Recycling Halon Alternatives a No-No?
January’s issue of Consulting-Specifying Engineer, in it’s virtual M/E Roundtable, discusses the subject of clean agents and halon alternatives.
Editor’s note: January’s issue of Consulting-Specifying Engineer, in it’s virtual M/E Roundtable, discusses the subject of clean agents and halon alternatives. Specifically, the discussion addresses the latest innovations, the most current code and legislation issues affecting design and installation, and the most common mistakes engineers make in specifying fire-protection systems containing such agents. In the meantime, we present additional discussion of the issue, in this case, the reuse and recycling of halon clean agents.
Participating in the discussion are Steven T. Ginn, Business Manager, Fire Safety Products, Great Lakes Chemical Corporation, Lafayette, Ind., ; Reed Varley, P.E., Principal, Varley-Campbell & Assocs., Miami; Chris Hanauska, P.E., Senior Engineer, Hughes Assocs., Baltimore; Brian Engler, Global Business Manager, Fire Extinguishants, DuPont Fluoroproducts, Wilmington, Del.; and Paul Rivers, Product and Applications, Development Specialist, 3M, St. Paul, Minn.
CSE: Now that halon alternatives have been on the market since the 1990s, has it become common for these patented products to be recycled and then redistributed through a secondary market? Are there legal ramifications for this type of activity?
RIVERS: The major concern for recycling halon alternatives, by other than the original manufacturer, would be meeting the rigid specifications for the product. I know of no legal ramifications. However, I have seen the beginnings of the recycle and reclaim market for halocarbon halon alternatives. This is cost-driven, unlike inert gas agents, where the agent itself is quite inexpensive and
ENGLER: The U.S. Environmental Protection Agency requires that all halon and halon alternatives be recovered and recycled to minimize overall emissions of these products to the environment. There are a number of companies in the fire protection industry that provide this service, which is an essential element of good product stewardship. Patents apply to the recycled materials if the material is resold into new systems. However, they do not apply if the material is reused by the original owner. DuPont strongly recommends always using an approved recycling vendor.
GINN: The significant commercial success of the FM-200 (HFC-227ea) product over the past decade has established a sizable quantity of this extinguishing agent in the marketplace. In some cases, FM-200 suppression systems have reached the end of their service life. Some decommissioned systems are now finding their way into the traditional recycling channels established for halon.
Recycling HFC-227ea and reselling it without authorization from either Great Lakes or DuPont may pose several issues. Once the extinguishing agent is removed from its original system container and separated from the nitrogen propellant, it ceases to be the product sold by Great Lakes or DuPont. HFC-227ea sold by producers other than Great Lakes or DuPont in countries where their patents are in force may constitute a patent infringement.
Furthermore, this is an issue as recycled HFC-227ea is not subject to the quality control of Great Lakes or DuPont. Therefore, any recycled or reprocessed product sold or otherwise represented as the original extinguishing agent, such as FM-200, without a license constitutes a potential trademark infringement.
Beyond the matter of patents or trademarks, the greater concern is the unknown effect on system performance and reliability when systems incorporate HFC-227ea extinguishing agent from sources other than Great Lakes or DuPont, who hold patents in this area. All of the authorized HFC-227ea suppression systems manufactured worldwide have been tested and listed or approved by an independent third party testing laboratory to ensure that each and every system is backed by sound technology, and will perform as expected in the rare event of a fire. In addition, Great Lakes maintains a separate component listing for the FM-200 extinguishing agent from Underwriters Laboratories (UL) and component approval from Factory Mutual (FM) as an independent verification of the inherent quality built into the fire extinguishing agent.
The system and component listings and approvals by third parties are important safeguards built into the quality of these systems, and the peace-of-mind these safeguards offer system owners should not be compromised by utilizing extinguishing agents that do not meet these proven standards.
There is a clearly a need for an environmentally responsible solution for the reclamation of extinguishing agents from systems at the end of their useful service. In the case of HFC-22ea, Great Lakes will work closely with all owners of decommissioned systems to find an appropriate and environmentally responsible outlet for their HFC-227ea product.
VARLEY: At this time there appears to be no interest in a secondary market for halon alternatives. If the agent is obtained from a different vendor from the one that supplied the system, liability for defects may be difficult to apportion.
(For more on this discussion please see the January 2003 issue of CSE. The full discussion will also be posted at csemag.com later this month)