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:
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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)
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Service maintenance and repair records (date and type of service, quantity of Halon purchased and added)
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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:
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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."
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NFPA 12A. "Halon 1301 Fire Extinguishing Systems."
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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."
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American Society for Testing and Materials (ASTM) D5632-94a. "Standard Specification for Halon 1301, Bromotrifluoromethane."
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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.