FSSA is excited to launch a new course in our online training program to help the industry comply with the new AIM Act technician training requirement. The EPA requires technicians working with fire suppression systems containing HFCs to complete a training by June 1, 2026 or 30 days after they are hired, whichever is later.

FSSA Member Fee: Complimentary (You must be linked to your organization's membership to receive member pricing. For information on how to join a membership, click here.)

The following is a summary of new regulations published October 11, 2024 affecting companies that fill, recharge, recycle, and/or service fire suppression equipment containing HFCs.  Note that these reporting and recordkeeping requirements are in addition to agent test and recordkeeping requirements which became effective September 18, 2023 and the reporting requirements for recyclers of fire suppression HFCs which became effective in 2022.

Attached below is a copy of the Environmental Protection Agency (EPA) Final Rule (89 Fed. Reg. 82682, Oct. 11, 2024) on the management and reclamation of HFCs under the AIM Act. The Rule goes into effect on December 10,2024.

Here is a summary of the Rule’s requirements applicable to use of HFC (Hydrofluorocarbons) agents in fire suppression systems. References below are in 40 CFR Part 84 of the Code of Federal Regulations.

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.