Up in the Air

By Bill Polits

We know this is “old news” but we thought we should double-check in case you missed it the first time…

On October 30, 2009 the EPA issued a rule on reporting for greenhouse gas (GHG) emissions in the US. If you import or export fluorocarbon fire extinguishing agents that amount to 25,000 metric tons of CO2 equivalent (MMTCO2e) annually, you will have report this activity to the EPA. The EPA wants to know about this kind of activity so that they can monitor the amount of GHG in the country (you might remember that on April 19, 2009, the EPA found that GHG's pose a risk to public health).

For all the details on this rule, please see 40 CFR Parts 86, 87, 89 et al. Mandatory Reporting of Greenhouse Gases; Final Rule.

High global warming potential (GWP) extinguishing agents that would fall under this rule include:

Agent               GWP

HFC 23             11,700            
HFC 125           2,800
HFC 227ea       2,900
HFC 236fa        6,300
FK 5-1-12         1

To determine if your annual imports/exports trigger the reporting requirement, do the following:

1. Determine the number of pounds per year imported/exported

2. Multiply the lb./yr. by the GWP for the agent in question, above

3. Divide the result by the number of lb. per metric ton (ca. 2205)

4. If the result is over 25,000, you must report per the rule.