Wednesday, December 19, 2012

Report of the International Halon Replacement Coordination Meeting Third Meting (IHRCM/3)


 
IHRCM/3 Report
19/11/12
 
REPORT OF THE
INTERNATIONAL HALON REPLACEMENT COORDINATION MEETING
THIRD MEETING (IHRCM/3)
 
(Long Beach, California, United States, 15 to 16 November 2012)
 
SUMMARY
 
This report captures the presentations, discussions and conclusions of the third International Halon Replacement Coordinating Meeting (IHRCM/3).
1.                   INTRODUCTION
1.1                                       For over forty-five years halogenated hydrocarbons (halon) have been the main fire extinguishing agent used in civil aircraft fire suppression systems. With the signing of the Montreal Protocol on Substances that Deplete the Ozone Layer, the production of halon was banned on 1 January 1994 in developed States. This is mainly due to halon’s ozone depleting and global warming characteristics. However, halon is still to this day being used in aircraft fire suppression systems.
2.                   BACKGROUND
2.1                                       In December 2009, the first halon coordinating meeting (IHRCM/1) was held with industry, State regulators and international organizations to review the current status of halon replacements, look at the way ahead and discuss alternatives to halon. This meeting focused its work on the timeframes specified in Assembly Resolution A36-12 and on the viability of meeting those timeframes. As a result of the meeting, new timeframes were proposed in the form of an amended draft resolution.
2.2                                       During the IHRCM/1, it was concluded that the only effective means to set international requirements with regard to halon replacement would be to propose that the Council approve amendments to Standards and Recommended Practices (SARPs). Amending Annex 6 — Operation of Aircraft and Annex 8 — Airworthiness of Aircraft would be the recommended course of action in implementing the requirements of the updated Assembly Resolution A36-12 and Assembly Resolution A37-9 ─ Halon replacement, adopted on 7 October 2010, calls for the Council to establish a mandate for the replacement of halon fire extinguishing agents in civil aircraft and sets new timeframes previously agreed by stakeholders.
2.3                                       While Assembly Resolution A37-9 mandated the use of an alternative agent to halon, it also established other tasks to be accomplished:
a)      Direct the Council to conduct regular reviews of the status of potential halon alternatives to support the agreed upon implementation dates given the evolving situation regarding the suitability of potential halon alternative agents as they continue to be identified, tested, certified and implemented;
b)      Urge States to inform ICAO regularly of their halon reserves, and directs the Secretary General to report the results to the Council.  Further, the Council is directed to report on the status of halon reserves at the next Ordinary Session of the Assembly; and
c)      Resolve that the Council shall report to the next ordinary session of the Assembly on progress made developing halon alternatives for cargo compartments and engine/auxiliary power unit fire extinguishing systems as well as the status of halon alternatives for hand held fire extinguishers.
2.4                                       The process to amend Annexes 6 and 8 began in November 2010 and the proposal was adopted by the ICAO Council on 13 June 2011.
2.5                                       IHRCM/2 provided an opportunity for the various stakeholders to update and discuss on the following:
a)      the status of lavatory fire extinguishing systems;
b)      the status of halon alternatives for hand-held fire extinguishers;
c)      the progress made in the development of halon alternatives for engine/auxiliary power unit and cargo compartment fire extinguishing systems; and
d)      the reporting of halon reserves by States.
2.6                                       IHRCM/3 further updated and discussed with the stakeholders on the following:
a)      the status on the development of potential halon alternatives to support the agreed upon implementation dates, including halon alternatives for cargo compartment fire suppression systems;
b)      the issues associated with the quality of recycled halon;
c)      the progress of the implementation of the requirements of Annex 6 and Annex 8 for halon replacement;
d)      the States responses to the ICAO State questionnaire on halon reserves; and
e)      the proposal of a tentative timeframe for the replacement of halon in cargo compartments.
3.                   AGENDA ITEM 1: OPENING OF THE MEETING
3.1               Place and duration
3.1.1                                  The third meeting of the International Halon Replacement Coordinating Meeting (IHRCM/3) was held at Boeing Commercial Airplanes, Long Beach, USA on 15 and 16 November 2012. IHRCM/3 was held in conjunction with the International Aircraft Systems Fire Protection Working Group (IASFPWG) meeting on 14 and 15 November 2012 to accommodate participants.
3.2               Opening remarks
3.2.1                                  The meeting started at 1430 hours on 15 November 2012.  Mr. Alain Coutu, Technical Officer Airworthiness, Air Navigation Bureau (ANB) welcomed the participants and provided the opening remarks. Mr. Coutu stated that this gathering was different from previous meetings as there were more participants present than when the original group of experts first convened in 2009. He informed the meeting that this group of experts had been tasked to support the Secretariat in providing a progress report on halon alternatives and halon reserves, which is to be submitted at the next Assembly. A brief introduction to the halon replacement in aircraft was presented and a brief discussion on the earlier IHRCMs.
3.3               Attendance
3.3.1                                  The meeting was attended by experts and observers from four States, EASA, ICCAIA and twenty industry organizations. Also attending the meeting via teleconference were representatives of ICCAIA and IATA. The list of participants is attached in Appendix A.
3.4               Meeting Chairperson
3.4.1                                  Mr. Dick Hill, Program Manager, Fire Safety Branch, International Aircraft Systems Fire Protection Working Group (IASFPWG), was the Chairperson of the meeting throughout its duration supported by Mr. Coutu.
3.5               Adoption of the agenda
3.5.1                                  The meeting adopted the following agenda:
Agenda Item 1:
Opening of the meeting
 
1.1
Opening remarks
 
1.2
Administrative remarks
 
1.3
Introduction of participants
 
1.4
Adoption of Agenda
Agenda Item 2:
Status report
 
2.1
Status report on the development of potential halon alternatives to support the agreed upon timeline.
 
2.2
Updates on the research and development made on halon alternatives for cargo compartment fire suppression systems.
Agenda Item 3:
Recycled halon
 
3.1
Updates on issues associated with the quality of recycled halon.
Agenda Item 4:
Progress made since IHRCM/2
 
4.1
Presentations and discussions on alternatives to halon and progress of implementation of the requirements of Annex 6 – Operation of Aircraft and Annex 8 – Airworthiness of Aircraft for halon replacement.
 
4.2
Report on halon reserves based on States’ responses to the ICAO State questionnaire on halon reserves.
Agenda Item 5:
Timeframe for halon replacement in cargo compartment
 
5.1       
Propose a tentative timeframe for replacement of halon in cargo compartments.
Agenda Item 6:
Any other business
Agenda Item 7:
Closing
4.                   agenda item 2: STATUS REPORT
4.1               Agenda Item 2.1 - Status report on the development of potential halon alternatives to support the agreed upon timeline.
4.1.1                                  Present status of halon replacement in aircraft
4.1.1.1                            Mr. R. Hill of FAA Technical Center, provided a presentation to update the meeting on the status of halon alternatives for lavatory extinguishers and potential alternatives for hand-held, engine nacelle/APU and cargo compartment extinguishers.
4.1.2                                  Lavatory extinguishers
4.1.2.1                            The meeting was informed that the approved halon replacement agents FM-200 and FE-36 had passed the FAA Minimum Performance Standards (MPS) tests and are certified under the US EPA Significant New Alternatives Programme (SNAP). Currently, all Boeing and Airbus aircraft use these replacement agents.
4.1.2.2                            Bombardier and Embraer informed the meeting that halon replacement agents in lavatory fire extinguishers will begin to be implemented as of January 2013.
4.1.3                                   Hand-held extinguishers
4.1.3.1                            The meeting was informed that the following replacement agents for halon 1211 meet MPS and are SNAP approved:
a)                   HCFC Blend B (Halotron 1);
b)                   HFC-227ea (FM-200); and
c)                   HFC-236fa (FE-36)
4.1.3.2                            However, these 3 agents, though approved for use, have yet to be installed as they are reported to be up to twice the weight, greater in volume and have up to seven times global warming potential (GWP) than halon 1211. To mitigate the issue of weight, Mr. Hill informed that the FAA Technical Center has begun a project for hand-held extinguishers design optimization to reduce weight. Considerations include nozzle and bottle design and bottle operating pressures. This project is not aimed at finding a replacement but at what can be done should 2BTP (2-bromo-3, 3, 3-trifluropropene) fails.
4.1.3.3                            The meeting was updated on new replacement agents being evaluated including 2BTP  which is awaiting SNAP approval and Underwriters Laboratories (UL) rating. This is a promising agent.
4.1.3.4                            Mr. Hill informed the meeting that the industry has agreed to use approved agents if better alternatives are not approved prior to the established ICAO date, 31 December 2016.
4.1.4                                  Engine nacelle / APU extinguishers
4.1.4.1                            The meeting was briefed that the following replacement agents have passed MPS and are SNAP approved:
a)                   HCF-125  (17.6% concentration);
b)                   FK-5-1-12 (Novec 1230) (6.1% concentration); and
c)                   CF3I  (7.1% concentration)
4.1.4.2                            Mr. Hill provided further information on some of these agents:
a)                   HFC-125
i)                                             used by the military;
ii)                                            major weight and volume penalty
b)                   Novec 1230
i)                    Novec 1230 is not functioning as required by the MPS at low ambient temperature;
ii)                  more R&D needed
c)                   CF3I
i)                   toxicity concerns
d)                   Kidde Solid Aerosol (KSA)
i)                     new non-gaseous agent;
ii)                    MPS developed concentrations unable to extinguish live engine fire;
iii)                  additional R&D needed
4.1.5                                  Cargo compartment extinguishing systems
4.1.5.1                            The meeting was informed that the following potential replacement agents have failed the cargo compartment MPS test:
a)                   HFC-125/FM-200: high HF concentrations, ignition of smoke layer;
b)                   CF3I: toxicity concerns;
c)                  2BTP/Novec 1230: overpressures at below inerting concentrations during aerosol can scenario
4.1.5.2                            However, the following developments are being considered for cargo compartment fire extinguishing systems:
                        a)         Integrated Fire Protection - Water Mist/Nitrogen System
i)          passed MPS in early 2010;
ii)                  promising concept but requires significant development and acceptance; and
iii)                 requires the use of the on-board inert gas generation system installed on aircraft to reduce fuel tank flammability
b)                  Airbus has proposed a halon knock-down nitrogen system for A350 that would reduce the use of halon by 50%
4.1.5.3                            MPS was developed in 2005 (DOT/FAA/AR-TN05/20) and now the FAA is considering adding a lithium battery scenario. There is nothing at this time indicating that an additional test and/or amendment to the MPS may be required.
4.1.5.4                            Mr. Hill added that there is a possibility that there may be a recommendation from NTSB to equip freighter airplanes with fire extinguishing systems.
4.1.6                                  BTP- Status
4.1.6.1                            Mr. B. Colton from AMPAC provided a status report on 2BTP (2-Bromo-3, 3, 3-Trifluoropropene). 2BTP was initially developed as a replacement agent for halon 1301. However, rresults of recent testing provided confidence that 2BTP could be used as a drop-in replacement for the halon 1211 fire extinguishers.
4.1.6.2                            2BTP still requires further tests including toxicology and UL leak tests. Regulatory review is expected to be completed by 2013. Commercialization for aviation is expected to follow after US and EU approvals, sometime in 2014.
4.1.7                                  Industry update – Challenges and solutions to halon replacement
4.1.7.1                            Mrs. Robin Bennett of ICCAIA provided a presentation and information paper on the challenges and solutions to halon replacement from the perspective of the industry stakeholders. This update is based on Boeing, Airbus, Bombardier, AIA discussions.
4.1.7.2                            The aerospace industry remains committed to implementing solutions but the new challenges need to be addressed, and more concerted engagement by all stakeholders is key.  ICCAIA recognized the progress made with lavatory and handheld fire extinguishing agents, yet challenges remain. Two engine and APU alternatives promising agents did not meet expected performance requirements under additional FAA testing. The industry is not optimistic that any current known agent will be certification-ready to meet the 31 December 2014 date. The cargo alternatives research continues for potential replacements.
4.1.7.3                            ICAO reiterated that the 2014 date is applicable to aircraft for which an application for type certificate is submitted on or after 31 December 2014. There are still a few years after that before the aircraft rolls out of the production line. ICAO is not ready to change the established date.
4.1.7.4                            Industry’s position continues to be that it is premature to establish halon replacement deadlines for cargo applications. The successful establishment of a replacement date requires full cooperation of all stakeholders with broader representation and more frequent engagement.
4.1.7.5                            ICAO Assembly Resolution A37-9 adopted in 2010 should consider the new challenges and an update should be made to provide flexibility to address potential situation of alternative solutions not being viable with current A37-9 deadlines similar to the provision in the halon regulation adopted by the EU.
4.1.7.6                            The EASA representative, Mr R Deletain, was asked what would be the process if an applicant did not have a halon replacement at the time of type certificate application after 31 December 2014. Mr. Deletain stated that considerations at certification level would be whether it is a rejection of the application because it doesn’t propose a replacement agent or an alternative means to show compliance at later date as a certification plan changes with time. He is uncertain of what the process would be. Mr Deletain will request the rulemaking department at EASA.
4.1.7.7                            The EU regulation provides for exemption if no alternatives exist but there is an alternative for engine and APU. HFC 125 is currently used by the military and although it has a weight penalty, it works.
4.1.7.8                            Regarding more engagements by stakeholders, ICAO offered the meeting as a forum if stakeholders wanted to start discussions and form a working group. ICCAIA offered to support an initiative to bring the stakeholders together and draft a roadmap.
4.2                                       Agenda Item 2.2 - Updates on the research and development made on halon alternatives for cargo compartment fire suppression systems
4.2.1                                  This agenda item was covered by the presentation in Agenda item 2.1.
4.2.2                                  Laptop and other thermal runaways in Lithium battery development
4.2.2.1                            Mr. Kent Faith from Sprectrum FX provided information on lithium battery fire and the available product for extinguishing. The available product is not a replacement for halon and is a supplemental kit to existing handheld extinguishers for lithium battery. The agent called Firebane is not rated for electrical fire as it is conductive.
Conclusion
Status report
Lavatory fire extinguisher:
1)      There are currently two approved halon replacement agents FM-200 and FE-36
 
2)      All new Boeing & Airbus aircraft presently use replacement agents and Bombardier and Embraer will begin using a replacement agent as of January 2013.
 
Handheld Fire extinguisher:
1)      There are currently three replacement agents that are approved but not installed:
a.       HCFC Blend B (Halotron 1)
b.       HFC-227ea (FM-200)
c.       HFC-236fa (FE-36)
 
These agents are up to twice the weight, are larger in volume, and have up to 7 times the GWP.
2)      The FAA is funding a project for fire extinguisher design optimization to reduce weight. Its focus is on:
a)      nozzle design;
b)      bottle design; and
c)      operating pressure
 
3)      Work continues to be done with 2BTP as it is a promising agent. Commercialization for aviation is planned for 2014. 2BTP does not have the environmental, size, or weight issues of existing approved halon replacement fire extinguishers agents.
 
4)      Industry has agreed to use approved agents if better alternatives are not approved prior to the ICAO date.
 
Engine/APU fire extinguisher:
1)      Three replacement agents have passed the MPS and are SNAP approved
a)      HCF-125  (17.6% concentration)
b)      CF3I  (7.1% concentration)
c)      FK-5-1-12 (Novec 1230)  (6.1% concentration)
 
2)      Novec 1230
·         not functioning as required by the MPS at low ambient temperature
·         agents use in question – More R&D needed
 
3)      CF3I
·         concerns with toxicity
 
4)      HFC-125
·         currently used by military
·         major weight and volume penalty
 
5)      Kidde Solid Aerosol (KSA) Testing
·         new non-gaseous agent
·         MPS developed concentrations unable to extinguish live engine fire.
·         additional R&D is in process
 
6)      The research is in progress and ICCAIA is not certain to be able to meet the target date of 2014 for the engine/APU fire extinguisher.
 
7)      There is a replacement but it has weight and volume property.
 
8)      The representative from EASA will inquire from the rulemaking department at EASA what would be the course of action at the certification level if the applicant for a type certificate doesn’t propose a replacement agent or alternative considering that a certification plan changes with time.
 
Cargo fire extinguisher:
1)      Replacement agents tested – failed MPS
a)      HFC-125/FM-200: high HF concentrations, ignition of smoke layer
b)      CF3I: toxicity concerns
c)      2-BTP/Novec 1230: overpressures at below inerting concentrations during aerosol can scenario
 
2)      Integrated fire protection - water mist/nitrogen system
·         passed MPS in early 2010
·         promising concept but requires significant development and acceptance
·         uses on-board inert gas generation system installed on aircraft to reduce fuel tank flammability
 
3)      Airbus has proposed halon knock-down nitrogen system for A350
 
4)      MPS was developed in 2005 (DOT/FAA/AR-TN05/20) and now the FAA is considering lithium battery scenario.  It may or may not require a new test and/or amendment to the MPS.
5.                   AGENDA ITEM 3: RECYCLED HALON
5.1               Agenda item 3.1 – Updates on issues associated with the quality of recycled halon
5.1.1                                  Halon supply and quality of recycled halon
5.1.1.1                            Mr. R. Marcus of RemTec provided the meeting with an insight to issues associated to the recycling of and the quality of recycled halon (1211, 1301, and 2402). The presentation informed the meeting of the supply and quality issues; recovery, reclamation and destruction processes; quality control and testing of recycled halon; and storage considerations.
The production of halon 1211 has ceased in industrialized countries since 1 January 1994 and U.S. excise taxes apply to both new and used Halon 1211 imported into the U.S.  Supplies of Halon 1211 are limited and the quality of used installed inventory is declining.
 
Halon 2402 is primarily used on Soviet Union / Russian military and commercial aviation equipment and worldwide supplies are limited.
 
The production of halon 1301 ceased in industrialized countries 1 January 1994 and critical users are aviation, petrochemical plus and equipment distributors servicing used equipment.
 
In 1993 the installed inventory was primarily in Japan, North America and Europe. After 20 years the supply of used Halon 1301 is dwindling, quality is declining especially if sourced from developing countries and many of those countries restrict the export of halons. Japan does not allow export of halon.
 
As the quality and supply of halons has decreased, the cost to procure and reclaim halons has increased, and in the last 5 years, the cost of procuring recovered halon 1301 has augmented 100%.
Cross-contamination is becoming more prevalent the farther we move away from virgin production end dates. As used halon and other “in demand” halocarbons become more expensive, the incentive to intentionally blend-in cheaper halocarbons such as R-22, forming increases.
5.1.1.2                            The presentation suggests that to successfully manage halocarbons, considerations should be made to:
a)      provide incentives to encourage recovery from end-users;
b)      institute safe handling practices;
c)      document and track agents and tanks;
d)      perform laboratory testing for both the incoming material and the out-going finished product;
e)      establish long-term strategic reserves for critical users; and
f)       continually conduct leak testing and periodic physical inventories.


Conclusion
Recycled halon
 
1)      As the quality and supply of halons has gone down, the cost to procure and reclaim halons has gone up and in the last 5 years the cost of procuring recovered halon 1301 has increased 100%.
 
2)      Halons are more difficult to recycle due to cross contamination.
 
3)      Cross-contamination is becoming more prevalent the farther we move away from virgin production end dates. As used halon and other “in demand” halocarbons become more expensive the incentive to intentionally blend in cheaper halocarbons such as R-22 increases.
 
4)      TCCA, in cooperation with the FAA, the UK CAA and EASA, has accordingly undertaken a study to identify means to minimize the probability that non-compliant/contaminated agents will be installed on aircraft. 
6.                   AGENDA ITEM 4 – PROGRESS MADE SINCE IHRCM/2
6.1                                       Agenda item 4.1 - Presentations and discussions on alternatives to halon and progress of implementation of the requirements of Annex 6 – Operation of Aircraft and Annex 8 – Airworthiness of Aircraft for halon replacement.
6.1.1                                  EASA progress and plans
6.1.1.1                            Mr. R. Deletain of EASA briefed the meeting on EASA’s Rulemaking Tasks (RMT) on halon replacement. The meeting was updated on the status of several RMTs.
In 2011 EASA initiated a rulemaking task to amend CS-23, CS-25 and CS-29 in order to be compliant with EU legislation and with the Amendment 103 to ICAO Annex 8. And in 2012 CS-23 and CS-25 have already been amended and CS-29 is being amended accordingly. The CS (Book 1) has no reference to either halon or any other extinguishing agent and AMC/GM (Book 2) explains the reason for halon being phased out referring to Regulation 744/2010.
 
The EU legislation implies compliance with applicable amendments to ICAO Annex 6 (i.e. newly produced aircraft based on existing Type Certificates) only in 2025 (for handheld fire extinguishers) and 2020 (for lavatories).  EASA has planned RMT.0560 to comply with the dates set in ICAO Amendments to Annex 6 which will be late for lavatories. It will comprise of an update of EASA part 26 and propose a forward fit for lavatory disposal receptacle and portable fire extinguishers in cabins and crew compartments. 
 
The halon alternatives are sufficiently safe and suitable for handheld and lavatories fire extinguishers bringing environmental benefits, with minimum economic impact on aircraft manufacturers. This proposal complies with current ICAO standards without a need for amending EU regulation 744/2010. The Notice of Proposed Amendment (NPA) will be available by mid-2013 and anyone can comment.
 
EASA has also mandated SAE (Society of Automotive Engineers) to develop Minimum Performance Standards for (halon free) portable fire extinguishers to be used in aircraft and an ETSO (European Technical Standard Order) will be published. There is a rule making task (RMT.0206) in process and the NPA will be available in 2013.
 
In order to align with ICAO Resolution A37-9 ‘halon replacement’ adopted during ICAO 37th General Assembly, amendments to of Part- 145 and Part-M shall be made. AMC/GM (Acceptable Means of Compliance /Guidance Material) will be developed for production and maintenance organizations to verify the quality of halon in their possession through testing and internal procedures. The notice of proposed amendment (NPA) is planned for Q3 of 2013.
 
The following is a summary of EASA actions:
 
 
RMT
STATUS
0273
New applications for TC
CS-23 & 25 amended
CS-29 amended before end 2012
0560
Newly produced aircraft
NPA planned in 2013
0206
ETSO for portable fire extinguishers
NPA planned in 2013
0368
Contaminated halon
ToR being drafted
NPA planned in 2013
??
Engine nacelles, APU and cargo compartments
No obligation of any agent in CSs
Additional RMTs could be planned
 
Filing of Differences
            Mr. Alain Coutu presented a summary of the differences filed by States regarding the standards relating to halon replacement:
 
Annex 6, 8
A 35 Annex 6
Part I, 6.2.2.1
(L, H)
A30  Annex 6
Part II, S II 2.4.2.3
(L, H)
A16  Annex 6
Part III, S II 4.2.2.1
(L, H)
A 6  Annex 6
Part III, S III 4.1.3.2
(L, H)
A103  Annex 8
Part II, 1.2.5
(L, E, A)
No Difference
13
20
17
16
19
Currently do not have such requirements
3
5
5
3
3
Will comply at a later Date
13
12
6
13
0
N/A
0
1
2
1
2
Total Replies
29
38
30
33
24
 
No States filed differences stating they would not comply with the Standards. Most States either declared no differences or would comply at a later date. The N/A means the States do not have the activity in their State at this time.
6.2                                       Agenda item 4.2 - Report on halon reserves based on States’ responses to the ICAO State questionnaire on halon reserves.
6.2.1                                  Responses to ICAO State Letter on halon reserves
6.2.1.1                            Mr. Coutu also updated the meeting on the responses received from States regarding halon reserve.
       In May 2012 ICAO issued State Letter AN 3/25.1-12/35 requesting information on halon reserves accessible to the civil aviation industry within States to follow-up on Assembly Resolution A37-9: Halon replacement, adopted by the 37th Session of the ICAO Assembly. The resolution urges States to inform ICAO regularly on their halon reserves of which ICAO is to report at the next Assembly, which will be held in September 2013.
 
       As of October 2012 ICAO received 53 Replies to the questionnaire on halon reserve.
 
 
       To question No.1; “With the ban ……..do you anticipate that there will be enough halon to meet the civil aviation needs of your State? Most States responded they were unsure of the halon reserve while others responded N/A as they purchase it from an outside source.
 
       To question No. 2; “Do you know the quantity of halon reserves accessible to the civil aviation industry in your State in order to support its future operations? Most States replied no, while several others replied N//A. Only 33 States replied they know their reserves, 16 for halon 1211 and 17 for halon 1301.
6.2.2                                  Estimated Global Inventories of Halons 1301 and 1211
6.2.2.1                            Mr. T. Cortina presented, on behalf of UNEP, their approach to estimate the amount of halon available. The presentation also discussed the ownership of halon by region, the challenges in procurement, and the availability of halon for civil aviation use.
No one “Knows” how much halon is left. We know the global yearly production data, the global yearly estimated emissions and comparing with atmospheric measurements of emissions we can estimates the reserves.
 
Global quantities are irrelevant unless owned by civil aviation.  Some States have import taxes while others have exporting laws prohibiting export of halon. It is not only a reserve issue but also a regulatory issue. Halon reserves are difficult to estimate as there are owners retaining supplies from decommissioned systems for own uses/stockpile, large users like the US Dept. of Defense and North Slope in U.S., maintain their own long-term reserves, and some airlines may have their own reserve.
 
Reliance on halon “Banks” has implications, one which is destruction for carbon credits. Ozone depleting substance (ODS) have high global warming potential (GWP) similar to HFC alternatives.
(i.e.: Halon 1301 = 7,140, HFC-227ea = 3,220)
US Climate Action Reserve provides greenhouse gas (GHG) offset credits for destruction of ODS (not currently halons) and Australia will have a carbon tax in July 2013, which will be an incentive for destruction of waste GHGs. Therefore users of halon could be competing in a market with companies looking to destroy halons for GHG credits.
6.2.3                                  UNEP assessment of the responses to ICAO State letter on halon reserve
There is a notable lack of response from States where we think there could be a lot of halon and where filling of bottles now occurs. Although some States have determined their supplies some did not know how much halon they had. While some States believe that there is enough halon we are not certain how they could determine that.
                                                                                                      
The following is a fairly typical answer of the survey responses. Brazilian aircraft manufacturers, Embraer and Helibras declared:
     The halon used to fill the fire extinguishers of their aircraft is provided by foreign suppliers.
Moreover, the two Brazilian airlines, TAM and Gol, that retain approximately 75% of the civil aviation domestic market in Brazil and are the only Brazilian airlines that operate international flights declared:
     The halon used to fill the aircraft fire extinguishers of their fleet is also provided by foreign suppliers.
ANAC is unaware of any Brazilian company that recycles halon to be used in aircraft fire extinguishers.
 
Therefore, the civil aviation halon needs in Brazil depend on the availability of halon in the countries that supply the Brazilian aircraft manufacturers and airlines.
 
On the subject of cargo compartment fire extinguishing agent replacement, this is the largest use of halon on aircraft and drives the quantities of halon needed for the long-term. With no end in sight, it makes estimates of needs impossible to determine.
 
European Union has end and cut-off dates. We need to consider now establishing a date for the replacement of halons in new designs aircraft and the ICAO end dates help to support commercial research and development of halon alternatives.
6.2.3.1                            The presentation concluded with UNEP suggesting the following:
a)                  the need to consider establishing a date to mandate implementation of halon alternatives for aircraft cargo compartment;
a)                    civil aviation still needs to determine the long term needs for halon, where the requirements will come from, and to report to Parties to the Montreal Protocol;
b)                  resend ICAO State Letter AN 3/25.1-12/35 to States’ ozone focal point to canvass a broader response from States to the State Letter; and
c)                  consider developing guidance on the collection and provision of information on halon for aviation needs and halon reserves.


Conclusion
Progress made since IHRCM/2
1)      EASA has begun rulemaking and the following is a summary of EASA actions:
 
RMT
STATUS
0273
New applications for TC
CS-23 & 25 amended
CS-29 amended before end 2012
0560
Newly produced aircraft
NPA planned in 2013
0206
ETSO for portable fire extinguishers
NPA planned in 2013
0368
Contaminated halon
ToR being drafted
NPA planned in 2013
??
Engine nacelles, APU and cargo compartments
No obligation of any agent in CSs
Additional RMTs could be planned
 
 
2)      Of the States who have filed differences, none have stated they will not comply, and although some States stated no differences, others stated they would comply at a later date.
 
Halon reserves:
1)      The HTOC model of global inventories of halon is based on:
a)      production data known prior to 1996;
b)      estimate of yearly emissions by region;
c)      estimate of yearly recovery rates; and
d)      similar results from atmospheric samplings validate the HTOC model
2)      The HTOC charts on the global inventories of halon 1301 and halon 1211 is given in Appendix 2.
3)      No one “knows” how much halon is left. We know the global yearly production data, the global yearly estimated emissions, and comparing with atmospheric measurements of emissions, it is possible to estimate the reserves.
 
4)      Global quantities are irrelevant unless owned by civil aviation.  Some States have import taxes while others have exporting laws prohibiting export of halon. Therefore it is not only a reserve issue but also a regulatory issue.
 
5)      Reliance on banks has the implications that States may destroy halon for Carbon Credits:
a)      ODS have high GWPs similar to HFC alternatives
                                                               i.      Halon 1301 = 7,140, HFC-227ea = 3,220
b)      US Climate Action Reserve provides GHG offset credits for destruction of ODS (not currently halons)
c)      Australia carbon tax, incentives for destruction of waste GHGs including ODS in July 2013
d)      users of halon could be competing in market with companies looking to destroy halons for GHG credits
                                                               i.      Current cost of Halon 1301 in US ≈ $33,000/tonne
                                                             ii.      At $20/tonne of CO2 equivalent = $142,800/tonne
6)      Responses from States to ICAO State letter on halon reserve for civil aviation:
a)      little evidence that States civil aviation and ozone offices worked together;
b)      notable lack of response from States where possibly there could be a lot of halon and where filling of bottles now occurs;
c)      little evidence that States know how much halon is available to civil aviation although some States believe there is enough halon, it must be difficult to determine; and
d)      resend ICAO State Letter AN 3/25.1-12/35 to States’ ozone focal point to canvass a broader response from States to the State Letter.
7)        European Union has end and cut-off dates. ICAO needs to consider now establishing a date for the replacement of halons in new designs aircraft and the ICAO end dates help to support commercial research and development of halon alternatives.
7.                   AGENDA ITEM 5: TIMEFRAME FOR HALON REPLACEMENT IN CARGO COMPARTMENTS
7.1               Agenda item 5.1 – Propose a tentative timeframe for the replacement of halon in aircraft cargo compartments.
7.1.1                                  Establishment of Timeframe
7.1.1.1                            Mr. Coutu briefed the meeting on the ICAO Standard making process. It was explained that should a decision be made on the timeframe for halon replacement in November 2012; the earliest applicable date for a Standard in Annex 8 would be March 2018 and therefore would be adjusted to the 31 December 2018 to correspond with EASA cut-off date.
ICCAIA reiterated that it is too early to commit to a replacement date and committing to a replacement date that the industry is uncertain of meeting. Aircraft designers may be hesitant to apply for a new type certificate.
 
A representative from Boeing stated that the process is difficult and flexibility is required. ICAO reiterated that the process of standard making will lead to a date for the replacement of halon in cargo compartment fire extinguishing system for new design aircraft. In the Standard making process a date cannot be left open, an implementation date is required.
 
UNEP stated that with a replacement date of 2019, it will have been 20 years since the production of halon ceased and States do not know how much  halon is available for use by aviation. Will a few more years help? If a date is not established now, it is likely that a replacement will be available in the near future.
 
UNEP asked the question: EASA has a dateline; what are the manufacturers going to do?
 
Airbus stated that it is a big discussion right now within the organization and that although very political and controversial they may have to request an exemption. At least, this flexibility is available.
 
The meeting asked how the new lithium battery test would impact the research. The representative of the FAATC stated that it will not affect the progression of the research.
 
FAATC also stated that it is expected that the National Transportation Safety Board may issue a recommendation for the installation of fire suppression system in cargo airplane.
 
The concept of a working group of the stakeholders was discussed again and could be used as a collaborative decision making process to achieve the establishment of an implementation date for the replacement of halon in cargo compartment.
 
ICCAIA committed to lead the initiative and several stakeholders present offered their support. The group should have a plan by early January 2013 that will provide a target date, by which the group should have reached consensus, on a replacement date for cargo compartment.
 
Conclusion
Timeframe for halon replacement in cargo compartment
1)      Research has not progressed rapidly enough.
2)      ICCAIA has proposed to lead an initiative to create a working group of stakeholders that will work together at creating a roadmap that would define the processes required, as well as the role of the stakeholders, and by January 2013 would propose a plan that would lead to the establishment of a target date for the replacement of halon.
8.                   AGENDA ITEM 6: ANY OTHER BUSINESS
8.1               Study Regarding Fire Extinguishing/Suppression Agents’ Quality Processes
Mr. Claude Lewis of Transport Canada briefed the meeting on their study. The quality of agents in fire extinguishing and suppression systems has been brought into question as a result of cases of contaminated halons found installed (or destined for installation) on aircraft.  TCCA, in cooperation with the FAA, the UK CAA and EASA, has accordingly undertaken a study to identify means to minimize the probability that non-compliant/contaminated agents will be installed on aircraft.  The study, which is being conducted  (under contract) by R.G.W. Cherry & Associates (UK ) is considering contamination potential for both new and recycled agents, from agent production to filled vessels installed on aircraft, and accidental, as well as intentional ‘opportunities’.  The project comprises two phases: 1) documenting the processes currently in use in North America and in Europe, and 2) analysis to identify best practices as well as deficiencies/gaps, and development of proposed standardized quality protocols. The first phase, which involved the polling of stakeholders (manufacturers, suppliers, recyclers, operators, test laboratories, etc.) is essentially completed.  Preliminary review indicates that there are differences between the processes used in North America and in Europe for the different ‘applications’, that there are no equivalent to UL/ULC in Europe, and that third party testing/sampling, when done, is an industry practice or is being conducted as a contractual obligation.  The second phase has just been initiated and is expected to be completed in early 2013.
9.                   AGENDA ITEM 7: CLOSING OF THE MEETING
9.1               The meeting was concluded and ICAO thanks all participants for sharing information and discussing these issues. The meeting objectives were met and positive results can be reported at the next assembly on the progress made with halon replacement.
The meeting ended at 1400 hours on 16 November 2012
 
— END —.




APPENDIX B

 
IHRCM/3 Report
19/11/12
 
REPORT OF THE
INTERNATIONAL HALON REPLACEMENT COORDINATION MEETING
THIRD MEETING (IHRCM/3)
 
(Long Beach, California, United States, 15 to 16 November 2012)
 
SUMMARY
 
This report captures the presentations, discussions and conclusions of the third International Halon Replacement Coordinating Meeting (IHRCM/3).
1.                   INTRODUCTION
1.1                                       For over forty-five years halogenated hydrocarbons (halon) have been the main fire extinguishing agent used in civil aircraft fire suppression systems. With the signing of the Montreal Protocol on Substances that Deplete the Ozone Layer, the production of halon was banned on 1 January 1994 in developed States. This is mainly due to halon’s ozone depleting and global warming characteristics. However, halon is still to this day being used in aircraft fire suppression systems.
2.                   BACKGROUND
2.1                                       In December 2009, the first halon coordinating meeting (IHRCM/1) was held with industry, State regulators and international organizations to review the current status of halon replacements, look at the way ahead and discuss alternatives to halon. This meeting focused its work on the timeframes specified in Assembly Resolution A36-12 and on the viability of meeting those timeframes. As a result of the meeting, new timeframes were proposed in the form of an amended draft resolution.
2.2                                       During the IHRCM/1, it was concluded that the only effective means to set international requirements with regard to halon replacement would be to propose that the Council approve amendments to Standards and Recommended Practices (SARPs). Amending Annex 6 — Operation of Aircraft and Annex 8 — Airworthiness of Aircraft would be the recommended course of action in implementing the requirements of the updated Assembly Resolution A36-12 and Assembly Resolution A37-9 ─ Halon replacement, adopted on 7 October 2010, calls for the Council to establish a mandate for the replacement of halon fire extinguishing agents in civil aircraft and sets new timeframes previously agreed by stakeholders.
2.3                                       While Assembly Resolution A37-9 mandated the use of an alternative agent to halon, it also established other tasks to be accomplished:
a)      Direct the Council to conduct regular reviews of the status of potential halon alternatives to support the agreed upon implementation dates given the evolving situation regarding the suitability of potential halon alternative agents as they continue to be identified, tested, certified and implemented;
b)      Urge States to inform ICAO regularly of their halon reserves, and directs the Secretary General to report the results to the Council.  Further, the Council is directed to report on the status of halon reserves at the next Ordinary Session of the Assembly; and
c)      Resolve that the Council shall report to the next ordinary session of the Assembly on progress made developing halon alternatives for cargo compartments and engine/auxiliary power unit fire extinguishing systems as well as the status of halon alternatives for hand held fire extinguishers.
2.4                                       The process to amend Annexes 6 and 8 began in November 2010 and the proposal was adopted by the ICAO Council on 13 June 2011.
2.5                                       IHRCM/2 provided an opportunity for the various stakeholders to update and discuss on the following:
a)      the status of lavatory fire extinguishing systems;
b)      the status of halon alternatives for hand-held fire extinguishers;
c)      the progress made in the development of halon alternatives for engine/auxiliary power unit and cargo compartment fire extinguishing systems; and
d)      the reporting of halon reserves by States.
2.6                                       IHRCM/3 further updated and discussed with the stakeholders on the following:
a)      the status on the development of potential halon alternatives to support the agreed upon implementation dates, including halon alternatives for cargo compartment fire suppression systems;
b)      the issues associated with the quality of recycled halon;
c)      the progress of the implementation of the requirements of Annex 6 and Annex 8 for halon replacement;
d)      the States responses to the ICAO State questionnaire on halon reserves; and
e)      the proposal of a tentative timeframe for the replacement of halon in cargo compartments.
3.                   AGENDA ITEM 1: OPENING OF THE MEETING
3.1               Place and duration
3.1.1                                  The third meeting of the International Halon Replacement Coordinating Meeting (IHRCM/3) was held at Boeing Commercial Airplanes, Long Beach, USA on 15 and 16 November 2012. IHRCM/3 was held in conjunction with the International Aircraft Systems Fire Protection Working Group (IASFPWG) meeting on 14 and 15 November 2012 to accommodate participants.
3.2               Opening remarks
3.2.1                                  The meeting started at 1430 hours on 15 November 2012.  Mr. Alain Coutu, Technical Officer Airworthiness, Air Navigation Bureau (ANB) welcomed the participants and provided the opening remarks. Mr. Coutu stated that this gathering was different from previous meetings as there were more participants present than when the original group of experts first convened in 2009. He informed the meeting that this group of experts had been tasked to support the Secretariat in providing a progress report on halon alternatives and halon reserves, which is to be submitted at the next Assembly. A brief introduction to the halon replacement in aircraft was presented and a brief discussion on the earlier IHRCMs.
3.3               Attendance
3.3.1                                  The meeting was attended by experts and observers from four States, EASA, ICCAIA and twenty industry organizations. Also attending the meeting via teleconference were representatives of ICCAIA and IATA. The list of participants is attached in Appendix A.
3.4               Meeting Chairperson
3.4.1                                  Mr. Dick Hill, Program Manager, Fire Safety Branch, International Aircraft Systems Fire Protection Working Group (IASFPWG), was the Chairperson of the meeting throughout its duration supported by Mr. Coutu.
3.5               Adoption of the agenda
3.5.1                                  The meeting adopted the following agenda:
Agenda Item 1:
Opening of the meeting
 
1.1
Opening remarks
 
1.2
Administrative remarks
 
1.3
Introduction of participants
 
1.4
Adoption of Agenda
Agenda Item 2:
Status report
 
2.1
Status report on the development of potential halon alternatives to support the agreed upon timeline.
 
2.2
Updates on the research and development made on halon alternatives for cargo compartment fire suppression systems.
Agenda Item 3:
Recycled halon
 
3.1
Updates on issues associated with the quality of recycled halon.
Agenda Item 4:
Progress made since IHRCM/2
 
4.1
Presentations and discussions on alternatives to halon and progress of implementation of the requirements of Annex 6 – Operation of Aircraft and Annex 8 – Airworthiness of Aircraft for halon replacement.
 
4.2
Report on halon reserves based on States’ responses to the ICAO State questionnaire on halon reserves.
Agenda Item 5:
Timeframe for halon replacement in cargo compartment
 
5.1       
Propose a tentative timeframe for replacement of halon in cargo compartments.
Agenda Item 6:
Any other business
Agenda Item 7:
Closing
4.                   agenda item 2: STATUS REPORT
4.1               Agenda Item 2.1 - Status report on the development of potential halon alternatives to support the agreed upon timeline.
4.1.1                                  Present status of halon replacement in aircraft
4.1.1.1                            Mr. R. Hill of FAA Technical Center, provided a presentation to update the meeting on the status of halon alternatives for lavatory extinguishers and potential alternatives for hand-held, engine nacelle/APU and cargo compartment extinguishers.
4.1.2                                  Lavatory extinguishers
4.1.2.1                            The meeting was informed that the approved halon replacement agents FM-200 and FE-36 had passed the FAA Minimum Performance Standards (MPS) tests and are certified under the US EPA Significant New Alternatives Programme (SNAP). Currently, all Boeing and Airbus aircraft use these replacement agents.
4.1.2.2                            Bombardier and Embraer informed the meeting that halon replacement agents in lavatory fire extinguishers will begin to be implemented as of January 2013.
4.1.3                                   Hand-held extinguishers
4.1.3.1                            The meeting was informed that the following replacement agents for halon 1211 meet MPS and are SNAP approved:
a)                   HCFC Blend B (Halotron 1);
b)                   HFC-227ea (FM-200); and
c)                   HFC-236fa (FE-36)
4.1.3.2                            However, these 3 agents, though approved for use, have yet to be installed as they are reported to be up to twice the weight, greater in volume and have up to seven times global warming potential (GWP) than halon 1211. To mitigate the issue of weight, Mr. Hill informed that the FAA Technical Center has begun a project for hand-held extinguishers design optimization to reduce weight. Considerations include nozzle and bottle design and bottle operating pressures. This project is not aimed at finding a replacement but at what can be done should 2BTP (2-bromo-3, 3, 3-trifluropropene) fails.
4.1.3.3                            The meeting was updated on new replacement agents being evaluated including 2BTP  which is awaiting SNAP approval and Underwriters Laboratories (UL) rating. This is a promising agent.
4.1.3.4                            Mr. Hill informed the meeting that the industry has agreed to use approved agents if better alternatives are not approved prior to the established ICAO date, 31 December 2016.
4.1.4                                  Engine nacelle / APU extinguishers
4.1.4.1                            The meeting was briefed that the following replacement agents have passed MPS and are SNAP approved:
a)                   HCF-125  (17.6% concentration);
b)                   FK-5-1-12 (Novec 1230) (6.1% concentration); and
c)                   CF3I  (7.1% concentration)
4.1.4.2                            Mr. Hill provided further information on some of these agents:
a)                   HFC-125
i)                                             used by the military;
ii)                                            major weight and volume penalty
b)                   Novec 1230
i)                    Novec 1230 is not functioning as required by the MPS at low ambient temperature;
ii)                  more R&D needed
c)                   CF3I
i)                   toxicity concerns
d)                   Kidde Solid Aerosol (KSA)
i)                     new non-gaseous agent;
ii)                    MPS developed concentrations unable to extinguish live engine fire;
iii)                  additional R&D needed
4.1.5                                  Cargo compartment extinguishing systems
4.1.5.1                            The meeting was informed that the following potential replacement agents have failed the cargo compartment MPS test:
a)                   HFC-125/FM-200: high HF concentrations, ignition of smoke layer;
b)                   CF3I: toxicity concerns;
c)                  2BTP/Novec 1230: overpressures at below inerting concentrations during aerosol can scenario
4.1.5.2                            However, the following developments are being considered for cargo compartment fire extinguishing systems:
                        a)         Integrated Fire Protection - Water Mist/Nitrogen System
i)          passed MPS in early 2010;
ii)                  promising concept but requires significant development and acceptance; and
iii)                 requires the use of the on-board inert gas generation system installed on aircraft to reduce fuel tank flammability
b)                  Airbus has proposed a halon knock-down nitrogen system for A350 that would reduce the use of halon by 50%
4.1.5.3                            MPS was developed in 2005 (DOT/FAA/AR-TN05/20) and now the FAA is considering adding a lithium battery scenario. There is nothing at this time indicating that an additional test and/or amendment to the MPS may be required.
4.1.5.4                            Mr. Hill added that there is a possibility that there may be a recommendation from NTSB to equip freighter airplanes with fire extinguishing systems.
4.1.6                                  BTP- Status
4.1.6.1                            Mr. B. Colton from AMPAC provided a status report on 2BTP (2-Bromo-3, 3, 3-Trifluoropropene). 2BTP was initially developed as a replacement agent for halon 1301. However, rresults of recent testing provided confidence that 2BTP could be used as a drop-in replacement for the halon 1211 fire extinguishers.
4.1.6.2                            2BTP still requires further tests including toxicology and UL leak tests. Regulatory review is expected to be completed by 2013. Commercialization for aviation is expected to follow after US and EU approvals, sometime in 2014.
4.1.7                                  Industry update – Challenges and solutions to halon replacement
4.1.7.1                            Mrs. Robin Bennett of ICCAIA provided a presentation and information paper on the challenges and solutions to halon replacement from the perspective of the industry stakeholders. This update is based on Boeing, Airbus, Bombardier, AIA discussions.
4.1.7.2                            The aerospace industry remains committed to implementing solutions but the new challenges need to be addressed, and more concerted engagement by all stakeholders is key.  ICCAIA recognized the progress made with lavatory and handheld fire extinguishing agents, yet challenges remain. Two engine and APU alternatives promising agents did not meet expected performance requirements under additional FAA testing. The industry is not optimistic that any current known agent will be certification-ready to meet the 31 December 2014 date. The cargo alternatives research continues for potential replacements.
4.1.7.3                            ICAO reiterated that the 2014 date is applicable to aircraft for which an application for type certificate is submitted on or after 31 December 2014. There are still a few years after that before the aircraft rolls out of the production line. ICAO is not ready to change the established date.
4.1.7.4                            Industry’s position continues to be that it is premature to establish halon replacement deadlines for cargo applications. The successful establishment of a replacement date requires full cooperation of all stakeholders with broader representation and more frequent engagement.
4.1.7.5                            ICAO Assembly Resolution A37-9 adopted in 2010 should consider the new challenges and an update should be made to provide flexibility to address potential situation of alternative solutions not being viable with current A37-9 deadlines similar to the provision in the halon regulation adopted by the EU.
4.1.7.6                            The EASA representative, Mr R Deletain, was asked what would be the process if an applicant did not have a halon replacement at the time of type certificate application after 31 December 2014. Mr. Deletain stated that considerations at certification level would be whether it is a rejection of the application because it doesn’t propose a replacement agent or an alternative means to show compliance at later date as a certification plan changes with time. He is uncertain of what the process would be. Mr Deletain will request the rulemaking department at EASA.
4.1.7.7                            The EU regulation provides for exemption if no alternatives exist but there is an alternative for engine and APU. HFC 125 is currently used by the military and although it has a weight penalty, it works.
4.1.7.8                            Regarding more engagements by stakeholders, ICAO offered the meeting as a forum if stakeholders wanted to start discussions and form a working group. ICCAIA offered to support an initiative to bring the stakeholders together and draft a roadmap.
4.2                                       Agenda Item 2.2 - Updates on the research and development made on halon alternatives for cargo compartment fire suppression systems
4.2.1                                  This agenda item was covered by the presentation in Agenda item 2.1.
4.2.2                                  Laptop and other thermal runaways in Lithium battery development
4.2.2.1                            Mr. Kent Faith from Sprectrum FX provided information on lithium battery fire and the available product for extinguishing. The available product is not a replacement for halon and is a supplemental kit to existing handheld extinguishers for lithium battery. The agent called Firebane is not rated for electrical fire as it is conductive.
Conclusion
Status report
Lavatory fire extinguisher:
1)      There are currently two approved halon replacement agents FM-200 and FE-36
 
2)      All new Boeing & Airbus aircraft presently use replacement agents and Bombardier and Embraer will begin using a replacement agent as of January 2013.
 
Handheld Fire extinguisher:
1)      There are currently three replacement agents that are approved but not installed:
a.       HCFC Blend B (Halotron 1)
b.       HFC-227ea (FM-200)
c.       HFC-236fa (FE-36)
 
These agents are up to twice the weight, are larger in volume, and have up to 7 times the GWP.
2)      The FAA is funding a project for fire extinguisher design optimization to reduce weight. Its focus is on:
a)      nozzle design;
b)      bottle design; and
c)      operating pressure
 
3)      Work continues to be done with 2BTP as it is a promising agent. Commercialization for aviation is planned for 2014. 2BTP does not have the environmental, size, or weight issues of existing approved halon replacement fire extinguishers agents.
 
4)      Industry has agreed to use approved agents if better alternatives are not approved prior to the ICAO date.
 
Engine/APU fire extinguisher:
1)      Three replacement agents have passed the MPS and are SNAP approved
a)      HCF-125  (17.6% concentration)
b)      CF3I  (7.1% concentration)
c)      FK-5-1-12 (Novec 1230)  (6.1% concentration)
 
2)      Novec 1230
·         not functioning as required by the MPS at low ambient temperature
·         agents use in question – More R&D needed
 
3)      CF3I
·         concerns with toxicity
 
4)      HFC-125
·         currently used by military
·         major weight and volume penalty
 
5)      Kidde Solid Aerosol (KSA) Testing
·         new non-gaseous agent
·         MPS developed concentrations unable to extinguish live engine fire.
·         additional R&D is in process
 
6)      The research is in progress and ICCAIA is not certain to be able to meet the target date of 2014 for the engine/APU fire extinguisher.
 
7)      There is a replacement but it has weight and volume property.
 
8)      The representative from EASA will inquire from the rulemaking department at EASA what would be the course of action at the certification level if the applicant for a type certificate doesn’t propose a replacement agent or alternative considering that a certification plan changes with time.
 
Cargo fire extinguisher:
1)      Replacement agents tested – failed MPS
a)      HFC-125/FM-200: high HF concentrations, ignition of smoke layer
b)      CF3I: toxicity concerns
c)      2-BTP/Novec 1230: overpressures at below inerting concentrations during aerosol can scenario
 
2)      Integrated fire protection - water mist/nitrogen system
·         passed MPS in early 2010
·         promising concept but requires significant development and acceptance
·         uses on-board inert gas generation system installed on aircraft to reduce fuel tank flammability
 
3)      Airbus has proposed halon knock-down nitrogen system for A350
 
4)      MPS was developed in 2005 (DOT/FAA/AR-TN05/20) and now the FAA is considering lithium battery scenario.  It may or may not require a new test and/or amendment to the MPS.
5.                   AGENDA ITEM 3: RECYCLED HALON
5.1               Agenda item 3.1 – Updates on issues associated with the quality of recycled halon
5.1.1                                  Halon supply and quality of recycled halon
5.1.1.1                            Mr. R. Marcus of RemTec provided the meeting with an insight to issues associated to the recycling of and the quality of recycled halon (1211, 1301, and 2402). The presentation informed the meeting of the supply and quality issues; recovery, reclamation and destruction processes; quality control and testing of recycled halon; and storage considerations.
The production of halon 1211 has ceased in industrialized countries since 1 January 1994 and U.S. excise taxes apply to both new and used Halon 1211 imported into the U.S.  Supplies of Halon 1211 are limited and the quality of used installed inventory is declining.
 
Halon 2402 is primarily used on Soviet Union / Russian military and commercial aviation equipment and worldwide supplies are limited.
 
The production of halon 1301 ceased in industrialized countries 1 January 1994 and critical users are aviation, petrochemical plus and equipment distributors servicing used equipment.
 
In 1993 the installed inventory was primarily in Japan, North America and Europe. After 20 years the supply of used Halon 1301 is dwindling, quality is declining especially if sourced from developing countries and many of those countries restrict the export of halons. Japan does not allow export of halon.
 
As the quality and supply of halons has decreased, the cost to procure and reclaim halons has increased, and in the last 5 years, the cost of procuring recovered halon 1301 has augmented 100%.
Cross-contamination is becoming more prevalent the farther we move away from virgin production end dates. As used halon and other “in demand” halocarbons become more expensive, the incentive to intentionally blend-in cheaper halocarbons such as R-22, forming increases.
5.1.1.2                            The presentation suggests that to successfully manage halocarbons, considerations should be made to:
a)      provide incentives to encourage recovery from end-users;
b)      institute safe handling practices;
c)      document and track agents and tanks;
d)      perform laboratory testing for both the incoming material and the out-going finished product;
e)      establish long-term strategic reserves for critical users; and
f)       continually conduct leak testing and periodic physical inventories.


Conclusion
Recycled halon
 
1)      As the quality and supply of halons has gone down, the cost to procure and reclaim halons has gone up and in the last 5 years the cost of procuring recovered halon 1301 has increased 100%.
 
2)      Halons are more difficult to recycle due to cross contamination.
 
3)      Cross-contamination is becoming more prevalent the farther we move away from virgin production end dates. As used halon and other “in demand” halocarbons become more expensive the incentive to intentionally blend in cheaper halocarbons such as R-22 increases.
 
4)      TCCA, in cooperation with the FAA, the UK CAA and EASA, has accordingly undertaken a study to identify means to minimize the probability that non-compliant/contaminated agents will be installed on aircraft. 
6.                   AGENDA ITEM 4 – PROGRESS MADE SINCE IHRCM/2
6.1                                       Agenda item 4.1 - Presentations and discussions on alternatives to halon and progress of implementation of the requirements of Annex 6 – Operation of Aircraft and Annex 8 – Airworthiness of Aircraft for halon replacement.
6.1.1                                  EASA progress and plans
6.1.1.1                            Mr. R. Deletain of EASA briefed the meeting on EASA’s Rulemaking Tasks (RMT) on halon replacement. The meeting was updated on the status of several RMTs.
In 2011 EASA initiated a rulemaking task to amend CS-23, CS-25 and CS-29 in order to be compliant with EU legislation and with the Amendment 103 to ICAO Annex 8. And in 2012 CS-23 and CS-25 have already been amended and CS-29 is being amended accordingly. The CS (Book 1) has no reference to either halon or any other extinguishing agent and AMC/GM (Book 2) explains the reason for halon being phased out referring to Regulation 744/2010.
 
The EU legislation implies compliance with applicable amendments to ICAO Annex 6 (i.e. newly produced aircraft based on existing Type Certificates) only in 2025 (for handheld fire extinguishers) and 2020 (for lavatories).  EASA has planned RMT.0560 to comply with the dates set in ICAO Amendments to Annex 6 which will be late for lavatories. It will comprise of an update of EASA part 26 and propose a forward fit for lavatory disposal receptacle and portable fire extinguishers in cabins and crew compartments. 
 
The halon alternatives are sufficiently safe and suitable for handheld and lavatories fire extinguishers bringing environmental benefits, with minimum economic impact on aircraft manufacturers. This proposal complies with current ICAO standards without a need for amending EU regulation 744/2010. The Notice of Proposed Amendment (NPA) will be available by mid-2013 and anyone can comment.
 
EASA has also mandated SAE (Society of Automotive Engineers) to develop Minimum Performance Standards for (halon free) portable fire extinguishers to be used in aircraft and an ETSO (European Technical Standard Order) will be published. There is a rule making task (RMT.0206) in process and the NPA will be available in 2013.
 
In order to align with ICAO Resolution A37-9 ‘halon replacement’ adopted during ICAO 37th General Assembly, amendments to of Part- 145 and Part-M shall be made. AMC/GM (Acceptable Means of Compliance /Guidance Material) will be developed for production and maintenance organizations to verify the quality of halon in their possession through testing and internal procedures. The notice of proposed amendment (NPA) is planned for Q3 of 2013.
 
The following is a summary of EASA actions:
 
 
RMT
STATUS
0273
New applications for TC
CS-23 & 25 amended
CS-29 amended before end 2012
0560
Newly produced aircraft
NPA planned in 2013
0206
ETSO for portable fire extinguishers
NPA planned in 2013
0368
Contaminated halon
ToR being drafted
NPA planned in 2013
??
Engine nacelles, APU and cargo compartments
No obligation of any agent in CSs
Additional RMTs could be planned
 
Filing of Differences
            Mr. Alain Coutu presented a summary of the differences filed by States regarding the standards relating to halon replacement:
 
Annex 6, 8
A 35 Annex 6
Part I, 6.2.2.1
(L, H)
A30  Annex 6
Part II, S II 2.4.2.3
(L, H)
A16  Annex 6
Part III, S II 4.2.2.1
(L, H)
A 6  Annex 6
Part III, S III 4.1.3.2
(L, H)
A103  Annex 8
Part II, 1.2.5
(L, E, A)
No Difference
13
20
17
16
19
Currently do not have such requirements
3
5
5
3
3
Will comply at a later Date
13
12
6
13
0
N/A
0
1
2
1
2
Total Replies
29
38
30
33
24
 
No States filed differences stating they would not comply with the Standards. Most States either declared no differences or would comply at a later date. The N/A means the States do not have the activity in their State at this time.
6.2                                       Agenda item 4.2 - Report on halon reserves based on States’ responses to the ICAO State questionnaire on halon reserves.
6.2.1                                  Responses to ICAO State Letter on halon reserves
6.2.1.1                            Mr. Coutu also updated the meeting on the responses received from States regarding halon reserve.
       In May 2012 ICAO issued State Letter AN 3/25.1-12/35 requesting information on halon reserves accessible to the civil aviation industry within States to follow-up on Assembly Resolution A37-9: Halon replacement, adopted by the 37th Session of the ICAO Assembly. The resolution urges States to inform ICAO regularly on their halon reserves of which ICAO is to report at the next Assembly, which will be held in September 2013.
 
       As of October 2012 ICAO received 53 Replies to the questionnaire on halon reserve.
 
 
       To question No.1; “With the ban ……..do you anticipate that there will be enough halon to meet the civil aviation needs of your State? Most States responded they were unsure of the halon reserve while others responded N/A as they purchase it from an outside source.
 
       To question No. 2; “Do you know the quantity of halon reserves accessible to the civil aviation industry in your State in order to support its future operations? Most States replied no, while several others replied N//A. Only 33 States replied they know their reserves, 16 for halon 1211 and 17 for halon 1301.
6.2.2                                  Estimated Global Inventories of Halons 1301 and 1211
6.2.2.1                            Mr. T. Cortina presented, on behalf of UNEP, their approach to estimate the amount of halon available. The presentation also discussed the ownership of halon by region, the challenges in procurement, and the availability of halon for civil aviation use.
No one “Knows” how much halon is left. We know the global yearly production data, the global yearly estimated emissions and comparing with atmospheric measurements of emissions we can estimates the reserves.
 
Global quantities are irrelevant unless owned by civil aviation.  Some States have import taxes while others have exporting laws prohibiting export of halon. It is not only a reserve issue but also a regulatory issue. Halon reserves are difficult to estimate as there are owners retaining supplies from decommissioned systems for own uses/stockpile, large users like the US Dept. of Defense and North Slope in U.S., maintain their own long-term reserves, and some airlines may have their own reserve.
 
Reliance on halon “Banks” has implications, one which is destruction for carbon credits. Ozone depleting substance (ODS) have high global warming potential (GWP) similar to HFC alternatives.
(i.e.: Halon 1301 = 7,140, HFC-227ea = 3,220)
US Climate Action Reserve provides greenhouse gas (GHG) offset credits for destruction of ODS (not currently halons) and Australia will have a carbon tax in July 2013, which will be an incentive for destruction of waste GHGs. Therefore users of halon could be competing in a market with companies looking to destroy halons for GHG credits.
6.2.3                                  UNEP assessment of the responses to ICAO State letter on halon reserve
There is a notable lack of response from States where we think there could be a lot of halon and where filling of bottles now occurs. Although some States have determined their supplies some did not know how much halon they had. While some States believe that there is enough halon we are not certain how they could determine that.
                                                                                                      
The following is a fairly typical answer of the survey responses. Brazilian aircraft manufacturers, Embraer and Helibras declared:
     The halon used to fill the fire extinguishers of their aircraft is provided by foreign suppliers.
Moreover, the two Brazilian airlines, TAM and Gol, that retain approximately 75% of the civil aviation domestic market in Brazil and are the only Brazilian airlines that operate international flights declared:
     The halon used to fill the aircraft fire extinguishers of their fleet is also provided by foreign suppliers.
ANAC is unaware of any Brazilian company that recycles halon to be used in aircraft fire extinguishers.
 
Therefore, the civil aviation halon needs in Brazil depend on the availability of halon in the countries that supply the Brazilian aircraft manufacturers and airlines.
 
On the subject of cargo compartment fire extinguishing agent replacement, this is the largest use of halon on aircraft and drives the quantities of halon needed for the long-term. With no end in sight, it makes estimates of needs impossible to determine.
 
European Union has end and cut-off dates. We need to consider now establishing a date for the replacement of halons in new designs aircraft and the ICAO end dates help to support commercial research and development of halon alternatives.
6.2.3.1                            The presentation concluded with UNEP suggesting the following:
a)                  the need to consider establishing a date to mandate implementation of halon alternatives for aircraft cargo compartment;
a)                    civil aviation still needs to determine the long term needs for halon, where the requirements will come from, and to report to Parties to the Montreal Protocol;
b)                  resend ICAO State Letter AN 3/25.1-12/35 to States’ ozone focal point to canvass a broader response from States to the State Letter; and
c)                  consider developing guidance on the collection and provision of information on halon for aviation needs and halon reserves.


Conclusion
Progress made since IHRCM/2
1)      EASA has begun rulemaking and the following is a summary of EASA actions:
 
RMT
STATUS
0273
New applications for TC
CS-23 & 25 amended
CS-29 amended before end 2012
0560
Newly produced aircraft
NPA planned in 2013
0206
ETSO for portable fire extinguishers
NPA planned in 2013
0368
Contaminated halon
ToR being drafted
NPA planned in 2013
??
Engine nacelles, APU and cargo compartments
No obligation of any agent in CSs
Additional RMTs could be planned
 
 
2)      Of the States who have filed differences, none have stated they will not comply, and although some States stated no differences, others stated they would comply at a later date.
 
Halon reserves:
1)      The HTOC model of global inventories of halon is based on:
a)      production data known prior to 1996;
b)      estimate of yearly emissions by region;
c)      estimate of yearly recovery rates; and
d)      similar results from atmospheric samplings validate the HTOC model
2)      The HTOC charts on the global inventories of halon 1301 and halon 1211 is given in Appendix 2.
3)      No one “knows” how much halon is left. We know the global yearly production data, the global yearly estimated emissions, and comparing with atmospheric measurements of emissions, it is possible to estimate the reserves.
 
4)      Global quantities are irrelevant unless owned by civil aviation.  Some States have import taxes while others have exporting laws prohibiting export of halon. Therefore it is not only a reserve issue but also a regulatory issue.
 
5)      Reliance on banks has the implications that States may destroy halon for Carbon Credits:
a)      ODS have high GWPs similar to HFC alternatives
                                                               i.      Halon 1301 = 7,140, HFC-227ea = 3,220
b)      US Climate Action Reserve provides GHG offset credits for destruction of ODS (not currently halons)
c)      Australia carbon tax, incentives for destruction of waste GHGs including ODS in July 2013
d)      users of halon could be competing in market with companies looking to destroy halons for GHG credits
                                                               i.      Current cost of Halon 1301 in US ≈ $33,000/tonne
                                                             ii.      At $20/tonne of CO2 equivalent = $142,800/tonne
6)      Responses from States to ICAO State letter on halon reserve for civil aviation:
a)      little evidence that States civil aviation and ozone offices worked together;
b)      notable lack of response from States where possibly there could be a lot of halon and where filling of bottles now occurs;
c)      little evidence that States know how much halon is available to civil aviation although some States believe there is enough halon, it must be difficult to determine; and
d)      resend ICAO State Letter AN 3/25.1-12/35 to States’ ozone focal point to canvass a broader response from States to the State Letter.
7)        European Union has end and cut-off dates. ICAO needs to consider now establishing a date for the replacement of halons in new designs aircraft and the ICAO end dates help to support commercial research and development of halon alternatives.
7.                   AGENDA ITEM 5: TIMEFRAME FOR HALON REPLACEMENT IN CARGO COMPARTMENTS
7.1               Agenda item 5.1 – Propose a tentative timeframe for the replacement of halon in aircraft cargo compartments.
7.1.1                                  Establishment of Timeframe
7.1.1.1                            Mr. Coutu briefed the meeting on the ICAO Standard making process. It was explained that should a decision be made on the timeframe for halon replacement in November 2012; the earliest applicable date for a Standard in Annex 8 would be March 2018 and therefore would be adjusted to the 31 December 2018 to correspond with EASA cut-off date.
ICCAIA reiterated that it is too early to commit to a replacement date and committing to a replacement date that the industry is uncertain of meeting. Aircraft designers may be hesitant to apply for a new type certificate.
 
A representative from Boeing stated that the process is difficult and flexibility is required. ICAO reiterated that the process of standard making will lead to a date for the replacement of halon in cargo compartment fire extinguishing system for new design aircraft. In the Standard making process a date cannot be left open, an implementation date is required.
 
UNEP stated that with a replacement date of 2019, it will have been 20 years since the production of halon ceased and States do not know how much  halon is available for use by aviation. Will a few more years help? If a date is not established now, it is likely that a replacement will be available in the near future.
 
UNEP asked the question: EASA has a dateline; what are the manufacturers going to do?
 
Airbus stated that it is a big discussion right now within the organization and that although very political and controversial they may have to request an exemption. At least, this flexibility is available.
 
The meeting asked how the new lithium battery test would impact the research. The representative of the FAATC stated that it will not affect the progression of the research.
 
FAATC also stated that it is expected that the National Transportation Safety Board may issue a recommendation for the installation of fire suppression system in cargo airplane.
 
The concept of a working group of the stakeholders was discussed again and could be used as a collaborative decision making process to achieve the establishment of an implementation date for the replacement of halon in cargo compartment.
 
ICCAIA committed to lead the initiative and several stakeholders present offered their support. The group should have a plan by early January 2013 that will provide a target date, by which the group should have reached consensus, on a replacement date for cargo compartment.
 
Conclusion
Timeframe for halon replacement in cargo compartment
1)      Research has not progressed rapidly enough.
2)      ICCAIA has proposed to lead an initiative to create a working group of stakeholders that will work together at creating a roadmap that would define the processes required, as well as the role of the stakeholders, and by January 2013 would propose a plan that would lead to the establishment of a target date for the replacement of halon.
8.                   AGENDA ITEM 6: ANY OTHER BUSINESS
8.1               Study Regarding Fire Extinguishing/Suppression Agents’ Quality Processes
Mr. Claude Lewis of Transport Canada briefed the meeting on their study. The quality of agents in fire extinguishing and suppression systems has been brought into question as a result of cases of contaminated halons found installed (or destined for installation) on aircraft.  TCCA, in cooperation with the FAA, the UK CAA and EASA, has accordingly undertaken a study to identify means to minimize the probability that non-compliant/contaminated agents will be installed on aircraft.  The study, which is being conducted  (under contract) by R.G.W. Cherry & Associates (UK ) is considering contamination potential for both new and recycled agents, from agent production to filled vessels installed on aircraft, and accidental, as well as intentional ‘opportunities’.  The project comprises two phases: 1) documenting the processes currently in use in North America and in Europe, and 2) analysis to identify best practices as well as deficiencies/gaps, and development of proposed standardized quality protocols. The first phase, which involved the polling of stakeholders (manufacturers, suppliers, recyclers, operators, test laboratories, etc.) is essentially completed.  Preliminary review indicates that there are differences between the processes used in North America and in Europe for the different ‘applications’, that there are no equivalent to UL/ULC in Europe, and that third party testing/sampling, when done, is an industry practice or is being conducted as a contractual obligation.  The second phase has just been initiated and is expected to be completed in early 2013.
9.                   AGENDA ITEM 7: CLOSING OF THE MEETING
9.1               The meeting was concluded and ICAO thanks all participants for sharing information and discussing these issues. The meeting objectives were met and positive results can be reported at the next assembly on the progress made with halon replacement.
The meeting ended at 1400 hours on 16 November 2012
 
— END —.



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