The rumoured change to Article VII Critical uses of halon has caused a storm in the air industry as a forced phase out will (they say) costs hundreds and thousands of pounds as the replacements do not drop in (2 times larger agent cylinders) and will both increase costs and environmental CO2 impact due to extra weight.
Furthermore some pilots are considering stopping flying if the inferior alternatives are forced through and cite that the environmental impact of one plane crashing & burning from an uncontrolled cabin, cargo or engine fire would be far greater than that saved by a change of Annexe VII - only 1 kilo of halon a year is reported as discharged to atmosphere by the air industry.
The air industry has formally petitioned DG Environment at the EU with a technical paper around the issue
Trying to find information out from the EU about these legislative changes is like getting blood out of a stone, but after much digging-
Article 2037/200 on Ozone Depleting Substances is to be reissued on 01/01/2010 as it includes expensive bureaucratic requirements and references not needed now the phase out dates in it are due to have passed
With regard to Halons it says:
Article 13
Critical uses of halons
1. By way of derogation from Article 5(1), halons may be placed on the market and used for
critical uses set out in Annex VI.
2. The Commission may review the critical uses listed in Annex VI and adopt modifications and time-frames for phaseout by defining end dates, taking into account the availability of both, technically and economically feasible alternatives or technologies that are acceptable from the standpoint of
environment and health
Those measures, designed to amend non-essential elements of this Regulation, inter alia by
supplementing it, shall be adopted in accordance with the regulatory procedure with scrutiny
referred to in Article 25(3).
3. The Commission may, at the request of the competent authority of a Member State and in accordance with the procedure referred to in Article 25(2), grant derogations from end dates, provided those end dates have been specified in Annex VI in accordance with paragraph 2, for specific cases where it is demonstrated that no technically and economically feasible alternative is available.
ANNEX VI
Critical uses of halon
Use of halon 1301:
– in aircraft for the protection of crew compartments, engine nacelles, cargo bays and
dry bays, and fuel tank inerting,
– in military land vehicles and naval vessels for the protection of spaces occupied by
personnel and engine compartments,
– for the making inert of occupied spaces where flammable liquid and/or gas release
could occur in the military and oil, gas and petrochemical sector, and in existing
cargo ships,
– for the making inert of existing manned communication and command centres of the
armed forces or others, essential for national security,
– for the making inert of spaces where there may be a risk of dispersion of radioactive
matter,
– in the Channel Tunnel and associated installations and rolling stock.
Use of halon 1211:
– in military land vehicles and naval vessels for the protection of spaces occupied by
personnel and engine compartments,
– 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.
Use of halon 2402* only in Cyprus, the Czech Republic, Estonia, Hungary, Latvia, Lithuania,
Malta, Poland, Slovakia and Slovenia:
– in aircraft for the protection of crew compartments, engine nacelles, cargo bays and
dry bays and fuel tank inerting,
– in military land vehicles and naval vessels for the protection of spaces occupied by
personnel and engine compartments,
– for the making inert of occupied spaces where flammable liquid and/or gas release
could occur in the military and oil, gas and petrochemical sectors, and in existing
cargo ships,
– for the making inert of existing manned communication and command centres of the
armed forces or others, essential for national security,
– for the making inert of spaces where there may be a risk of dispersion of radioactive
matter,
– in hand-held fire extinguishers and fixed extinguisher equipment for engines for use
on board aircraft,
– in fire extinguishers essential to personal safety used for initial extinguishing by fire
brigades,
– in military and police fire extinguishers for use on persons.
Use of halon 2402 only in Bulgaria:
– in aircraft for the protection of crew compartments, engine nacelles, cargo bays and
dry bays, and fuel tank inerting,
– in military land vehicles and naval vessels for the protection of spaces occupied by
personnel and engine compartments.
Critical use has now settled at 500 tones a year in the EU (the air industry uses only 1% of worldwide stocks a year) and the world halon 1211 bank is projected by the UN to be 34,200 tonnes by 2020, allowing more time to find alternatives.
The Regulation 2037/2000 ‘comitology’ Committee is looking at the Article VI exemptions to see if any can be given phase out dates and information it has received makes it likely that a range of dates between 2015 & 2030 will be enacted for each use.
One of the problems for the critical users is that the chemical manufacturers are not helping formulate alternatives strongly as the market is very small compared to R&D and production costs as the general market s now used to it's 'traditional' alternatives and a new Halon Revolution like in the 60's/70's unlikely.
I'm trying to find out which dates are likely to be allotted to each critical use - watch this space!
*1,2-Dibromotetrafluoroethane (C2Br2F4)is a haloalkane. It is also known under codenames R-114B2 and Halon 2402. It is a colorless liquid with a boiling point of 47.2 °C. R-114B2 is occasionally used in fire suppression systems, mostly in the former Soviet Bloc and was never really used elsewhere with CTC, MB, CBM, BCF & BTM being preferred .
On November 8, 2008, an accident aboard Russian submarine K-152 Nerpa due to unintentional activation of a fire suppressant system loaded with R-114B2 killed 20 people and injured 21 more.
