On September 23, 2021, the United States Environmental Protection Agency (EPA) finalized rules pertaining to the American Innovation and Manufacturing Act (AIM Act). In December, the AIM Act was passed by Congress and signed into law. Within the AIM Act, the EPA has mandated a phased drawdown of hydrofluorocarbons (HFCs). This drawdown began January 1, 2022, and will ultimately reduce HFC production in a step-down fashion to 15 percent of its baseline level by the year 2036.
The overall category of HFC gases is overwhelmingly comprised of mostly refrigerants, coolants, aerosol propellants and foams, along with many others. On a much smaller scale, two very popular Clean Agent Fire suppression agents: FM-200 (HFC-227ea) and ECARO-25 (HFC-125), are also composed of HFC gases and are, unfortunately, immediately affected by this overall phasedown schedule.
The long-term impact on the availability of FM-200 and ECARO-25 is yet to be determined, as there is language in the act that will allow for “sector-specific” HFCs to be granted exemptions. Two of the six current exemptions do include HFCs used in specific fire protection applications, military and aerospace, but the exemptions as currently written do not carry over to the private sector. Petitions for public and private sector considerations have been submitted but may take months to gain approval, if at all, and be re-written into the legislation.
As such, we have no choice but to prepare for the immediate impact of this act on these popular products used to protect your own mission critical applications. The production of new FM-200 and ECARO-25 is declining sharply as of January 1, 2022, meaning the availability of new inventory will be reduced substantially. Subsequently, while FM-200 and ECARO-25 will still be available for purchase for years to come, the cost per unit pound of agent has increased significantly from the agent manufacturers. This is certain to affect project budgets and the cost competitiveness of FM-200 and ECARO-25 versus other commercially available “un-regulated” products, such as 3MTM Novec 1230 Fire Suppression Fluid.
In light of all this, Hard Fire Suppression Systems is transitioning our pending quotes that included FM-200 or ECARO-25 to Novec 1230 fire protection fluid. We are also quoting recharge from these two AIM Act casualty agents to Novec 1230.
If you have any questions about this act or how it affects your clean agent fire suppression system, please give us a call at (614) 882-2990 or contact us.