
Part XIII: Additional Information
Provide any additional information that may assist EPA's review. Submitters are not required to include
information in this section.
Part XIV: Attachments
Clearly identify all attachments being provided in support of the submission.
Mark (X) in the CBI box next to any attachment that you claim as confidential. The public version of the
submission form must include the attachment name/citation at a minimum. All claims of confidentiality
must be substantiated in Part I.
Response Checker
The Response Checker identifies questions in the Notice form that are missing responses. Please review
the questions that are missing responses carefully to ensure that all required information is provided
before submitting the Notice form to EPA. Please note that this checker is not an indicator of whether
EPA will consider the submission complete, but rather, this checker is an indicator of whether all
questions have been answered.
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Part XV: Certification
The individual identified in Part I of the form as the person submitting the Information Notice must sign
the certification in Part XIV of the form. This official is responsible for the truth and accuracy of each
statement in the certification. If an agent assists you in preparing the submission, the agent must also
sign the certification.
A printed copy of the certification page, with original signature, must be submitted with electronic or
paper submissions. If the submission is not signed. EPA will consider the submission incomplete and will
not review the substitute.
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