Differentiating PFAS Series: What is the Future Liability Potential for Using Clean Agents?


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.

Trifluoroacetic acid (TFA) has been discussed for decades. Research papers from universities, industry, and regulatory authorities have been commenting on this for years. In fact, U.S. EPA has not promulgated any ruling in an attempt to restrict TFA. The NFPA GFE committee governing NFPA 2001 met (1st Draft meeting) June 2023 and TFA was not on the agenda or even brought up. There is nothing currently on the horizon that would indicate restrictions on the use of FK-5-1-12. There will be restrictions on HCFCs, to be phased out by 2030. The manufacturers of HFCs will have to make a decision by 2035 or 2036 on the mixture of products that they are going to use for fire protection, refrigeration, and so forth, because they must bring the use of HFCs down to 85%, down to 15% of 2005 level on a CO2 equivalent basis. At this point in time, there are no restrictions on the use of FK-5-1-12, other than what currently exists regulatorily.

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