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.