Further analysis indicated that less than 10% of halon emissions were attributable to fire fighting.6 EPA, NFPA, and other organizations were now working to educate stakeholders about the importance of eliminating testing, training, and accidental discharges. In Australia, the State of Victoria implemented strong controls on halon use, and plumbers' unions refused to install or service halon systems unless it was deemed essential by a committee of public and private experts. Elsewhere, authorities of jurisdiction were helping to eliminate requirements for discharge testing and training with halon.

In 1989, the United Nations Environment Programme (UNEP) organized the first technology assessment, which included the work of the UNEP Halon Technical Options Committee. This committee of international experts became the catalyst for global efforts.

Slowly fundamental change began to occur. Property owners began to use a broader range of strategies to protect property. Computer manufacturers confirmed that, contrary to advertising claims for halon, most equipment could be protected with water sprinklers. Insurance companies agreed to offer their most favorable rates to insure property with fire protection other than halon. Telecommunications companies reduced the need for halon by using cable materials that would not bum. The military began to design weapons systems that did not depend on halon. Broader fire protection engineering considerations and fire prevention began to take precedence over the basic fire-extinguishing perspective. These efforts stimulated other important paradigm shifts. For example, military aircraft designers reevaluated whether space and weight might be better allocated to threat avoidance or weapons rather than fire protection.

The EPA and the Air Force helped to organize the Halon Alternatives Research Corporation (HARC) to aid in identifying the most promising research opportunities, and they worked to prepare markets to accept alternatives and substitutes as they developed. The Marine Corps, Navy, and Air Force cooperated to develop the first practical halon recycling equipment and were the first organizations in the world to deploy this equipment. The Navy and Marine Corps teamed up with EPA to teach halon recycling to experts from Latin America and the Far East.

Unfortunately, halons are still required for 15 to 20% of the applications they satisfied in 1986. If halons currently contained in existing equipment are never released to the atmosphere, the integrated effective future chlorine loading above the 1980 level is predicted to be 10% less over the next 50 years.7 See Chapter 3 for further discussion.

Thus, much work remains to complete the phaseout of halon use. Chemical substitutes for halon for the remaining important uses are a part of the ultimate solution.

U.S. Regulation of Halons and Halon Substitutes

When the Montreal Protocol was signed in 1987, the EPA's role in stratospheric ozone protection derived from the Clean Air Act of 1977, Part B, section 157(b):

. . . the Administrator shall propose regulations for the control of any substance, practice, process or activity (or any combination thereof) which in his judgment may reasonably be anticipated to affect the stratosphere, especially ozone in the stratosphere, if such effect in the stratosphere may reasonably be anticipated to endanger public health or welfare.

This language gave EPA broad latitude, but it did not give clear guidance. EPA began to develop control strategies based primarily on measures of ozone depletion potential (ODP). A product whose ODP was lower than that of the CFCs was considered to have an advantage over the halons. Thus, FM-100™ (HBFC-22B1 or CF2HBr) with an ODP of 0.748 was investigated as an effective halon substitute. With the enactment of the Clean Air Act Amendments of 1990 (CAAA), Congress provided guidance to EPA by stipulating that any substance with an ODP of 0.2 or greater would be a class I substance and would be subject to the same production phaseout as the CFCs and halons. This restriction effectively eliminated some potential fire-extinguishing substitutes, such as FM-100™, and mixtures using CFCs.

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