Halon-Containing Equipment Testing and Maintenance

Release of Halon is prohibited during testing of containing-containing equipment unless all four of the following conditions are met: 1) systems or equipment employing suitable alternative fire extinguishing agents are not available; 2) systems or equipment testing requiring release of Halon is essential to demonstrate functionality; 3) failure of the system or equipment would pose a great risk to human safety or the environment; and 4) a simulant agent cannot be used in place of Halon during testing for technical reasons.

No owner of containing-containing equipment shall allow a Halon release to occur as a result of failure to maintain such equipment.

Halon-containing equipment is typically used in fire extinguishing and explosion protection systems. Halon 1211, a liquid streaming agent, is most often used in hand-held fire extinguishers while Halon 1311, a gaseous agent, is used mainly in built-in total flooding systems. Halon-containing equipment is used for the protection of areas that contain sensitive or irreplaceable equipment or items that could be damaged or adversely affected by water, foam, dry chemical or carbon dioxide. Such areas include computer rooms, telecommunications facilities, data/document storage areas, control rooms, museums, art galleries, or kitchens.

Recycling and Disposal Practices

If you send containing-containing equipment offsite for disposal, it must be sent to a manufacturer, fire equipment dealer, or recycler operating in accordance with National Fire Protection Association (NFPA) 10 and NFPA 12A standards. Verify that facilities receiving your containing-containing equipment meet these requirements by asking them to provide you with documentation that confirms that these standards are being met.

If you send Halon offsite for disposal, it must be sent for:

• Recycling, to a recycler operating in accordance with NFPA 10 and NFPA 12A standards; or

• Destruction, using an EPA-approved destruction technology (e.g., liquid injection incineration, reactor cracking, gaseous/fume oxidation, rotary kiln incineration, cement kiln, radio frequency plasma destruction, or an EPA-approved destruction technology that achieves a destruction efficiency of 98% or greater).

Verify that facilities receiving your Halon meet these requirements by asking them to provide you with documentation that confirms that these standards are being met.

(Note that EPA is considering future regulations that would: 1) require the certification of Halon recycling and recovery equipment; and 2) allow the removal of Halons only through use of certified equipment.)

Maintenance/Service Vendor Suggestions

Ensure that your vendor has properly trained technicians to perform any testing, maintenance, service, repair, recovery, or recycling activities.

Ensure that your vendor is properly disposing of Halon and containing-containing equipment in accordance with EPA standards.

Have your vendors evaluate substitutes and costs for recharging your system(s) with replacement Halon if release occurs.

Reporting and Record keeping

It is recommended that you keep the following records to demonstrate compliance with the requirements:

• Halon and containing-containing equipment recycling/disposal records (Halon type and quantity and the date sent off-site and the name and address of disposal/recycling facility)

• Service maintenance and repair records (date and type of service, quantity of Halon purchased and added)

• Halon purchase records

• Technician training records

Obtain from your service vendor written assurances that only properly trained technicians will be used for work at your facility.

If you send your Halon and/or containing-containing equipment offsite for recycling/disposal, be sure that the recycling/disposal facilities are meeting EPA operating standards. Obtain documentation from your Halon recycler/disposer to verify compliance with EPA requirements.

Maintain all records for a minimum of five years.

Technician Certification Requirements

Technicians performing testing, maintenance, service, or repair on containing-containing equipment must be trained regarding Halon emissions reduction:

• Technicians hired on or before April 6, 1998 will be trained by
  September 1, 1998.

• Technicians hired after April 6, 1998 will be trained within 30 days of hiring or by September 1, 1998, whichever is later.
  
  EPA does not specify criteria for technician training program content, but recommends use of the following documents as guidance for developing training programs addressing Halon management and emissions reduction. These documents describe practices for handling, testing, servicing, maintaining, and transporting fire extinguishing systems and emphasize the importance of Halon emissions minimization.

• National Fire Protection Association (NFPA) 10. "Standard for Portable Fire Extinguishers."

• NFPA 12A. "Halon 1301 Fire Extinguishing Systems."

• International Organization for Standardization (ISO)-7201-1.
  "Fire protection - Fire extinguishing media - Halogenated hydrocarbons - Part 1: Specifications for Halon 1211 and Halon 1301."

• ISO-7201-2. "Fire extinguishing media – Halogenated hydrocarbons - Part 2: Code of practice for safe handling and transfer procedures of Halon 1211 and Halon 1301."

• American Society for Testing and Materials (ASTM) D5632-94a. "Standard Specification for Halon 1301, Bromotrifluoromethane."

• ASTM D5631-94. "Standard Practice for Handling Transportation and Storage of Halon 1301 Bromotrifluoromethane."

Contact your fire protection vendor for information about training program availability.

Halon Release Requirements

The intentional or knowing release of Halon to the atmosphere is prohibited. This prohibition applies during maintenance, repair, service, disposal, testing or technician training. De minimis amounts of Halon released during good faith attempts to recover, recycle, or safely dispose of Halon during servicing, maintenance, repair, and disposal activities conducted in compliance with Federal laws and regulations are not subject to this prohibition.

No owner of containing-containing equipment shall allow a Halon release to occur as a result of failure to maintain such equipment.

Please be aware that use of Halon can pose health and safety hazards to personnel depending upon the type of system and area in which it is located.

Halon Substitutes

The production of Halon has been banned since 1994 and the cost of Halon has, therefore, been increasing. Replacement Halon to recharge systems and equipment will ultimately become unavailable. Key property may be at risk if existing Halon systems and equipment cannot be recharged.

Halon substitutes are now commercially available, but have properties that are less universally acceptable than Halon 1211 or Halon 1301. Some substitutes can present health and safety hazards to personnel and are therefore not acceptable for use in occupied areas. In addition, some substitutes are less effective for fire suppression and must be used in greater quantities than Halon. Re-engineering of delivery piping, storage tanks, and other mechanical components is generally required. Fire protection engineering analysis is required to determine which substitute would be suitable for a particular occupancy or property, whether a drop-in substitute will work, and/or if new systems are necessary.

Key Things To Know

The intentional or knowing venting of Halons into the atmosphere is prohibited, including venting from equipment testing.

Service technicians must be trained in Halon emissions reduction in order to test, maintain, service, or repair containing-containing equipment.

Recycling/disposal of Halon and containing-containing equipment must be conducted in accordance with EPA standards.

Halon Management Practices Checklist

Is a containing-containing equipment inventory maintained and up-to-date?

Are employees aware of the prohibition on intentional releases of Halon including equipment testing?

Does the facility have a regular maintenance and repair program for containing-containing equipment?

Are personnel who perform containing-containing testing, maintenance, service, repair, recycling, and disposal properly trained in Halon emissions reduction?

Does record keeping include:

• Halon purchase log?
• Training records of technicians involved in containing-containing equipment testing, maintenance, service repair, recycling, and disposal?
• Halon-containing equipment service log?
• Halon and containing-containing equipment disposal/recycling log?
• Halon and containing-containing equipment disposal/recycling records?

Do disposal and recycling facilities meet EPA specifications and requirements?

Ask your vendor for a list of containing-containing equipment that he/she services for your faculty or administrative department.

Has an engineering analysis been conducted to identify Halon alternatives for new or existing facilities?

Based on current Halon prices, have you considered the impact of a Halon system release?

Suggestion: Also require documentation from contractors who service equipment.

NFPA, Inc. specializes in meeting all your Halon-Containing Equipment needs, whether it be buying, recycling, or selling bulk Halon and/or Halon fire extinguishers. Give us a call.

RTA fire extinguishers are sold through aviation distributors world wide.
or email us for a distributor in your area.