The Hazard Mitigation Analysis (HMA) is step number one. This is the first thing that you as manufacturers, you as installers, you as property managers that are looking for properties, need to talk about; do we have an HMA for our batteries? I had someone come up to me recently and say, well, sometimes when we pick a site, we don't know the technology. Okay, you normally have a couple in mind or two, or three. Make an HMA with all three technologies and then we can just get rid of the ones that you don't end up using. But let's start this hazard mitigation analysis early. Because what it does is it looks at the consequences of failure. And if you look at the Phoenix Fire Code, we require this for every single battery installation. NFPA 855 and the base International Fire Code (IFC) has three different criteria.

NFPA 855: How are battery manufacturers working with UL to create safer batteries?

In the ICC, Chapter 12 is what deals with lithium ion and other batteries Currently, there's a committee called the Fire Code Action Committee that brings in industry, manufacturers, AHJ’s, like myself, and experts. We're working on different parts of Chapter 12 for energy issues. Be careful, just because a jurisdiction adopts Chapter 12, we might amend it. In the City of Phoenix, we amended Chapter 12, heavily. Ours is probably a little bit more restrictive than most of the country. I would say our sprinkler density, that we'll talk about here in a little bit, is more restrictive. We wanna require our AHJs to be more restrictive, so be careful. Always look at the code amendments from that local jurisdiction.

How do we try to make these as safe as possible? It starts for us with the codes and standards. You have the International Code Council, which is the ICC, that creates the International Fire Code, the International Building Code. We have the National Fire Protection Association, the NFPA. We also have to have standards testing. UL has UL 9540, which is the listing for Battery Energy Storage Systems (BESS). You look at all the codes and the codes will require UL 9540 listing for all batteries. And the test is the 9540 A test. So these have all been updated and worked on after McMicken, after Victoria in Australia, after Moss landing, after all of the fires. We're doing a much better job about getting everyone together in a room and creating better codes.

We always try to learn lessons. What worked well, what didn't work well. McMicken showed us that a clean agent type fire protection system alone is not adequate. We need something else. We need sprinklers. If we're going to be in an occupiable space, once again, we know that sprinklers don't control the thermal runaway, so all we're really doing is cooling it. Now, sprinkler water, as well as the water mist system, is really good about keeping vapors down, which is another thing that we're working on here in the valley with one of our battery installations. But sprinklers alone are not going to control the thermal runaway. It's going to do its thing until it's done.

A Joint Study by the Fire Suppression Systems Association and the Fire Industry Association (UK)

Issued November 1, 2023 - Released December 15, 2023

"The Fire Industry Association (FIA), a non-profit organisation, has pledged to dedicate a portion of its yearly revenue to support joint research initiatives that contribute to the well-being of its members, the industry, or public safety. Collaboration with other organisations is integral to the success of these projects. The partnership with the Fire Suppression Systems Association (FSSA) exemplifies the FIA's steadfast commitment to this initiative." - Robert Thilthorpe, Technical Manager, Fire Industry Association

“This research report is the culmination of almost six years’ collaboration between the UK’s Fire Industry Association (FIA) and the USA’s Fire Suppression Systems Association (FSSA).  The research demonstrated that continuous recirculating airflow can enhance uniformity of gaseous agent concentrations in data center applications, even in spaces where aisle containments are present.  The conclusions of the report should be quite useful to those responsible for designing and maintaining clean agent fire extinguishing systems for data centers” - Tom Wysocki, Technical Director, Fire Suppression Systems Association

On October 19, 2023, the EPA issued a proposed rule titled Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes under Subsection (h) of the American Innovation and Manufacturing Act of 2020 (88 FR 72216). For additional information on the proposed rule and supporting documents, please visit https://www.epa.gov/climate-hfcs-reduction/management-certain-hydrofluorocarbons-and-substitutes-under-subsection-h. 

The rulemaking proposes the following requirements:

If one is working through a distributor or an installing contractor that has a supply agreement or a contract with an original equipment manufacturer (OEM) for the equipment that is listed using Novec 1230 fluid, they are likely listed with FK-5-1-12 from alternative suppliers as well. Novec 1230 is a neat (single component) agent. It is typically discharged from a cylinder with a nitrogen super pressurization or one with a separate nitrogen tank design used in a piston flow fashion giving a “push” to it.

It is recommended that one first checks with the original equipment manufacturer and their representative installing contractor to make sure they are supplying it with a listed or approved system. And second, make sure that they have a certificate of analysis assuring the quality of the clean agent material.

There has not been a sufficient concern to compel regulatory authorities to put restrictions on the use of Halon from a persistent standpoint, and for other reasons. The PFCs, HFCs, and HCFCs, are all being regulated for other reasons, based on ozone depletion potential (ODP), global warming potential (GWP), and so forth. The European ECHA has a proposal in place but at this point in time, clean agents are considered for derogation in the proposal.

In December 2022, 3M announced its plans to exit the manufacturing of 3M™ Novec™ 1230 Fire Protection Fluid and their fluorochemical line of products completely by 2025, shocking the fire protection industry, as no one saw it coming. There is still a lot of excitement and maybe some angst or concern out in the marketplace. The best advice is to stay calm because regulatory resolution is not something that will unfold very quickly. There currently exist proposed changes offered or enacted state legislation that have taken place, particularly here in the United States. Even with current action, time is needed to determine what really needs to be done. There will be much discussion but watch for action.

Halocarbon clean agents are not going away anytime soon. Halon manufacturing was banned in Article One countries back on December 31st, 1992, at 11:59 PM EST, yet decades later we still see halon systems in use. This is not to say that things will be exactly the same for systems using Novec 1230 fluid, but these things do not tend to move very quickly. What is important is that halocarbons are not going away anytime soon, and 3M has made it clear that they plan to honor their commitments to fulfill orders of the product already made.

Trifluoroacetic acid (TFA) actually meets the definition of PFAS because it has a CF3 radical on the molecule. Researchable comments exist regarding the fate of trifluoroacetic acid, like from Columbia Climate School Center. The source of the currently observed levels is unknown and puzzling according to them. In 2001, the observed TFA concentrations were orders of magnitude larger than those predicted to result from the atmospheric degradation of the replacement of HCFCs and HFCs. The Columbia researchers noted that at the time FK-5-1-12 was not even commercialized.

Another collaborative study was conducted in 2002 and published in Environmental Science and Technology by the Environmental Laboratory in Seattle, Washington, the Department of Environmental Chemistry and Eco Toxicity in Germany, Scripps Institution of Oceanography, the University of California San Diego in La Jolla, and NOAA. The purpose of that study was to estimate TFA in ocean waters, given the material is strongly hydrophilic, and to assess whether today's levels are mainly from anthropogenic origin or whether biological or geological sources must be considered. Their conclusion at that time was that TFA is present in the global environment in two major compartments, in the ocean water and in the atmosphere, and in other areas, precipitation and fresh waters and so forth.

The European Chemicals Agency (ECHA) is currently accepting comments in the REACH restriction process regarding future use of per and polyfluoroalkyl substances (PFAS), including those used in fire protection like FK-5-1-12. This is a three-phase process according to ECHA. Phase 1 is preparation and submission of a restriction proposal, beginning with notification of intent to submit a restriction, then the registry of intentions, preparing the restriction dossier, and then submission and conformity check. Phase 2-A, a consultations phase, includes a consultation on the restriction report and a consultation on the Committee for Socio-Economic Analysis (SEAC) draft opinion. Phase 2-B is an opinion development phase that includes advice from the forum, RACs opinion and SEACs opinion. Finally, Phase 3 is the decision and follow-up phase including commission decision on the restriction, complying with the restriction, and enforcing the restriction. Regarding FK-5-1-12 as well as other halocarbon clean agents, ECHA is currently in the second phase which, again in itself has two phases; consultations and opinion development. So, once completed, with comments taken until 25 September 2023, there will be a decision and follow up on what the regulation is going to be in Europe.

The atmospheric degradation mechanism of FK-5-1-12 looks like this as a balanced equation C₂F₅(O)CF(CF₃)₂—-->4CO₂+CF₃COOH+9HF. Taniguchi concludes the photolysis of the ketone in the air results in a radical, uh, and also carbonyl fluoride will be incorporated in the air cloud and seawater where it'll undergo hydrolysis to, to give the trifluoroacetic acid. Similarly, the carbonyl fluoride will undergo hydrolysis to give CO₂ and HF. The CO₂, as well as any of these, the other two products that result from reacting with ketone at the concentrations expected in the environment is not considered harmful according to Taniguchi. The concentrations expected from what is going to be emitted into the atmosphere, combined with a short atmospheric lifetime, the global warming potential is negligible.

The acronym PFAS is short for per or polyfluoroalkyl substance. Depending on the source, there are up to 15,000 products or materials that meet the definition of PFAS. PFAS includes a broad category of materials that can be solids, liquids or gasses. Some fire protection materials, defined as PFAS, that are components in aqueous film forming foams (AFFF) are considered persistent, bioaccumulative, and toxic (PBT). Because of this, their use in fire protection and other applications is being phased out globally by the U.S. EPA and other regulatory agencies.

On June 29, the EPA announced its framework for addressing new and new uses of per- and poly-fluoroalkyl substances (PFAS). The framework outlines EPA’s planned approach when reviewing new PFAS and new uses of PFAS to ensure that, before these chemicals are allowed to enter into commerce, EPA will undertake an extensive evaluation to ensure they pose no harm to human health and the environment. Read the news release here.

If you want to learn more about the framework, register for EPA’s upcoming webinar on September 6 at 2:00pm ET.

The EPA has issued its Fire Suppressant Recycling Under the HFC Allocation Program Questions and Answers Fact Sheet dated May 2023. It provides guidance regarding when a company is considered an HFC Fire Suppressant Recycler, and its reporting obligations under the AIM Act. This guidance was first requested by FSSA in March 2022. A key provision in the fact sheet:

Who qualifies as an HFC fire suppressant recycler?

3M Company recently issued a release stating the company’s intention to exit per- and polyfluoroalkyl substance (PFAS) manufacturing and work to discontinue the use of PFAS across its product portfolio by the end of 2025.  This was a business decision by 3M and will include the manufacturing of its 3M™ Novec™ 1230 Fire Protection Fluid - which is 3M’s trademarked-version of the FK-5-1-12 fire suppression agent.

In the release, 3M states that “PFAS can be safely made and used” and its “products are safe for their intended use.” The company commits to facilitating an orderly transition for customers. The announcement does pledge 3M will fulfill its current contractual obligations.

To: State and Local Building Officials, Fire Marshals, and other Local Authorities
From: The Fire Suppression Systems Association

The Fire Suppression Systems Association (FSSA) is a membership organization composed of manufacturers, installers, and professionals engaged in the application of fire suppression systems and other fire extinguishing technologies. The FSSA is very concerned with the severity of fires and explosions occurring in battery energy storage systems (BESS) using new battery technologies. Our members have collectively witnessed severe disruptions due to fires originating in these systems.