FM Magazine spoke to Bill Polits, Director of Sales & Strategy at refrigerant supplier A-Gas, about the regulation of hydrofluorocarbons used in fire prevention under the American Innovation and Manufacturing (AIM) Act.
The American Innovation and Manufacturing (AIM) Act of 2020 has been incorporated into the (inventively named) Innovation for the Environment, of the Consolidated Appropriations Act, 2021 (H.R. 133 (116th): Consolidated Appropriations Act of 2021, which authorizes a phased approach to reducing industrial dependency on hydrofluorocarbons (HFCs) by the Environmental Protection Agency (EPA.
Under the first stage of the weaning process, EPA is currently phasing down production and consumption of listed HFCs - a process that will be followed by stage two (with a focus on managing HFCs) before the final stage facilitates the transition to 'next-generation technologies' by imposing sector-specific restrictions.
Phasedown-promoting regulations are now in place across most of the developed world. The developing world is planned to follow suit in 2029.
HFCs are used widely in fire suppressant applications, and Bill Polits from A-Gas had much to say about the EPA's approach.
Can you explain the context and goals of the AIM Act 2020?
Due to their molecular properties — the source of hydrofluorocarbon (HFC) fire suppressant gases’ abilities to transfer heat away from fires to cause extinguishment — HFCs are extremely effective in trapping the infrared radiation rising from the earth’s surface after being heated by the sun.
As such, they can be a huge and growing source of atmospheric warming if not managed responsibly.
HFC fire suppressants are among the most powerful global warming substances we know of.
Due to their molecular properties — the source of hydrofluorocarbon (HFC) fire suppressant gases’ abilities to transfer heat away from fires to cause extinguishment — HFCs are extremely effective in trapping the infrared radiation rising from the earth’s surface after being heated by the sun.
As such, they can be a huge and growing source of atmospheric warming if not managed responsibly.
HFC fire suppressants are among the most powerful global warming substances we know of.
Demand for refrigeration and air conditioning has grown across the globe, both in the developed world and in the developing world.
HFC-based refrigerants supply the bulk of the markets.
Due to the climate impacts of HFC use and production, the HFC industry has known that global HFC regulations are needed.
After failed efforts in other arenas, in 2016, the Parties to the Montreal Protocol approved the Kigali Amendment, which mandates signatories to follow a 15-year HFC phasedown on a 2-track system: one for developed and another for developing countries.
The AIM Act is the US legislative response to the Kigali Amendment requirements.
Phasedown-promoting regulations are now in place across most of the developed world.
The developing world is planned to follow suit in 2029.
How is the AIM Act affecting virgin HFCs in fire protection?
The Environmental Protection Agency (EPA) has developed a system of allocations for the Production and Consumption of virgin HFCs: Production = Manufacturing – (Destruction + Reclamation + Transformation); Consumption = (Production + Importation) – Export.
Baseline levels were determined by mandatory reporting from the last decade.
The first of January, 2022, marked the beginning of the EPAs HFC virgin Production and Consumption phasedown.
The phasedown proceeds in a total of five step-downs.
By 2036, Production and Consumption of virgin HFCs will be limited to 15% of the baseline.
- Hire a trusted consultant who is aware of the regulations and clean agent business dynamics.
- Join the Halon Alternatives Research Corporation (HARC), which monitors regulatory activity in clean agent fire suppression. HARC directly interfaces in-person with the EPA and advocates for clean agent fire suppression generally.
- Join the Fire Suppression Systems Association (FSSA), which monitors HARC activity from a clean agent suppression Installer point of view, among many other things.
The AIM Act’s allocations plan tracks Production and Consumption allocations based on the GWP values of the quantities of various HFCs per active entity rather than material-mass-based allocation systems.
Such a system incentivises producers and importers to traffic in lower GWP molecules.
As such, since HFC refrigerants have a much higher deployment volume for fire suppressants by at least an order of magnitude and lower GWP values than those used in fire suppression, this has caused a sharp price spike in HFC fire suppressants since early 2022.
As the phasedown of HFCs intensifies, what challenges do companies involved in the HFC-based clean agent trade face?
The AIM Act’s allocations plan tracks Production and Consumption allocations based on the GWP values of the quantities of various HFCs per active entity rather than material-mass-based allocation systems.
The main challenge is the magnitude of price spikes for virgin HFC clean agents such as HFC-227ea, HFC-125, and HFC-236fa.
In most cases, customers will not accept such a high premium.
Effectively navigating HFC phasedown requires companies to become familiar with specifying and servicing low/no GWP replacements, such as FK-5-1-12 (GWP ≤ 1), reclaimed HFCs, and other firefighting clean agents, including inert gases.
How has understanding of the impact of HFCs on the climate changed?
The fire protection industry is intimately aware of the effect on our work due to atmospheric environmental regulations since the phasedown and production ban on ozone-depleting substances (such as halons) required by the Montreal Protocol.
In force in the US since the early 1990s, the Montreal Protocol ended the production of halons in the developed world on December 31, 1993.
Due to the clean agent fire protection industry’s experience with halons and the Montreal Protocol, we understand how to reclaim and redeploy clean agents that pose atmospheric harm.
In fact, we do this as a matter of routine, keeping emissions rates to their minimum.
Our industry understands that a “keep it in the tank!” policy of used gas recovery, reclamation, and redeployment keeps the value in the material and prevents harmful releases because of the economic incentive to do otherwise.
As with halons, we expect reclaimed HFC clean agents to be used for many decades even with active and approaching phasedowns across the globe.
How can companies ensure a smooth transition during the phasedown period?
The best defense is an aggressive offense.
Here are some good options for companies:
HARC directly interfaces in-person with the EPA and advocates for clean agent fire suppression generally.-item wp:list-item
What are the implications for the market of the focus in the AIM Act on recycling and reclamation of HFCs?
The Act incentivizes the use of reclaimed materials and promotes the circular economy.
Circular economy considerations for large end-users are becoming more and more important.
And be aware of the requirements as to what constitutes “recycling” for fire suppressants under the AIM Act, which will keep companies clear of EPA violations for their reporting and recordkeeping requirements for AIM Act Fire Suppressant Recyclers.
Is there a longterm future for HFCs in fire protection?
Our main case study for the future availability of HFCs under the AIM Act connects directly to halons under the Montreal Protocol.
As we know, halons are widely used in existing and OEM-new systems and handhelds.
We expect a similar case to hold true for HFCs as low/no-GWP systems are increasingly deployed.
As a treaty under the United Nations, the United Nations Environmental Panel’s (UNEP) Technical and Economic Assessment Panel (TEAP) sponsors the Fire Suppressant Technical Options Committee (FSTOC).
Every 4 years, the FSTOC publishes a quadrennial assessment.
The FSTOC’s 2022 Assessment noted that the total amount of HFC-227ea currently in cylinders worldwide is ~168,500 metric tons (MT).
By way of comparison, the FSTOC reports that the highest estimate of halon 1301 peaked in 1991 at 77,000 MT.
The large bank of HFC-227ea bodes well for continued availability for first fill and recharge for the decades to come.
The Act incentivizes the use of reclaimed materials and promotes the circular economy. Circular economy considerations for large end-users are becoming more and more important.
We expect the other HFC clean agents to follow suit.
