On January 1, 1994, production and import of virgin halons were phased out in the United States. Since that time, recycled halons are the only supply of halons in the United States for specialty fire suppression applications. While alternatives are available for most halon-based fire extinguishing applications c, halons are still employed for important applications such as on civil aircraft, in legacy military systems, and for oil and gas exploration. Sources of recycled halons include stockpiles and recovered agent from cylinders collected from decommissioned systems both in the United States and abroad.
U.S. Management of Halons
Management of halons in the United States over the last several decades combines strong collaboration by industry, government, and key users, effective regulations to reduce emissions, a smooth transition to safe alternatives through revisions to industry standards, voluntary industry codes of practice, maintenance of halon banking, and government halon reserves. Commercial recyclers buy halon from decommissioned equipment, reclaim it to industry specifications and sell it into important, continuing uses such as aviation, military, and oil and gas exploration.
EPA regulations address the import, export, handling, and disposal of halons 1211, 1301, and 2402 and equipment containing them. The regulations cover the following:
- Ban on Halon Blends
- Intentional Releases
- Technician Training
- Proper Disposal
- Import and Export of Used Halon 1301
Ban on Halon Blends
A halon blend is any mixture or combination of substances that contains two or more halons. Since 1998, it is unlawful to manufacture any halon blend.
EPA regulations prohibit the venting of halons during testing, maintenance, servicing, repair, or disposal of halon-containing equipment, or during the use of such equipment for technician training. Regulations also prohibit halon releases that occur because an owner failed to maintain halon-containing equipment to relevant industry standards.
The regulations exempt certain limited halon releases for health, safety, environmental, and other considerations:
- De minimis releases associated with good faith efforts to recycle or recover halon. For example, the release of residual halon contained in fully discharged total flooding fire extinguishing systems is considered a de minimis release.
- Releases during the testing of fire extinguishing systems or equipment only if the following four criteria are met: 1) systems or equipment employing suitable alternative agents are not available, 2) release of agent is essential to demonstrate system or equipment functionality, 3)failure of the system would pose great risk to human safety or the environment, and 4) a simulant agent cannot be used for the testing purposes.
- Releases that occur during research and development for halon alternatives and analytical determinations of halon purity.
- Releases associated with qualification and development testing during the design and development of halon-containing systems and equipment only when 1) such tests are essential to demonstrate functionality, and 2) a suitable simulant agent cannot be used for the testing.
This prohibition does not apply to emergency releases of halons for legitimate fire extinguishing, explosion inertion, or other emergency applications for which the systems or equipment were designed.
Technicians must be trained in handling and disposing of halons within 30 days of hire. Several industry organizations provide training guidelines and other relevant information. These include the National Fire Protection Association (NFPA), the International Organization for Standardization (ISO), and the American Society for Testing and Materials (ASTM).
Halon-containing equipment must be properly disposed of at the end of its useful life. Proper disposal means sending this equipment for halon recovery or recycling only to a facility (e.g., a manufacturer, fire equipment dealer, recycler, or an in-house recovery or recycling operation) operating in accordance with NFPA 10 and NFPA 12A standards. The halon itself must also be properly disposed of only by a facility operating in accordance with NFPA 10 and NFPA 12A, or destroyed using one of several controlled processes identified in the regulation.
Ancillary system devices, such as electrical components that are not necessary to the safe and secure containment of the halon, are not subject to this provision. In addition, equipment containing only de minimis quantities of halon is not subject to this requirement.
Import and Export of Used Halon 1301
EPA uses petitions to approve and track the import of used halons. Used halons must be imported via EPA's petition process. Below is a table showing the recent import and export of used halon 1301.