Comment Log Display

I agree with the Environmental Justice Advisory Committee's
recommendation that this sector should be proposed and developed. 
However, I want to specifically address the comments that
accompanied the committee's recommendation. Those comments were as
follows:

1. The question of the toxicity of the alternatives is
important and lingering and must be addressed before
adopting such a regulation.
2. We urge ARB to undertake a complete life cycle
analysis of any proposed substitutes.

Recognizing that a variety of substitute technologies exist that
can enable reductions in greenhouse gases from the fire protection
sector, and the recommendations do not specifically call out an
agent of concern, I would like to comment on these points with
respect to Novec 1230 fluid.

With regard to these comments, please consider that Novec 1230
fluid is not new and that it is sold into a highly regulated
market. Novec 1230 fluid has been a commercial product globally
for the past 5 years.  Its health and environmental impact has
been reviewed by numerous global regulatory bodies including the
U.S. EPA.  In fact, two different branches of EPA have reviewed
and approved the use of Novec 1230 fluid as a fire suppression
agent.  Because Novec 1230 fluid is a novel chemistry, a
pre-manufacture notice was submitted and reviewed by the U.S. EPA
Office of Pollution Prevention and Toxics.  In addition, because
Novec 1230 fluid has been commercialized as a replacement for an
ozone depleting substance, its environmental, health and safety
impact have been reviewed by the Significant New Alternatives
Policy Program in the Office of Stratospheric Protection.  The
review by these two separate branches of U.S. EPA thoroughly
addressed the toxicity of Novec 1230 fluid in its intended
application and addressed its life cycle impact.  Please also
consider that similar reviews have been conducted in many other
jurisdictions around the world including the EU, UK, France,
Germany, Canada, Korea, Japan, and Australia to name a few. Below,
I have highlighted text from the 2002 EPA SNAP approval of Novec
1230 that specifically addresses the issue of safety and life
cycle impact relative to alternative technologies:

"EPA has reviewed the potential environmental impacts of this
substitute and has concluded that, by comparison to halon 1301 and
other acceptable substitutes, C6-perfluoroketone significantly
reduces overall risk to the environment...... C6-perfluoroketone
provides an improvement over use of halon 1301,
hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) in
fire protection. We find that C6-perfluoroketone is acceptable
because it reduces overall risk to public health and the
environment in the end use listed."

It is also important to understand that this sector is also
regulated by standards organizations and approval bodies such as
NFPA, ISO, FM, Lloyds, UL, VDS, etc. that, to some extend, also
address the EHS characteristics of new agents prior to approval.

In some sectors where high GWP materials are used, use of those
materials results in an increase in energy efficiency. On this
basis, the direct emissions of the agent needs to be balanced with
the indirect CO2 reductions that are enabled. This is often
referred to as a life cycle analysis.  Because there is no energy
component to be considered in the fire protection sector, this
type of life cycle analysis is not relevant.

Several papers by independent researchers have been published that
address the atmospheric chemistry of Novec 1230 fluid. I have
referenced one below.

Atmospheric Chemistry of C2F5C(O)CF(CF3)2: Photolysis and Reaction
with Cl Atoms, OH Radicals, and Ozone N. Taniguchi,*,† T. J.
Wallington,*,‡ M. D. Hurley,‡ A. G. Guschin,§ L. T. Molina,§ and
M. J. Molina§ Department of Molecular Engineering, Kyoto
UniVersity, Kyoto 606-8501, Japan, Ford Motor Company,
SRL-3083, Dearborn, Michigan 48121-2053, and Department of Earth,
Atmospheric, and Planetary Sciences, Massachusetts Institute of
Technology, Cambridge, Massachusetts 02139

In summary, Novec 1230 fluid has been commercial for 5 years. More
than 3000 systems have been installed globally.  This technology
has been studied, evaluated, and/or approved by independent
researchers, standards organizations, approval bodies and
government regulators globally.  The toxicity and LCA
characteristics have been thoroughly evaluated, reviewed, and
approved.