On July 20, 2023, the EPA published an update to (40 CFR Part 84) which implements the American Innovation and Manufacturing Act. The updated regulations, effective September 18, 2023, include new requirements to verify the quality of HFC fire suppressant agents by laboratory testing as well as additional recordkeeping requirements. These updated regulations affect FSSA members who fill or recharge HFC fire system cylinders. An overview of the EPA regulation was given at the FSSA Annual Forum and discussed at the division meetings. (88 Fed. Reg. 46836)

SUMMARY OF THE REGULATORY UPDATES

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:

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?

Written by: Bill Polits, Director, Sales and Strategy, A-Gas

The AIM Act is landmark legislation curbing the production and consumption of HFCs in the US. The AIM Act also puts a focus on economic growth through job creation and American global leadership in technology and global trade. Despite lots of talk about the AIM Act, many in the fire protection industry have questions. While this article will outline the background behind this legislation, detail how the Environmental Protection Agency (EPA) will implement the AIM Act, describe the current situation for virgin HFCs in fire protection, and share what the future may hold for HFCs, the regulatory world is always evolving and changing. Thus, your company should always check with its own counsel to help with decision-making.