revised guidance note for ozone depleting substancesrevised guidance note for ozone depleting...

Revised Guidance Note for Ozone Depleting Substances

Halon Phase-Out (Fire Protection Sector)

August 2008

Revised Guidance Note for Ozone Depleting Substances Halon Phase-Out (Fire Fighting Systems)

Environmental Protection Agency Rev 02

Acknowledgements

The Environmental Protection Agency is grateful for the input of URS Ireland Ltd. to the first draft of this Guidance Note (November 2005). The Agency would also like to thank the Fire Engineering Systems Association (FESA). This revised version is based on the November 2005 draft.

© Environmental Protection Agency 2008

Although every effort has been made to ensure the accuracy of the material contained in this

publication, complete accuracy cannot be guaranteed. Neither the Environmental Protection

Agency nor the author accepts any responsibility whatsoever for loss or damage occasioned,

or claimed to have been occasioned, in part or in full as a consequence of any person acting

or refraining from acting, as a result of a matter contained in this publication. All or part of

this publication may be reproduced without further permission, provided the source is

acknowledged.


Environmental Protection Agency Page i

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CONTENTS

Section Page No

WHAT YOU NEED TO KNOW................................................................................................. 1

1. INTRODUCTION ........................................................................................................... 2

2. USES OF HALONS ...................................................................................................... 3

3. ENVIRONMENTAL IMPACT ...................................................................................... 4

4. IMPACT OF REGULATIONS ..................................................................................... 5

4.1. Implementation .............................................................................................................. 5 4.2. Phase-out Dates............................................................................................................ 5 4.3. Import and Export.......................................................................................................... 6 4.4. Supply and Use of Ozone Depleting Substances .................................................. 10 Critical Users ............................................................................................................................. 10 Non-Critical Users..................................................................................................................... 11 4.5. Training and Minimum Qualifications ....................................................................... 12

5. ODS WASTE MANAGEMENT ................................................................................. 12

6. REPORTING REQUIREMENTS............................................................................... 14

7. SUMMARY OF ALTERNATIVES............................................................................. 15

8. ENFORCEMENT AND PROSECUTIONS .............................................................. 15

9 SOURCES OF INFORMATION ................................................................................ 16

Appendix A - Alternatives to Halons

Appendix B - Safety in Halon Decommissioning

Appendix C - ODS Waste Management Guidance

Appendix D - Halon Critical Users – Annual Report to EPA


Environmental Protection Agency Page 1

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WHAT YOU NEED TO KNOW

This Guidance Note is intended for those involved in the handling (decommissioning) of halon in the fire protection sector and specified critical uses of halon1 in Ireland. The following summarises the main impacts of the Regulation (EC) No. 2037/2000 on substances that deplete the ozone layer in relation to supply and use of halons, further implemented in Ireland by the Control of Substances that Deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of 2006).

Impact Guidance Note Section No.

Use and sale of halon fire-fighting equipment for non-critical users is prohibited since 31st December 2002. This includes use and sale of recovered and recycled halons.

4.2/4.5

All halon fire-fighting equipment should have been decommissioned by December 31st 2003. Following decommissioning, all halons must be recovered for destruction.

4.2/4.5

Import and placing on the market of halons and products and equipment containing halons is prohibited, except for critical uses, for use as a feedstock or processing agents or for the purpose of destruction.

4.3

Exports from the EU of halons or products and equipment containing halons is prohibited, with the exception of halons exported for critical uses until 31st December 2009. Specific provisions apply.

4.3

Those involved in handling/decommissioning of halon are required to obtain a minimum qualification standard

4.6

Critical use for aircraft protection is permitted. 4.5

Waste halon should be managed and disposed of in line with Irish and European waste management legislation in order to minimise any potential environmental impact.

3.0/5.0

Those continuing to use halon for critical use must maintain accurate records of use

6.0

Alternatives are available for replacement of halon. Critical users should actively investigate suitable available alternatives

7.0

Further details are provided in the main body of the Guidance Note.

1 Critical uses of halon allowed under the Regulation refer mainly to use for fire protection in civil

aviation and military uses, as well as the oil, gas and petrochemical sector and in existing cargo

ships and use by fire brigades.



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1. INTRODUCTION

The stratospheric ozone layer acts as a protective barrier or ‘natural sunscreen’ in the upper atmosphere, preventing harmful ultraviolet radiation from reaching the earth’s surface. Research during the 1970’s and 1980’s identified a hole in this ozone layer at certain times of the year above the Antarctic, with CFCs (chlorofluorocarbons) being identified as the cause of the depletion of stratospheric ozone. In addition to CFCs a range of other Ozone Depleting Substances (ODS) were identified as contributing to the depletion of the ozone layer. Through the United Nations Environment Programme (UNEP) a Global Convention was developed to protect the ozone layer, eventually resulting in the development of the Montreal Protocol in the late 1980’s. Regulation (EC) No. 2037/2000 on substances that deplete the ozone layer is the European response under the Montreal Protocol. The Protocol is under constant review and amendments are agreed under the auspices of the United Nations (UN). Ireland has ratified all amendments.

Regulation (EC) No. 2037/20002 established rules for the production, import, export, placing on the market, use, recovery, recycling, reclamation and destruction of substances, referred to as controlled substances, that deplete the ozone layer. This covers a range of substances including:

• Chlorofluorocarbons (CFCs);

• Hydrochlorofluorocarbons (HCFCs);

• Halons,

• Hydrobromofluorocarbons (HBFCs);

• Methyl Bromide;

• 1,1,1-Trichloroethane;

• Bromochloromethane

• Carbon Tetrachloride.

These substances are mostly used in refrigeration, air-conditioning (including heat pump equipment), fire suppression and pest control. Furthermore, some ODS are used as solvents, aerosol sprays and blowing agents. The Regulation prohibits CFCs, halons, 1,1,1 trichloroethane, carbon tetrachloride, HBFCs, BCM and methyl bromide (with some exceptions). In addition, gradual phase-out and a medium term ban on HCFCs is introduced.

While Regulation 2037/2000 is directly binding on all Member States, certain provisions of the Regulation are further implemented in Ireland by the Control of Substances that deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of

2 A copy of the Regulation and other relevant information can be downloaded from the Commission’s

website at: http://ec.europa.eu/environment/ozone/index.htm



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2006). These Regulations officially designate the Environmental Protection Agency as competent authority, while the Department of Agriculture and Food, the Revenue Commissioners (Customs) and the Department of Transport (Maritime Safety Directorate) are each designated as competent bodies. A copy of the Regulations is can be downloaded from www.ozone.ie.

A series of Guidance Notes has been produced to cover the range of controlled substances and their uses. This Guidance Note focuses on the main uses in Ireland in relation to halon use in the fire protection sector.

2. USES OF HALONS

The term ‘Halon’ is a shortened form of halogenated hydrocarbon. Halons have been extensively used as fire suppressants in fire extinguishers and halon flooding systems. Small amounts of halons have also been used as components of solvents and pesticides.

Table 1 provides an overview of the halons controlled under Regulation (EC) No. 2037/2000.

Table 1 Halons Controlled under EC No. 2037/2000

Halon Chemical Formula

Trade name

Atmospheric lifetime (years)

Ozone Depleting Potential3

Halon-1211 CF2BrCl BCF 16 3.0

Halon-1301 CF3Br BTM 65 10.0

Halon-2402 C2F4Br2 20 6.0

Halon-1011 CH2BrCl 0.37 0.12

Key characteristics of halons include:

• They are non-conductive, which makes them ideal for use with electrical and electronic equipment;

• They do not leave a residue, thereby minimising damage to equipment;

• They act very quickly in suppressing a fire; and

• They can be used in occupied spaces as their toxicity is low (halon 1211 is reported to be more toxic than halon 1301 hence halon 1301 is normally used in occupied spaces).

3 ODP scale is based on an ozone depleting potential for CFC-11 (chlorofluorocarbon) of 1.0.



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Halons are used in both fire suppression flooding systems and hand held extinguishers. Halon fire suppression systems have been commonly used in:

• Electronic and electrical cabinets, and computer rooms;

• Aircraft engine nacelles and dry bays;

• Turbine or engine compartments, etc.

Halon 1301 is typically used as a flooding agent in occupied spaces due to its low toxicity to humans (at recommended concentrations). Halon 1211 can also be used in flooding systems but is more commonly used in hand held extinguishers. Contact with the fire protection sector indicated that Halon 1301 was the only halon known to be used in flooding systems in Ireland, while Halon 1211 was employed in portable fire extinguishers. Alternatives to halons are discussed in Section 7.

3. ENVIRONMENTAL IMPACT

Halons are referred to as ozone depleting substances (ODS), because once such gases are released into the environment and reach the stratosphere, they interact with ozone and destroy ozone molecules. Some ODS can have lifetimes in the stratosphere of hundreds of years, though in the case of halons the reported atmospheric lifetime is up to 65 years (see Table 1). A molecule of halon gas has the potential to destroy ozone molecules during its entire lifetime. Various ODS are assigned Ozone Depleting Potentials (ODP) depending on their potential4 to cause ozone depletion in the stratosphere (see Table 1).

Ozone is a gas composed of three bonded oxygen atoms (O3). In the Earth’s atmosphere, ozone is formed from molecular oxygen (O2) in the reactions initiated by UV light. Ozone can be found in two levels, at ground level and in the Earth’s upper atmosphere, referred to as the stratosphere. At ground level, ozone is a significant air pollutant, forming smog. In the stratosphere it is referred to as the ozone layer. The ozone layer encircles the stratosphere at approximately 10 km above ground level. It filters ultraviolet (UV) radiation reducing the amount of radiation reaching ground level.

The depletion of the ozone layer exposes living organisms to high levels of the harmful UV-B radiation. Most importantly, this negatively impacts human health causing increased occurrence of skin cancers, cataracts and weakened immune system. Other negative impacts of depletion of the ozone layer are:

• High levels of UV-B radiation causes sunburn and can potentially damage DNA,

• Changes in plant growth,

4 ODP scale is based on an ozone depleting potential for CFC-11 (chlorofluorocarbon) of 1.0.



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• Degradation of building materials, particularly paints, rubbers, woods and plastics.

While many ozone depleting substances also have potential health and safety impacts the objective of the Regulation and of this Guidance Note relates to the potential for depletion of the ozone layer due to release of these compounds. The most significant ozone layer depletion occurs over Antarctica, where the ozone concentration is approximately 30% of its pre-1970s concentration. Ozone concentration is still decreasing, but at a lower rate since implementation of the Montreal Protocol in 1989. It is estimated that the ozone layer above Antarctica will recover after 2050. Further information on ozone depletion and international action is available from the United Nations Environment Programme website (http://ozone.unep.org/index.asp).

4. IMPACT OF REGULATIONS

4.1. Implementation

Under the Control of Substances that Deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of 2006), the Environmental Protection Agency is the designated competent authority for implementation and enforcement of Regulation 2037/2000. Three competent bodies have also been assigned official responsibility under the Regulations: Department of Agriculture and Food, the Revenue Commissioners (Customs Division) and the Maritime Safety Directorate.

Specific requirements, such as minimum qualifications, have also been introduced in Ireland under the Control of Substances that Deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of 2006). This is discussed further in Section 4.5.

4.2. Phase-out Dates

Under the Montreal Protocol Halon 1301, Halon 1211 and Halon 2402 production was required to have ceased by 31st December 1993.

Under the Regulation (EC) No. 2037/2000 all use5 and sale of halon fire-fighting equipment for non-critical users is prohibited from 31st December 2002. This includes recovered and recycled halons and is applicable to hand-held fire extinguishers in vehicles and buildings. All halon fire-fighting equipment should have been decommissioned by December 31st 2003. Following decommissioning, all halons must be recovered for storage for critical uses or destruction. Guidance on the decommissioning of obsolete halon systems and halon waste management and is presented in Section 5 and Appendix B and C. Table 2 lists the phase-out dates for halon-containing equipment.

5 Use is defined as “the utilisation of a substance in the production or maintenance, in particular

refilling, of products or equipment or in other processes except for feedstock and processing agent

uses”.



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Table 2 Halon equipment phase-out dates

Date Action

31st December 1993 Halon 1301, Halon 1211 and Halon 2402 production ceased.

31st December 2002 Use and sale of Halon fire-fighting equipment for non-critical users is prohibited.

31st December 2003 All Halon fire-fighting equipment for non-critical users should have been decommissioned.

31st December 2009 Export of recovered, recycled and reclaimed halon stored for critical uses prohibited6.

The only legitimate use of halon now remaining is the critical uses listed in Annex VII of Regulation 2037/2000.

Contact with industry indicates that non-critical halon fire protection systems may be still in use beyond the decommissioning deadline. These must be decommissioned immediately according to Article 4(4)(v) and Article 16 of the Regulation. Failure to decommission such systems may result in prosecution. A range of alternatives are available and are discussed in Section 7.

4.3. Import and Export

Import and export in the context of Regulation (EC) No. 2037/2000 refers only to trade with non-EU countries and does not refer to movement of ODS within the European Community. The shipment of waste ODS within the EU is governed by other national and EU legislation. Figure 1 illustrates the relationships in the ODS import and export reporting requirements etc. The import and export of ODS is subject to strict limitations as detailed in the Import and Export Declaration documents which can be downloaded from the Commission ODS website at: http://ec.europa.eu/environment/ozone/ods.htm.

The import and export of the majority of ODS is effectively prohibited, with limited exceptions for authorised essential uses, use as a feedstock or processing agent, and import for destruction (this is not applicable for Ireland as no destruction facilities are available in Ireland). The import and export of equipment and products containing ODS is also severely restricted. Imports are allowed for authorised essential uses. Products and equipment shown to be manufactured

6 The European Commission may decide to prohibit such exports before this time on completion of

an export review in January 2005.



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prior to the entry into force of the Regulation (i.e. before 1 October 2000) are not subject to import prohibitions.

The export prohibition does not apply to halons exported for critical uses if obtained from recovered, recycled and reclaimed halons stored in facilities authorised or operated by the Competent Authority until 31 December 2009. However, the European Commission export authorisation procedures for ODS must be followed.

Further limitations are applicable to trade with countries which are not party to the Montreal Protocol, with trade only being allowed under very limited circumstances.

The import and export of ODS into/out of the European Community require authorisation from the Commission under Regulation (EC) No. 2037/2000. Import Licenses and Export Authorisation Numbers can be obtained via the Commission’s ODS website by following the correct procedures. It is the responsibility of the importer/exporter to apply to the Commission via their website http://europa.eu.int/comm/environment/ozone/ods.htm. All correspondence with the Commission should be directed to:

Ozone Layer Protection European Commission Directorate - General Environment Unit ENV.C.2 – Climate Change B 1049 Brussels Fax: + 32 22 99 8764

Email: [email protected]

Where an import request is approved, a copy of the import licence will be sent to the Competent Authority of the Member State. Similarly, for authorised exports from the EU, the exporter is issued with an Export Authorisation Number (EAN). Exports cannot be carried out without an EAN issued by the Commission. Applications for import and export authorisation must be renewed on an annual basis. Importers and exports are required to report annually to the Commission according to Article 19 of Regulations 2037/2000, with specified data on import and export of methyl bromide. A copy of the report must be submitted to the Environmental Protection Agency:

Ozone Depleting Substances Office of Licensing and Guidance Environmental Protection Agency P.O. Box 300 Johnstown Castle Estate Co. Wexford Or via e-mail to [email protected]



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In addition, stamped used licence documents (import licences and export authorisation numbers) must be provided to Customs (www.revenue.ie) at the point of import or export. Further guidance on import and export procedures can also be obtained from Customs.

It is recommended that any person wishing to carry on trade of ODS or ODS containing equipment with countries outside the European Community should carefully consult the Regulation 2037/2000 and S.I. No. 281 of 2006 and the guidance provided on the Commission ODS website prior to making an application to the Commission.

It should also be noted that the Regulation 2037/2000 prohibits the transportation of all ODS in disposable containers, except for essential uses.



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Figure 1 Guidance for importers and exporters

Information for Art

20(3) report

Environmental

Protection Agency

Customs

European Commission

Copies of import licences and export

authorisations

Copies of import licences and export authorisations and Art 19(1) and 19(3)

reports

Importers & exporters

Report under Article 19(1) and 19(3) (copy to EPA)

Issue import licences and

export authorisations

Stamped used licence documents

(import licenses and export

authorisations)

Copy

1. Declare intent to import or export

2. Request import licence or export

authorisation

Used licence documents

(import licenses and export

authorisations)



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4.4. Supply and Use of Ozone Depleting Substances

Critical Users

Annex VII of Regulation 2037/2000 defines those critical halon uses which are currently permitted. However, it should be noted that this list is currently being revised by the Commission and it is likely that end-dates for critical use exemptions will be introduced. Critical uses identified in Ireland are:

Halon 1301

• In aircraft for the protection of crew compartments, engine nacelles, cargo bays and dry bays, and fuel tank inerting.

Halon 1211

• In hand-held fire extinguishers and fixed extinguisher equipment for engines for use on board aircraft.

• In aircraft for the protection of crew compartments, engine nacelles, cargo bays and dry bays.

• In fire extinguishers essential to personal safety used for initial extinguishing by fire brigades.

• In military and police fire extinguishers for use on persons.

The Department of Communications, Marine and Natural Resources issued a Marine Notice (Marine Notice No. 38) in 2003 to all owners, masters, skippers, surveyors, shipyards, boatyards and repairers of ships and fishing vessels7. This indicated that the Department was not aware of any Irish vessels to which the critical use exemptions allowed under the Regulation would apply and has therefore urged all vessels to comply with the requirements of the Regulation by decommissioning halon systems. Any halon systems or halon-containing fire extinguishers remaining on ships or other vessels should therefore be decommissioned immediately.

Any critical users who have not been contacted by the EPA in relation to the Regulation should contact the EPA as soon as possible.

The Regulation requires that all precautionary measures practicable are taken to prevent and minimise leakages of halons. This requires an effective maintenance and inspection programme, perhaps in conjunction with leak detectors. Such detectors identify increased halon concentrations in a given space. Personnel involved in handling halon are required to meet minimum qualification requirements. This is further discussed in Section 4.5.

Critical users must estimate their future needs and arrange for procurement and storage of appropriate volumes of halons. The EPA, as competent authority for

7 Responsibility for this sector is now under the remit of the Department of Transport.



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implementation and enforcement, must report annually to the Commission, under Article 4(4)(iv) of the Regulation, detailed information in relation to the quantity of halon installed and stored for critical uses. Critical users in Ireland must report this information to the EPA on an annual basis. This is further discussed in Section 6.

There are currently no halon banks in Ireland. However critical users may be able to source halons from surplus stocks in storage by other critical users in Ireland or by direct contact with the fire sector that may be carrying out decommissioning of halon systems of extinguishers.

The Halon clearing houses that were set up in the past outside Ireland for the movement of halon stocks appear now to be inactive. These clearing houses were as follows:

• Halon Users National Consortium (HUNC – www.hunc.org);

• United Nations Environment Programme Halon Trader web portal – www.halontrader.org;

There are currently no commercial facilities in Ireland for the recycling or reclamation of Halons. Recovery of halons from fire protection systems for use in critical use systems should only be carried out by suitably qualified personnel to minimise the potential for inadvertent halon release to the atmosphere. Refer to Section 4.6 below on Training and Minimum Qualifications.

General guidance and best practice measures for decommissioning of halon systems is presented in Appendix B. This is taken from the UNEP publication: Eliminating Dependency on Halons – Self-Help Guide for Low Consuming Countries.

Non-Critical Users

All non-critical halon flooding systems and extinguishers should be immediately decommissioned by qualified personnel (see Section 4.6). Use of halon other than for critical used outlined in Annex VII of the Regulation8 is an offence under the Control of Substances that Deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of 2006) and may lead to prosecution.

Those requesting a fire systems contractor to decommission an installed flooding system should ensure that the contractor has obtained the minimum qualification as outlined below and that the decommissioned halon is either taken by a critical user or is sent for destruction according to Article 16 of the Regulation and in compliance with national and European waste legislation. Under no circumstances should halon from decommissioned systems be released to atmosphere

8 Use as feedstock or as a processing agent is also permitted but such uses are considered unlikely in

Ireland.



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4.5. Training and Minimum Qualifications

The minimum qualification for persons whose business or employment involves the installation, servicing, maintenance, dismantling or disposal of fire protection systems and fire extinguishers, in which controlled substances are used is the British Fire Protection Systems Association Competence Certificate Course Class 1, or equivalent9. This requirement is made mandatory by Article 9 of the Control of Substances that Deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of 2006), addressing Article 16 of Regulation 2037/2000.

This course was developed by the British Fire Protection Systems Association10 to address Regulation 2037/2000 following its publication. The course took place in Dublin in April 2007 and a small number of companies and personnel are now appropriately qualified in Ireland.

In addition, there are two Irish Standards which are applicable to this sector and should be taken into account by operators when hadling halons:

• I.S. EN 27201-2:1994. Fire Protection – Fire Extinguishing Media – Halogenated Hydrocarbons – Code of Practice for Safe Handling and Transfer Procedures;

• I.S. EN 27201-1: 1994: Fire Protection – Fire Extinguishing Media – Halogenated Hydrocarbons – Part 1: Specifications for Halon 1211 and 1301.

General guidance and best practice measures for decommissioning of halon systems is presented in Appendix B. This is taken from the UNEP publication: Eliminating Dependency on Halons – Self-Help Guide for Low Consuming Countries.

5. ODS WASTE MANAGEMENT

Detailed guidance on management of waste ODS is provided in Appendix C, while a general introduction is provided in this section.

Halons can only be destroyed by approved methods, for example liquid injection incineration. There are currently no facilities in Ireland for the destruction of halons. However, cylinders can be exported for destruction or recovery in accordance with the existing EU and national legislation.

The fire protection company decommissioning the system is typically able to arrange for disposal of halons via a waste management contractor. Decommissioning and transport of cylinders should only be carried out by qualified personnel. Valve protection caps should be employed while the cylinders are in transit to minimise the potential for accidental release of the

9 Any decision on equivalent qualifications will be made by the Environmental Protection Agency.

10 Now known as the Fire Industry Association, following the merger of the British Fire Protection Systems

Association and the Fire Extinguisher Trades Association. Refer to http://www.fia.uk.com/ for further information.



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cylinder contents, as the high storage pressure means that accidental release from a cylinder can result in the cylinder acting as a ‘projectile’.

Waste ODS, including waste halons (and also, potentially, used ODS containers) are considered a hazardous material and are subject to the requirements of the relevant EU and Irish waste management legislation including:

• Waste Management Acts 1996 to 2008;

• Waste Management (Hazardous Waste) Regulations 1998;

• Waste Management (Movement of Hazardous Waste) Regulations, 1998;

• Waste Management (Shipment of Waste) Regulations, 2007;

• The Carriage of Dangerous Goods by Road Regulations, 2001;

• Waste Management (Collection permit) Regulations, 2007;

• Waste Management (Collection Permit) (Amendment) Regulations, 2008;

It is important to note that the legislative references detailed in the text are subject to ongoing review both at EU and national level and may change in time.

For movement of hazardous waste within Ireland, the movement of the waste must be recorded by means of a consignment note, known as a C1 form (which are obtained from local authorities).

Export of hazardous waste is subject to Transfrontier Shipment (TFS) requirements. Dublin City Council operates the National TFS Office, which can be contacted as follows:

Dublin City Council

National TFS Office

Eblana House

68-71 Marrowbone Lane

Dublin 8

Administration Department

(01) 222 4411

(01) 222 4601

(01) 222 4634

(01) 222 4249

Technical Department

(01) 222 4374

(01) 222 4235

(01) 222 4467

Fax: (01) 411 3440

Email: [email protected]

Web: www.dublincity.ie

The collection and movement of waste, returned and recovered halons (and other fire suppression agents that are either ozone depleting substances or fluorinated greenhouse gases) is subject to requirements outlined in the Collection Permit Regulations. Special provisions have been made to allow the collection and movement of halons either by waste collection permit holder or by a person that has submitted a Prior Annual Notification to the EPA. Refer to the EPA website for further information on waste ODS collection: www.ozone.ie.



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Prior Annual Notifications must be made to the EPA, providing information specified in the Fifth Schedule of the Regulations, and can only be made where the following conditions are met:

• the activity is incidental to the main business

• the activity is small-scale, leading to environmentally beneficial

operations

• the quantity transported does not exceed 2 tonnes

• no mixing of different gases occurs

• the material is brought to an authorised facility11

• handling and transport should prevent venting or leakage

• the material is recycled or destroyed according to relevant

requirements

The movement and disposal of hazardous waste is a relatively complex and specialised area, and it is therefore recommended that the services of a licensed hazardous waste contractor is employed to dispose of any consignments of hazardous waste. A list of licensed contractors is available on the Irish EPA website at www.epa.ie (A search facility for waste licences is available on the home page).

Upon ultimate disposal of the waste a certificate of disposal will be issued to the producer of the waste. A copy of all waste documentation (e.g. C1 forms, TFS documents) should be kept by the producer of the waste and maintained (along with other related waste documentation) for a minimum of 7 years.

6. REPORTING REQUIREMENTS

Producers, Importers and Exporters

Producers, importers and exporters of ODS are required to report annually to the Commission, according to the requirements set out in Article 19 of Regulation 2037/2000, copying any such report to the Environmental Protection Agency. There are no known halon producers in Ireland and its use is now limited to a relatively small number of critical use applications.

Critical Use

11 An authorised facility is a facility that has been granted an waste/site authorisation in the form of a waste

licence, a waste facility permit or a certificate of registration



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The EPA, as competent authority, is also required to submit annual reports to the Commission on critical use of halon in Ireland under Article 4(4)(iv) of the Regulation. To this end, the EPA conducts an annual survey of the critical users to gather this information and prepare the annual report. An example of the reporting table required to be submitted to the EPA is included in Appendix D to this Guidance Note.

Operators in the Fire Protection Sector

There are also specific reporting requirements for the EPA in relation to reporting annually to the Commission on the quantity of controlled substances recovered, recycled, reclaimed or destroyed. To this end, the EPA conducts an annual survey of operators in the fire protection sector in Ireland to gather information on halon decommissioned from fire protection systems and extinguishers in the preceding calendar year, if any.

7. SUMMARY OF ALTERNATIVES

Alternatives to halon fire extinguishers and flooding systems are available. However, the choice of alternative depends on many factors such as the type of hazard, the characteristics of the alternative method (e.g. ability to extinguish solid and/or liquid fuel fires), and the risk assessment of use. The toxicity of the alternative method should also be considered if there is potential for human exposure.

Contact with the fire sector in Ireland indicated that FM200 (a trade name for HFC227ea) is the most popular replacement for Halon 1301 in flooding systems. Nitrogen flooding systems have also been installed in some cases. Controls on the use of HFCs have recently been introduced by European legislation on certain fluorinated greenhouse gases12.

The European Commission (2000) recommended that alternatives be selected on the basis of lowest possible environmental impact consistent with personnel safety, speed of suppression, volume, weight and cost for protecting life and the environment from fire.

Information on alternatives is available on the Commission’s website: http://ec.europa.eu/environment/ozone/alternatives.htm. A summary of alternatives for fixed systems and portable fire extinguishers is provided in Appendix A to this Guidance Note.

8. ENFORCEMENT AND PROSECUTIONS

The Environmental Protection Agency has been officially designated as competent authority for the implementation and enforcement of Regulation (EC) No. 2037/2000 by Article 6 of the Control of Substances that Deplete the Ozone

12 Regulation 842/2006 on certain fluorinated greenhouse gases.



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Layer Regulations 2006 (S.I. No. 281 of 2006). In addition, supporting roles have been assigned to three competent bodies as follows:

• Department of Agriculture and Food

• The Revenue Commissioners

• The Maritime Safety Directorate

With the support of relevant competent bodies, the EPA will continue, and expand where necessary, its current contacts with the fire protection sector with the view to ensuring compliance and gathering data to meet reporting requirements.

Any breaches of the Regulation will be regarded seriously by the Agency and the competent bodies. Prosecution is provided for under Article 12 of the Control of Substances that Deplete the Ozone Layer Regulations 2006 (S.I. No. 281 of 2006).

9 SOURCES OF INFORMATION

Competent Authority - Environmental Protection Agency

Ozone Depleting Substances

Office of Licensing and Guidance

Environmental Protection Agency

PO Box 3000

Johnstown Castle Estate

Co. Wexford

Phone: 053 9160600

Website: www.ozone.ie

Government Body - Department of the Environment, Heritage and Local Government

Air/Climate Section

Department of the Environment, Heritage and Local Government

Customs House

Dublin 1

Phone: 01 8882000

Website: www.environ.ie/en/Environment/Atmosphere/ProtectionoftheOzoneLayer/



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Competent Bodies –

Department of Agriculture and Food

Pesticide Control Service

Department of Agriculture and Food Laboratories

Backweston Campus

Young's Cross

Celbridge

County Kildare

Phone: 01 6157552

www.pcs.agriculture.gov.ie/

Forest Service

Department of Agriculture and Food

Agriculture House

Kildare Street

Dublin 2

Phone: 1 6072000

www.agriculture.gov.ie/index.jsp?file=forestry/pages/index.xml

Revenue Commissioners (Customs Division)

Office of the Revenue Commissioners International and Trade Security Branch Customs Division Nenagh Co. Tipperary Phone: 067 63400 Website: www.revenue.ie Maritime Safety Directorate

Maritime Safety Directorate Department of Transport Leeson Lane Dublin 2 Phone: 01 6786400 Website: www.transport.ie/marine/MaritimeSafetyDirectorate/index.asp?lang=ENG&loc=1933

Other Useful Contacts

Fire Engineering Systems Association

Fire Engineering Systems Association Ltd. 8 Willbrook Road Dublin 14 Website: www.fesa.ie National Standards Authority of Ireland

Glasnevin Dublin 9 Phone: 01 8073800 Website: www.nsai.ie



Rev 02

Useful Websites

• www.uneptie.org/ozonaction/

• http://ozone.unep.org/

• http://ec.europa.eu/environment/ozone/index.htm

• www.euro.who.int/globalchange/topics/20020627_1



Rev 02

Appendix A - Alternatives to Halons


Environmental Protection Agency 20

Table A1: Summary of the Existing Alternatives for Fixed Halon Systems

The information in the table below is taken from the following publication which was published in 2001.

Information provided should therefore be taken only as a guide and a thorough investigation of

alternatives should be undertaken prior to choosing an alternative.

• United Nations Environment Programme, 2001. Standards and Codes of Practice to Eliminate Dependency on Halons.

ALTERNATIVE ADVANTAGES DISADVANTAGES

Halocarbons. Alternatives include

HCFCs, HFCs and PFCs. FM200,

a common replacement for Halons

in Ireland is a trade name for HFC

227ea.

Electrically non-conductive;

Clean agents (no residue);

Can be stored and discharged from

fire protection systems that are

similar to that used for Halon 1301.

All (except CF3I) are less efficient fire

extinguishers than Halon 1301 in terms of storage

volume and weight, hence the use of these

agents requires increased storage capacity;

All (except CF3I) produce more decomposition

products (primarily HF) than Halon 1301;

Are more expensive than Halon 1301;

Use of HCFCs as a Halon replacement in fire

protection systems is limited under the

requirements of Regulation (EC) No. 2037/2000

(such as the HCFC supplier must cover 70 % of

the destruction costs) under Article 5(3). The

commission therefore expects that use of HCFCs

as alternatives to Halons in the EC will be

negligible (European Commission, 2000);

HFCs and PFCs are greenhouse gases and are

regulated under the Kyoto Protocol and will also

be regulated under the proposed ‘Regulation of

the European Parliament and of the Council on

Certain Fluorinated Greenhouse Gases,

COM(2003)492 Final’.

Inert Gases. Common inert gases

used in fire protection systems

include: Nitrogen; Argon;

Nitrogen/argon blend; and

Nitrogen/argon/CO2 blend.

Electrically non-conductive;

‘Clean’ fire suppressants (i.e. no

residue);

Are not subject to thermal

decomposition and hence form no

by-products;

Have no global warming or ozone

depletion properties.

Are stored as high pressure gases. This results

in increased storage volume requirements, health

and safety requirements and increased weight;

Discharge time for these systems is of the order

of 1 – 2 minutes. This may limit some

applications involving very rapidly developing

fires;

Some concerns in relation to reduced oxygen

concentration when these gases are released in

occupied spaces.

Fine Water Mist. This technology

involves the release of water in

small droplets (10 – 200

nanometres). Types of system

include:

Single fluid systems (i.e. water

only) at low – moderate pressure (3

Water application rates are

approximately 100 times less than

conventional sprinkler systems. The

mists do not conduct electricity as

readily as solid water streams and

hence can be considered for use on

electrical equipment;

Do not always guarantee extinguishment of fires.

Small obstructed fires may require response team

intervention;

The droplet size must be sufficiently small to

ensure adequate distribution and of water

throughout the compartment;

These systems are still relatively new and have




– 50 bar);

Single fluid systems at high

pressure (> 50 bar);

Dual fluid systems (which use

nitrogen or another gas to atomise

water at the nozzle).

Reasonably weight efficient;

Reported to be safe for use in

occupied areas;

No ozone depletion or global

warming properties.

not been as rigorously tested or developed as

other traditional systems.

Inert Gas Generators. This

system utilises a solid material

which oxidises rapidly to produce

large quantities of CO2 and/or

nitrogen.

Have been used in military

applications (particularly aircraft)

Have no ozone depletion or global

warming properties

Their use in non-military applications is limited at

presented as further development is required.

Fine Particle Aerosol

Generators. This technology is

still under development. It relies on

the properties of solids particles to

suppress fires, however the

‘collateral’ damage due to use of

these generators would be

considerably lower than traditional

dry powder technologies.

Considered to be a relatively low

cost/low technology technique

Development is still ongoing and at present these

generators are not considered a viable

replacement for Halon systems.

Detection and Manual

Intervention. This involves the

use of highly sensitive smoke

detection and aspiration systems,

which allow early detection of the

fire and manual intervention (hand

held extinguishers or hose reels)

before the fire is out of control, or to

minimise fire spread while waiting

for the fire services.

Early detection and intervention

reduces fire damage;

Hand held extinguishers can be

employed which have no ozone

depleting or global warming

potential;

Cheaper than installation of complex

suppression systems, lower

maintenance.

Potentially increase health and safety risk to staff;

If the fire goes out of control, there is no option

but to wait for the fire services to intervene,

unless a manual backup flooding system is

available;

Use of some portable extinguishers can result in

significant collateral damage (e.g. use of water on

electrical equipment);

This methodology is suitable only for a certain

types of hazard and should be examined carefully

in terms of the types of fires that are likely to

occur in a given application.

Can be a significant change where previous

methods have involved automatic fire

suppression systems.

Water Sprinklers. Traditional

water sprinkler systems are

commonly employed in Ireland in a

number of different types of

applications. These systems

simply release a deluge of water to

extinguish the fire.

Systems are very reliable and are

highly unlikely to discharge

accidentally. They can also be

designed to activate only after two

separate detection systems have

been activated, thus further reducing

the potential for accidental releases;

Systems have been proved effective

in extinguishing fires, but the

potential types of fires should be

examined carefully as not all fire

types are effectively extinguished

(see disadvantages).

Not ideally suited for use on live electrical

equipment, flammable liquid fires, or in any area

where materials may react violently with water;

Systems are likely to result in significant water

damage to equipment, however this must be

weighed against the potential damage which

would result from an unhindered fire;

Fires which occur in enclosed spaces such as

computer or electrical cabinets may not be

effectively extinguished unless a nozzle is

installed in the enclosed area.




Carbon Dioxide. This method

involves flooding the area with CO2

gas to extinguish the fire and has

been successfully employed for a

number of years in varied

applications. Suitable applications

include:

Telecommunications facilities;

Computer and control rooms;

Transformer rooms, switchgear

rooms and machinery spaces;

Record storage and cultural

heritage facilities;

Flammable liquid hazards;

CO2 is a ‘clean’ fire suppressant;

CO2 gas is electrically non-

conductive;

CO2 gas has good penetration into

obstructed areas.

CO2 is toxic and an asphyxiant, and so should not

be used in occupied spaces, or should be locked

off when protected spaces are occupied. CO2 is

also odourless and so malfunctions may not be

detected.

CO2 is stored at high pressure. High

concentrations are required to ensure effective

fire suppression. This has storage volume and

weight implications for the design of suppression

systems;

CO2 is controlled under the Kyoto Protocol as it is

known to cause global warming.

Foam Systems. These systems

operate by forming a barrier

between the fire and the supply of

oxygen as well as having a cooling

effect. Different types of foam

include low, medium and high

expansion foams.

Low/medium expansion foams are

most suited to liquid pool fires, while

high expansion foam is more suitable

as a flooding agent for areas such as

document storage facilities;

May be capable of being delivered

through traditional water sprinkler

equipment, thus increasing the

extinguishing efficiency;

No ozone depleting or global

warming potential.

Risk of suffocation if discharge occurs in occupied

areas;

Not suitable in applications where materials may

act violently with water as the foam solution

contains water;

Care must be taken in selection of the foam

agent, as certain liquids (such as alcohols) can

destroy some foam blankets;

May not be effective in extinguishing fires in

enclosed spaces such as cabinets unless a

dedicated nozzle is installed in these areas.

Dry powder systems. Operate by

releasing powder onto the fire to

prevent oxidation thus

extinguishing the fire. Different

types of dry powder systems are

available including:

Formulations based on sodium

bicarbonate are suitable for fires

involving flammable liquids and

gases;

Multipurpose dry powder systems

are based on formulations of

ammonium dihydrogenphosphate

and are also suitable for use on

fires involving ordinary

combustibles such as wood or

paper in addition to flammable

liquids and gases.

Electrically non-conductive and

hence can be used safely in areas

containing electrical equipment;

No ozone depleting or global

warming potential.

Residues are left after application of dry powders;

As mentioned above, some dry powders may not

be suitable for all fires. The types of powder

being used should be examined closely;

Powders are ineffective once the powder has

settled;

Some powders exhibit toxic effects. This should

be investigated prior to release in occupied areas.

The release of powders will also obscure visibility.



Table A2: Replacement Agents in Portable Extinguishers

The information in the table below is taken from the following publication which was published in 1999.

Information provided should therefore be taken only as a guide and a thorough investigation of

alternatives should be undertaken prior to choosing an alternative.

• United Nations Environment Programme, 1999. Eliminating Dependency on Halons: Self Help Guide for Low Volume Consuming Countries

Type Ordinary

Combustibles

Flammable

liquids

Electrically

non-conductive

Ability to permeate

concealed spaces

Stream

Range

Effective

Weight

Secondary

Damage

CO2 Poor Fair Yes Good Fair Poor Good

Dry Powder Good Good Yes Fair Very Good Good Poor

AFFF Good Fair No Poor Good Poor Poor

Water Stream Good Ineffective No Poor Good Poor Poor

Water Fog Good Fair Yes Fair Fair Fair Fair

Halocarbons Good Good Yes Good Good Good Good

Halon 1211 Good Good Yes Good Good Good Good



Appendix B - Safety in Halon Decommissioning



The guidance presented below is taken from the UNEP publication: Eliminating

Dependency on Halons – Self-Help Guide for Low Consuming Countries, which

was published in 1999. Information provided should therefore be taken only as a

guide and only appropriately trained technicians should attempt to decommission

halon system.

B.1 Introduction

Decommissioning is the process of removing a halon system from service. This

must be done in order to recover the halon so it can be made available for other

uses. As a logical and natural outcome of the decision to phase-out production in

Non-Article 5(l) countries, the rate at which halon systems are being

decommissioned is increasing around the world. This is because recycled halon

is now the only source for the remaining Essential Uses in Non-Article 5(l)

countries, and in most Article 5(l) countries as well. Because safety is such an

important aspect of decommissioning, it is becoming a more significant issue for

the fire protection industry as more systems are being removed so their halon

can be used elsewhere.

Halons are pressurised gases. Therefore, the cylinders containing them are

under pressure and must be handled with great care. If the pressure is released

in an uncontrolled way, the cylinder will become a projectile and can cause

serious injury or death to people working on the cylinder, or to bystanders. It is of

utmost importance that proper safety procedures be followed at all times when

handling halon cylinders. There are basically two ways halon bottles can become

dangerous. One is by damaging the valve and the other is to activate the

discharge mechanism. It can be easy to accidentally activate these bottles, and

cause serious injury or death. In Canada last year, a service technician was

killed while preparing to remove halon from a cylinder. His death occurred

because proper safety procedures were not being followed. In the US, the Fire

Suppression Systems Association (FSSA) has received a number of reports of

incidents involving cylinders that accidentally discharged in an uncontrolled way

when they were being removed from service or during handling. In all cases, the

cause was improper handling of the cylinders by untrained and unqualified

people.

Today, the remaining needs for halons in all Non Article 5(l) countries, and most

Article 5(l) countries is being met with recycled halon. This halon becomes

available to the market when an owner of a halon system removes the system

from service and makes the halon available to another buyer. Before the phase-

out when halon was widely available, halon systems were decommissioned at a

much slower pace than is occurring today. With the process taking place so

much more frequently, the temptation to hire untrained and inexperienced people

is increasing. This situation can occur when the market demand for service

professionals exceeds the capacity of the local industry, or because of a need to

acquire halon quickly.

Halon systems components have been manufactured for over 20 years, in many

places around the world, and by many different companies. As a result, many



different types and models of valves and activation mechanisms are installed on

halon cylinders. Because of this, it can be difficult to know exactly how a

particular valve mechanism works, or the proper procedures for safe

decommissioning. This can even be true for professionals who may not have

encountered a particular design before. Ideally, the people who decommission a

system should be those who installed and serviced it, however this is not always

possible. In any case, the procedures outlined in the Operations and

Maintenance Manuals, Owners Manuals, Service Manuals, etc., that are

provided by the manufacturer for the specific type of equipment installed must be

followed.

Some of the key steps that would be considered as mandatory in any procedures

manual are detailed below:

B.2 Secure Cylinders

Before any steps are taken to disconnect any piping from a halon cylinder, it

must first be firmly secured to an immovable object. If this is not done, and the

valve becomes damaged, the cylinder could become a projectile. Cylinders

connected to installed systems are usually adequately secured to a system

manifold.

B.3 Disable Actuation Devices

Once the cylinder is firmly secured, the first step in decommissioning is to

disable the actuation devices so the cylinder cannot accidentally fire. The

actuation device triggers the valve to open. The valves holding the pressure in

the cylinder are designed such that when activated, they go from a fully closed to

fully open position instantly, and the cylinder will be fully emptied in

approximately 10 seconds. When this happens, the cylinder depressurises

rapidly. If the cylinder is not safely secured in place when this occurs, it will

become a projectile. This is why the first thing the technician must do when

decommissioning (after securing to an immovable object) is to disable the

actuation mechanism.

Actuation mechanisms can be either electrical, pneumatic or mechanical.

However, simply disconnecting the device from its electrical or pneumatic source

is not enough to deactivate the device. In the case of pneumatic systems, there

is usually a small pin exposed that must be covered with a safety cap. Failure to

do this could result in accidental discharge. On electrically activated valves,

disconnecting the electrical leads to the solenoid valves is acceptable. However,

if the electrical connection is to an explosive initiator, it is very important to

remove the initiator. This is a very important safety practice, because static

electricity can cause the explosive to detonate, firing the valve. These actions

must be taken before any further dismantling is done.

B.4 Install Anti-Recoil Devices

At this point, it is now safe to carefully disconnect any discharge piping from the

discharge port. Immediately upon disconnection of the piping, an anti-recoil



device must be installed. The anti-recoil device prevents the cylinder from

becoming a projectile in the event the cylinder activates or if the valve becomes

damaged. Most fire suppression system cylinders are furnished with valve outlet

anti-recoil devices, and in some cases cylinder protection/safety caps. DO NOT

disconnect cylinders from the piping system, or move or ship the cylinders if the

anti-recoil devices or safety caps are missing.

Obtain these parts from the Distributor or the Manufacturer. These devices are

provided for safety reasons, and must be installed at all times, except when the

cylinders are connected to the piping system, or being filled. All control heads,

pressure operating heads, initiators, discharge heads, or other type of actuation

devices must be removed; and anti-recoil devices or safety caps must be

installed before disconnecting the cylinders from the system piping. Fire

suppression system equipment varies according to manufacturer, therefore it is

important to follow the instructions and procedures provided in the

manufacturer’s manuals. Decommissioning should only be undertaken by

qualified fire suppression system service company personnel.

A safety cap is a device to prevent recoil. It is simply a cap which is secured over

the discharge port to disperse a sudden release of halon and prevent the

cylinder from becoming a projectile. It is important that the caps designed and

manufactured for the specific model of valve be used. This is because the

threads are not standardised, and if the wrong size is used they may not hold the

pressure of the halon release.

If the proper manufacturers caps cannot be obtained, pipe caps, plugs or plate

can be substituted, but must be installed correctly. If pipe caps, plugs or plates

are used, at least four opposing holes must be drilled in the cap, plug or plate so

that in the event of a discharge, the pressure is dispersed in a way that balances

the forces exerted on the cylinder. Anti-recoil device safety caps, plugs or plates

must always be properly installed before handling the cylinders.

B.5 Packing Cylinders for Shipment

Complying with the above safety practices is paramount before removing any

cylinders from the mounting position. Once the safety devices are in place,

cylinders can be moved with relative safety. However, it is always important to

remember that these are high pressure compressed gas cylinders, and must be

handled according to all the safety procedures applicable to any other high

pressure gas cylinder. At this point, with the actuating mechanism removed or

disabled and the anti-recoil device correctly installed, the cylinder may be moved

to the location where the halon will be removed. Sometimes the halon is

removed on site, but usually the cylinders are secured onto pallets or packed in

crates and shipped to a central point.

B.6 Receiving Shipped Cylinders

At the receiving point for the cylinders, there are a number of safety procedures

that must be followed. When opening the shipping container, a “halon sniffer”

should be used to determine if there has been an accidental discharge or



leakage during transit. If there is a reading, people should move away and allow

any heavy concentrations of halon to dissipate.

Technicians should then look carefully at each cylinder to determine which one

of the following devices is present:

• Burst disk/initiator

• Mechanical/cutter valve

• Shraeder valves/pilot check valves

If there is no initiator present and the safety cap is in place, the cylinder may be

safely unloaded and stored.

If the burst disk/initiator valve is present, look for initiators and safety caps and

proceed as follows:

If the initiator and safety cap are both in place, the cylinder may be carefully

unloaded, but the initiator must be disabled immediately by a qualified

technician. It is important not to discharge any static electricity to the initiator or

the initiator wiring during unloading. This could cause the valve to discharge.

If the initiator is in place and there is no safety cap in place, first connect an

electrical ground strap to the cylinder, the vehicle the containers were shipped in,

and the person unloading the cylinder. Then install an anti-recoil device (safety

plug, plug or plate) over the outlet, taking care not to release any static electricity

to the initiator or its wiring. After the anti-recoil device is installed, the initiator

must be immediately disabled by a qualified technician.

If the valve is of the mechanical/cutter type, look for the safety caps/plugs and

proceed as follows:

If the cutter mechanism is removed and the safety cap is in place, or if the cutter

mechanism is in place with a safety cap or plug in place, the cylinder may be

safely unloaded and stored.

If the cutter mechanism is in place and no safety plug is installed, DO NOT

INSTALL A SAFETY PLUG. Make sure the cylinder is secured to a pallet, and is

handled in a safe manner. Cutter valves are activated by a sharp edge which

cuts into the disk sealing the cylinder opening. Be careful that the cylinder and

pallet are not hit hard against anything since this could cause the cutting edge of

the mechanism to cut into the disk and discharge the cylinder. Hold the cylinders

in a safe location until a qualified technician can take action.

If the valve type has a Shraeder core, look for safety caps and proceed as

follows:

• If the safety caps are installed and the release valve or mechanism is

secured, the cylinder may be safely unloaded and stored.



• If the safety cap is not in place and the release mechanism is not

secured, install the appropriate safety caps and secure the release

mechanism before unloading the cylinder.

The procedures for actually removing the halon differ depending on the type of

valve the cylinder has connected. There are many different types, manufactured

by many different companies around the world.

B.7 Measures to Improve the Safety of Decommissioning

The Halons Technical Options Committee recommends fire protection industry

associations, regulatory agencies of government with cognisant authority, and

system manufacturers work together to make sure only qualified people work on

halon systems, and that all necessary literature for the safe decommissioning be

made widely available throughout the industry, anticipating a greater than usual

demand for this information.

Owners of halon systems wishing to make the halon available to other buyers

should first turn to the company that installed the system originally, or the

company which provided service to the system to have the system

decommissioned. If these companies are no longer available, a company with

experience with the specific system should be contacted. HTOC suggests that

the following options might form some appropriate guidelines:

B.7.1 For Consideration by Governments:

Governments which regulate their domestic fire protection industries should be

aware that decommissioning will be taking place much more frequently than they

have in the past. Governments can use the same methods they now use to

communicate regulatory requirements to industry to increase awareness about

the importance of safety during decommissioning, and to distribute technical

information. It would also be prudent at this time to review the adequacy of

existing rules and Regulations governing the qualifications of people who

perform this work and the procedures to be followed, and make adjustments as

necessary.

B.7.2 For Consideration by Halon System Owners:

It is in the interest of the halon system owners that the removal of the system

proceed without incident. Once the decision to sell halon has been taken, the

owner should first determine whether a halon bank is operating in their country.

This information can usually be obtained from the ozone protection, or Montreal

Protocol unit of the national government’s environment ministry, department, or

agency. The halon banking organisation may also be able to locate a buyer,

arrange for testing of the material to protect both buyer and seller, negotiate a

price, and identify companies competent to remove and recycle the halon.

B.7.3 For Consideration by Repository Operators, Halon Recyclers, and

Halon Service Professionals:



Be aware of the increasing pace of halon decommissioning. Develop awareness

and training materials for use by the industry. The guide to different valves and

some of the safety information in this report would serve as a good start to

awareness material targeted to the service professionals. In a number of

countries in which halon banks operate, a surcharge has been placed on the

halon transactions brokered. Such a scheme could finance the development,

publishing and distribution of such safety material for the industry.

B.7.4 For Consideration by All Interested Groups:

The US DOD through their ODS Reserve Program Office has assembled a halon

system valve types and safety issues manual. The ODS Reserve Office has

kindly agreed to make this manual available on a case by case basis to parties

engaged in the decommissioning of halon systems. In addition, they have

volunteered to expand this document as additional technical information is

submitted by other companies, individuals, or fire protection organisations. The

Halon Technical Options Committee would appreciate it if fire protection

professionals reading this report would submit technical information on cylinders,

valve assemblies and actuators not included in this manual so they may be

added to future updates. Please send information and requests for to the

following address:

DOD ODS Reserve (DSCR-RP)

Defense Supply Center Richmond

8000 Jefferson Davis Highway

Richmond, VA 23297-5100

www.denix.osd.mil



Appendix C - ODS Waste Management

Guidance



1. WASTE CLASSIFICATION

Most waste ODS and used ODS containers13

are classified as hazardous substances. Waste

is classified across the EU according to the European Waste Catalogue and Hazardous

Waste List14

. Most of the ODS are covered under the following chapters of the catalogue:

ODS substances (gases, solvents, etc.)

Chapter 07 Wastes from organic chemical processes (this section includes codes

for solvents used in a wide range of organic chemical industries)

Chapter 08 Wastes from the manufacture, formulation, supply and use (MFSU)

of coatings (paints, varnishes and vitreous enamels), sealants and

printing inks

Chapter 14 Waste organic solvents, refrigerants and propellants (except 07 and

08)

For equipment containing ODS

Chapter 16 Wastes from electrical and electronic equipment (including CFC,

HCFC and HFC)

Chapter 20 Municipal wastes (household waste and similar commercial,

industrial and institutional wastes) including separately collected

fractions

The European Waste Catalogue and Hazardous waste list can be downloaded from the

following web site: http://www.epa.ie/whatwedo/resource/nwr/

2.0 COLLECTION AND TRANSPORT OF WASTE

2.1 Waste Collection Permits

In general, waste may only be collected and transported by holders of waste collection

permits. Waste collection permits are granted by local authorities. However, special

provisions have been made in the revised Waste Collection Permit Regulations to allow the

collection of waste, returned or recovered refrigerant gases to be carried on by persons that

have made a Prior Annual Notification to the EPA. Further information is available on

www.ozone.ie.

13 Containers that were used to transport ODS that are now empty or are nominally empty and are to be

disposed of.

14 EPA, European Waste Catalogue and Hazardous waste List (2002) See

http://www.epa.ie/OurEnvironment/Waste/WasteClassificationandCharacterisation/



The special provisions referred to above can only be made by persons meeting the following

conditions:

• the activity is incidental to the main business

• the activity is small-scale, leading to environmentally beneficial operations

• the quantity transported does not exceed 2 tonnes

• no mixing of different gases occurs

• the material is brought to an authorised facility15

• handling and transport should prevent venting or leakage

• the material is recycled or destroyed according to relevant requirements

2.2 Transport of Hazardous Waste within Ireland (C1 form)

The movement of hazardous waste point to point within Ireland must be accompanied by a

C1 form in accordance with the Waste Management (Movement of Hazardous Waste)

Regulations, 199816

. However, a number of exemptions apply, under Article 35 of the

Collection Permit Regulations17

.

In practical terms, the C1 form must be completed at each stage of a journey. The form has

five carbon copies. By the time the shipment is ended, one copy will be with the originator of

the waste, one copy will be with the authorised destination facility, one copy will be with the

local authority that issued the blank C1, one copy will be with the destination local authority

and one copy will be retained by the carrier.

C1 forms may be obtained from the local authority in whose area the waste is collected. For

more information on C1 forms, contact your local authority.

2.3 Export of Waste outside of Republic of Ireland

Any movement of waste from a point within Ireland to a point outside of Ireland is governed by

the EU Transfrontier Shipment of Waste Regulation (1013/2006)18

. For the export of

hazardous waste, a transfrontier shipment (TFS) notification must be made, and

15 An authorised facility is a facility that has been granted an waste/site authorisation in the form of a

waste licence, a waste facility permit or a certificate of registration

16 S.I. No 147 of 1998 Waste Management (Movement of Hazardous Waste) Regulations, 1998

17 S.I. No. 820 of 2007 Waste Management (Collection Permit) Regulations, 2007, amended by S.I. No.

87 of 2008

18 Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on

shipments of waste



authorisation to proceed obtained, prior to the export of waste taking place. No export of

waste should take place without the appropriate authorisations having been received from the

competent authorities in Ireland, the destination country and transit countries19

.

Dublin City council is designated as the National Competent Authority for export, import and

transit of waste shipments under the Waste Management (Shipment of Waste) Regulations

200720

. Further information can be obtained from the National TFS Office in Dublin City

Council: www.dublincity.ie.

A TFS notification is consists of two parts:

1) Notification form, which must be completed before waste is moved. This form

provides all the information necessary to obtain the advance consent of the

competent authorities.

2) Movement Tracking Form, which accompanies the shipment when it is moved. It

provides information on the actual movement of each waste load.

When the waste is received at its destination, the “consignee” issues a certificate of receipt

confirming that the waste has reached its authorised destination. Upon disposal of the waste,

the consignee issues a certificate of disposal confirming that the waste has actually been

destroyed.

3.0 STORAGE, TREATMENT, RECYCLING, DISPOSAL (AUTHORISED FACILITIES)

Waste may only be stored, treated, recycled or disposed of at authorised facilities. Depending

on the type and scale of activity, authorisation may be in the form of an EPA waste licence or

a local authority waste facility permit.

A waste licence is typically required for any facility where hazardous waste is stored, treated,

recycled or disposed of. This will include any transfer station for ODS in the form of packaged

chemical waste, for example, bottles of waste CFC or drums of waste solvent being shipped

abroad for disposal by incineration or other means. A list of all licensed facilities in Ireland

may be found at: http://www.epa.ie/terminalfour/wasteApril/index.jsp

Waste may only be stored, treated, recycled or disposed of at authorised facilities. Depending

on the type and scale of activity, authorisation may be in the form of an EPA waste licence or

a local authority waste facility permit.

19 For example, an export of waste from Ireland to Germany is likely to pass through the Netherlands. In

this case the competent authority of destination will be located in Germany and the competent

authority of transit will be located in the Netherlands.

20 S.I. No. 419 of 2007 Waste Management (Shipment of Waste) Regulations, 2007.



A waste facility permit is typically required for non-hazardous waste recycling facilities. This

typically includes any facility that handles fridges and freezers and general electrical and

electronic equipment. Waste Facility Permits are issued by local authorities.

For specified waste activities, certain facilities can operate under a Certificated of Registration

issued by a local authority or the EPA.

Further information on licensing, permitting and certificates of registration can be obtained

from the EPA website: http://www.epa.ie/whatwedo/licensing/waste/

Before you use any facility for the storage, treatment, recycling or disposal of waste for which

you are responsible, ask for a copy of the facility’s authorisation. If you have any doubts about

the facility, check with the appropriate regulator (EPA or local authority) and do not use the

facility unless you have seen and are wholly satisfied with the authorisation in place.

3.1 Practicalities of Collection, Transport, Storage, Treatment, Recycling and

Disposal

In practical terms, the generator/owner of waste ODS may decide to dispose of the waste in

either of two ways:

1) Recover and transport the waste to an authorised waste facility for storage and

treatment,

or

2) Employ the services of a waste contractor to collect the waste on the owner’s

behalf and transport it to an authorised waste facility.

There are a large number of waste contractors authorised to handle the collection and

transport of hazardous waste. These companies will typically provide a full service and deal

with all authorisation processes for the transport, storage and export of waste.

As above, do not use any waste contractor that cannot provide evidence of waste collection

permits (in respect of any collection and transport of waste) and waste facility permits or

licences (in respect of any facility in Ireland to which the waste will be delivered). If exporting

waste, ensure that the contractor complies with all transfrontier shipment of waste legislation.

If you intend using a waste broker or dealer to handle your waste, you must ensure that the

broker is registered with the National TFS Office. A waste broker arranges to handle,

transport, dispose of or recover controlled waste on behalf of others. Waste brokers include

waste dealers who acquire waste and sell it on21

.

There are also “Duty of a holder of waste” requirements under Section 32 (1) of the Waste

Management Act 1996, that one must be aware of regarding the holding, collection and

movement of waste;

21 S.I. No. 113 of 2008 Waste Management (Registration of Brokers and Dealers) Regulations, 2008



32 (1) “A person shall not hold, transport, recover or dispose of waste in a manner that

causes or is likely to cause environmental pollution”.22

With regards to the storage of waste, The Waste Management Act 1996 defines 'temporary

storage' as the storage of waste for a period not exceeding 6 months. The storage of waste

greater than 6 months would be deemed a waste disposal or waste recovery activity and

would require authorisation from the relevant local authority or the EPA.

Note that the use of unauthorised waste contractors may leave you liable for prosecution if

your waste was found to have been handled illegally.

22 Section 32 (1) of the Waste Management Act 1996



Appendix D - Halon Critical Users – Annual

Report to EPA



Each column is labelled A to J and your attention is drawn to the corresponding explanatory notes provided on the next page

Halon

type

Critical use

exemption

Brief description of the

critical Use

Total kg

installed in the

equipment on

31 December

2006

Total kg used in

the period 1 Jan

2006 to 31 Dec

2006

Total kg emitted

from this use from

1 Jan 2006 to 31

Dec 2006

Total kg

of stored

halon

Has an alternative

replaced this use

since the last

reporting? Please

indicate alternative

(and when

replaced)

Briefly

describe any

measures

taken to

minimise

emissions

Other

comments

A B C D E F G H I J


Page 39 of 43

Explanatory notes

Column A: Please indicate whether the halon is of type 1301 or 1211.

Column B: Please indicate the applicable critical us exemption from those critical use

exemptions listed in Annex VII of Regulation (EC) 2037/2000 on substances that deplete the

ozone layer.

Column C: Please provide a brief description of the critical use as it applies to your

operations i.e. expand on the critical use exemption wording to describe/justify how it applies

to you.

Column D: Please provide the total quantity (in kg) of halon installed in the equipment at a

point in time i.e. 31 December 2006.

Column E: Article 2 of Regulation (EC) 2037/2000 defines “use” as the utilisation of

controlled substances in the production or maintenance, in particular refilling, of products or

equipment or in other processes except for feedstock and processing agent uses. If any of the

halon system were used during the reporting period (i.e. calendar year 1 January – 31

December 2006), please provide the total quantity of halon used (in kg) in that period.

Column F: If there were any emissions from halon systems during the reporting period (i.e.

calendar year 1 January – 31 December 2006), please provide the total quantity of halon

emitted (in kg) in that period.

Column G: Please provide the total quantity (in kg) of stored halon at a point in time i.e. 31

December 2006. Please include all halon stored (e.g. mobile cylinders, bulk storage tanks

etc.) This information is not mandatory under Regulation (EC) 2037/2000 but is considered

useful.

Column H: If any alternatives have been used to replace halon in particular systems, please

provide the information here (e.g. name of alternative, when it was introduced etc). This

information is not mandatory under Regulation (EC) 2037/2000 but is considered useful.

Column I: Please provide a brief description here of any measures taken to minimise

emissions/leakages.

Column J: If you have any further comments to make/information to provide which you think

might be useful, please use this column.


Page 40 of 43

USER COMMENT FORM Completed forms to be sent to:

Ozone Depleting Substances Office of Licensing and Guidance Environmental Protection Agency

PO Box 3000 Johnstown Castle Estate

County Wexford Ireland

Fax: 053 60699 E-mail: [email protected] Web: www.ozone.ie and www.epa.ie

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SUGGESTIONS FOR FUTURE REVISIONS:

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ADDRESS…………………………………………………………………………………

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