Appendix P to Subpart G of Part 82 - Substitutes Listed in the September 27, 2006 Final Rule, Effective November 27, 2006

Appendix P to Subpart G of Part 82 - Substitutes Listed in the September 27, 2006 Final Rule, Effective November 27, 2006

Fire Suppression and Explosion Protection Sector - Total Flooding Agents - Acceptable Subject to Narrowed Use Limits

End-use	Substitute	Decision	Conditions	Further information
Total flooding	Gelled Halocarbon/Dry Chemical Suspension with any agent other than ammonium polyphosphate or sodium bicarbonate additive (Envirogel with sodium bicarbonate additive)	Acceptable subject to narrowed use limits	For use only in normally unoccupied areas	Use of this agent should be in accordance with the safety guidelines in the latest edition of the NFPA 2001 Standard for Clean Agent Fire Extinguishing Systems, for whichever hydrofluorocarbon gas is employed. Envirogel is listed as a streaming substitute under the generic name Gelled Halocarbon/Dry Chemical Suspension. Envirogel was also previously listed as a total flooding substitute under the same generic name. EPA has found Envirogel with the ammonium polyphosphate additive and Envirogel with the sodium bicarbonate additive to be acceptable as total flooding agents in both occupied and unoccupied areas. See additional comments 1, 2, 3, 4, 5

Additional comments:

1 - Should conform to relevant OSHA requirements, including 29 CFR 1910, subpart L, Sections 1910.160 and 1910.162.

2 - Per OSHA requirements, protective gear (SCBA) should be available in the event personnel should reenter the area.

3 - Discharge testing should be strictly limited to that which is essential to meet safety or performance requirements.

4 - The agent should be recovered from the fire protection system in conjunction with testing or servicing, and recycled for later use or destroyed.

5 - EPA has no intention of duplicating or displacing OSHA coverage related to the use of personal protective equipment (e.g., respiratory protection), fire protection, hazard communication, worker training or any other occupational safety and health standard with respect to halon substitutes.

[71 FR 56367, Sept. 27, 2006]