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Halon - Commission to propose remove aviation's critical use exemption

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Halon - Commission to propose remove aviation's critical use exemption

Old 30th Apr 2009, 09:19
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Halon - Commission to propose remove aviation's critical use exemption

The European Commission (DG Environment) has issued proposals to remove the critical use exemption for certain halon based aviation safety applications. This will affect all halon based aviation safety applications for handheld fire extinguisers, APU/ engine nacelle and cargo compartments. Both military and civil aeroplanes would be affected.

EU deadlines, outside the ICAO framework, are proposed by DG-Environment for new production aeroplanes as well as for retrofitting all existing aeroplanes.

The EU Member States (at the level of Ministries of Environment represented in the Regulation 2037/2000 ‘comitology’ Committee) have been asked submit their written comments to the European Commission (DG Environment) by 31st May 2009 r. Based on those comments, the European Commission plans to make a new proposals to be voted through comitlogy in October 2009.

DG Environment has ignored the concerns of the entire aviation industry in relation to our safety concerns (all existing alternatives to Halon are less effective in fire fighting capabilities), huge cost impact and questionable environmental benefits (increased weight and Co2 emissions) if aviation would be forced to face out halon based safety applications before viable and safe alternatives are available.

In particular the Commision does not recognize the fact that no viable alternatives available for handheld extinguisher in aircraft (the Commission proposes a 2011 mandate for new production aeroplanes with retrofit of in-service aeroplanes proposed by 2020). All existing alternatives are less effective in fire fighting capability (=safety concern) and have additional weight (and as a consequence extra fuel burn and Co2 emissions which means that the environment justification is also questionable in respect of EU anti-climate change objectives). Therefore no dates should be decided (even not for new production aeroplanes) before safe and viable alternatives are available and the focus should be on further research. Retrofit by 2020 is even more questionable since retrofit probably would mean a complete retrofit of aircraft cabins (due to different size of the bottles etc). ICAO is not discussing any retrofit in this context so why should EU airlines alone be burdened?


In conclusion it seems DG-Environment is willing to comprise aviation safety, does not care about cost impact on the aviation industry and indeed is even willing to comprise its own anti-climate change objectives for a purely political agenda on halon replacement ref ozon layer protection (even although halon based aviation safety applications are only used in real safety emergency cases which means they impact on the ozon layer of their use by civil aviation is negligible). We therefore need to make sure that the EU Member States reject those proposals.
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Old 30th Apr 2009, 10:10
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If ever there was a case for ignoring an EU ruling. This is it. Once an equal alternate is found fine. But for now I don't want to be sitting up the pointy end with a fire somewhere that we're not able to control effectively. All the while some well fed EU chap sits behind his desk sucking on pencils, tuttering to the smoking hole on the TV. No thanks.
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Old 30th Apr 2009, 12:06
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The current discussions on FTL (EASA/Moebus report) are not safety related, they are related to working conditions. Off course the airlines, like any normal business, are concerned about cost. This does not need to go in contradiction with safety. The simple fact is that if you think that safety is expensive, just try an accident.

This is a thread about Halon & Fire Extinguishers. if you want to open another discussion about FTL, I suggest you open another thread.
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Old 30th Apr 2009, 14:46
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I've seen what Halon extinguishers do in a fire, both enclosed and open, as have most of us who've been around long enough. I've also seen what the "next best alternative does" too.

If they ban Halon in aircraft, I might just hang up my wings...I don't EVER want to be in an aircraft aloft without it.

This is a far more serious issue than I've encountered in a long time. Any one have any EU commissioners' phone or Email adresses?
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Old 30th Apr 2009, 15:22
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This policy has already been imposed in the offshore oil and gas world where gas turbine enclosures are now "protected" by the "next best alternative" CO2 or water mist. Both of these alternatives are unsuitable for aircraft and this ruling should be opposed. Are the alternatives as good as Halon? No!
As Halon is only used on an aircraft when there is a fire and is consumed in the ensuing reaction I cannot see how this is an environmental threat. Offshore we had so many false alarms and discharges that a large proportion of the halon inventory diid end up in the sky and the concerns of the environmentalist were understood. But aircraft are completely different. If they are expecting CC to don BA sets and enter holds with dry powder then these EU folk are on another planet.
You will find your MEP's e-mail address on the EU website. Google MEP EU.
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Old 30th Apr 2009, 16:03
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I am not an expert on the pros and cons of Halon, beyond knowing what most people - and I - believe, that it is the only effective means of fighting certain airborne fires and that taking it out of use without an alternative would reduce safety.

But I do know that the body responsible for the safety of EU aircraft operators is EASA, and that if the Commission is proposing something dangerous, EASA's role is to stop it.

The UK is represented within EASA by the CAA, and of course the SRG will be pro-actively and energetically making sure that safety, in the UK at least, is not comp.......

Ah, well, yes, I do see the problem.

PS After writing that, I did what I should have done first, ie a bit of research. After discovering that CAA stands for Clean Air Act, I drilled down to this interesting document on the SRG's website. Mind you, I don't think some ppruners will be too happy about it.
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Old 30th Apr 2009, 16:16
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[email protected] (acting head of unit)

[email protected] (deals with the dossier in the unit of the above)

[email protected] (acting director)
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Old 30th Apr 2009, 16:33
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Halon is to be discontinued because it affects the ozone layer around the Earth? If that is so then maybe someone can contradict the following remarks or let the EU/Politicians allow the aviation industry to use Halon [nothing really works as an alternative ] as it isn't being used all day, every day.

"There isn't now, nor has there ever been a so-called 'hole' in the ozone layer.
It's just thinner in some places than in others at times.
It is the sun which creates the ozone layer, and over the poles is where this thinning occurs on an annual basis. It is at a minimum level in early spring and rapidly increases in the next few months, then begins to decline as the winter approaches. The minimums occur in September/October over the Antarctic and in March/ April over the Arctic.
This makes perfect sense to me since these are the periods of time when each pole is coming out of their winter period with minimal solar activity or solar exposure.
If the so-called 'hole' is larger this year than last year also makes sense since we are currently at the bottom of the 11 year cycle of solar sunspot activity which will also have an impact on ozone production.

This anomaly was first documented in the late 1950's but could not be explained at the time, and now that we have satellite data and more accurate and sophisticated equipment to measure the atmosphere, the evidence should point out what should be obvious, but science abuse still continues."

Anyone care to disprove the above statement?
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Old 30th Apr 2009, 16:38
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There is absolutely no doubt that halogenated hydrocarbons such as Halon have a destructive effect on the ozone layer, that is basic chemistry.

However the amount released by aircraft extinguishing systems is so miniscule and so rarely released that I cannot see how it would have any real effect.

Also I'm sure a crashed aircraft due to an uncontained fire due to no Halon suppressant system would have a fair more detrimental effect on the environment than the alternative.......
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Old 30th Apr 2009, 18:06
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An average EU airline emits around 1kg of Halon per year. This is not really a suprise since halon is only used in real emergency cases.

Apart from safety and cost, there are also environmental arguments against most halon replacements. Most replacements are heavier... as we know even a few kilo's extra weight on an aircraft means 1000s of kg of extra fuel burn and co2 emissions per year.

The folks from DG-environment even do not want to understand that their plans on halon replacement are even countra productive for the EU climate change objectives....

It is a typical example of EU regulation for the sake of regulation. unfortunately with decreased aviation safety margins as a consequence...

All should ask their Member States and MEPs to protest and to block those ill-conceived proposals.

Regretably environment ministries are in charge and are only supposed to 'consult' their Ministries of Transport and CAAs...

As regard EASA, they have been rather silent on this issue apart from supporting the 'political' will to replace halon rather than identifying safety concerns with some of the (heavier) alternatives
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Old 30th Apr 2009, 19:26
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As I read it, does this mean that after 2011, if I wanted to order some Boeings for a hypothetical EU based transatlantic airline they would have to have non-Halon extinguishers?

Would my (hypothetical) non EU competitors be burdened with the same regulations?



S78
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Old 30th Apr 2009, 21:15
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My name is Darren Boyle. I am a journalist with the Irish Sunday Mirror newspaper.
Now I know that you gentlemen and ladies dislike members of the media because "the pilot wrestled with the controls narrowly avoiding a convent" stories.
But this story screams "barmy Eurocrats risk jet smash horror in hair-brained environment scheme" "ace pilots threaten to quit as planes faces fire hell"
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Old 30th Apr 2009, 21:27
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"barmy Eurocrats risk jet smash horror in hair-brained environment scheme"
I don't suppose they could be invited to a suitable airfield with a practice fuselage and invited to control a fire from inside the aircraft (simulating problems at altitude), first with a halon system, and then with the proposed alternative? Either they'd get the hint or we'd have to vote in a new lot having toasted the current lot. I bet the new lot wouldn't make the same mistake.
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Old 1st May 2009, 11:08
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where is the currently installed Halon supposed to go?
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Old 1st May 2009, 11:44
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where is the currently installed Halon supposed to go?
Easy to dispose of the Halon in a non-environmentally damaging manner.

The bigger question is, what on Earth do you replace the Halon with ?????
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Old 1st May 2009, 13:05
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The concept of an oxygen/fuel fed engine is that there are extremely high temperatures created in the combustion chamber to produce the necessary energy that ultimately provides the thrust necessary for flight. On the rare occasion, fuel and ignition occur outside of the combustion chamber. In simple words, an engine fire results.

In even simpler terms, once an engine fire occurs, the basic survival of the aircraft depends entirely on extinguishing the fire. The engine fire procedures call for the pilots to shut off the fuel, the hydraulics and the electrics supply to/from the affected engine.

Once the above actions have been carried out, the pilots then activate the main fire extinguisher bottle to the affected engine. If after 30 seconds, the engine fire has not being extinguished, then the pilots will activate the back-up extinguisher bottle.

If the fire continues, the aircraft and its occupants are doomed unless the pilots can land the aircraft in a matter of a few minutes before the fire will cause structural failure and the aircraft will plummet to earth in a fiery smoky trail.

The best extinguisher known to man for aviation application at this stage in history, is Halon. Every other extinguisher agent comes a very poor second best. If aircraft manufacturers and airlines are forced to use the inferior agents by the EU or any other governing body, many fatalities will result as a direct result.

As aviators and passengers, we should all lobby for an open hunting season on "greenies", "tree-huggers" and inane politicians to try to tip the balance to bring some commonsense back into the equation of the importance human life and its continued co-existence on and the long term maintenance of this planet.
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Old 1st May 2009, 16:23
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There are several Halon replacements currently in use in non aviation applications (Computer rooms ) etc

HFC 125 Pentafluoroethane

HFC-227 or HFC-227ea
The above two examples have a huge greenhouse gas penalty eg 3000 to 12000 more than CO2


Novec 1230, C6F12O, (3m Novec 1230) fluid is an environmentally friendly Halon replacement for use as a gaseous fire suppression agent.

31 DECEMBER 2002
The last day that existing Halon systems may be recharged with recycled or reclaimed Halon. After this date, if a Halon suppression system discharges it is effectively useless.

31 DECEMBER 2003
By this date all existing Halon systems must have been decommissioned and the Halon itself must have been disposed of by an approved contractor. Halon portable extinguishers must also be taken out of service by this date. Halon therefore now has a negative value, requiring certified disposal.

The above two dates are for non aviation uses
IIRC In the EU the cut off date for any production is dec 31 2025 HTSH
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Old 1st May 2009, 18:09
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Originally Posted by Humpmedumpme
Not sure, but some greeny would probably take you to court for wilful damage to the environment if you decided to use a Halon extinguisher to fight a fire.
Basically, no matter what a pilot does, in the current legal environment they'll get their arse sued for something.
Isn't it about time that organisations like IFALPA, BALPA, any other associations and federations, you name it.... took the EU organisation involved to court, on charges of "wilfully endangering human life" and "misuse of public funds" (for having started the study in the first place, doing the usual empire building, and lining their pockets)?

Other issues such as "gross incompetence" and "wilfully misleading the public" unfortunately are not actionable quite as easily in court.

As a sop to the "greenies", it can then also be pointed out in court, that the "carbon footprint" of any alternative to Halon will be far greater than the effect of the minute amount of Halon released into the atmosphere each year.

CJ
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Old 1st May 2009, 18:24
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Excuse the interjection from an non-pilot, non-firefighting, environmentally-conscious but non-litigious desk jockey who's extinguished many fires over the years with water, power and CO2 but never Halon.

While I've no doubts of the considerable safety advantages of using Halon in a confined space, could anyone point me to a study comparing the efficacy of Halon over CO2?

tia
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Old 1st May 2009, 18:34
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Originally Posted by FlexibleResponse
As aviators and passengers, we should all lobby for an open hunting season on "greenies", "tree-huggers" and inane politicians ....
I don't think that's the answer...

This issue is far more serious.

Apart from the court action I mentioned, I'm all with Mr Scoop....
A major effort in the media: "Eurocrats condemn airline passengers to burn to death to 'protect' the environment", maybe?

llondel suggested "...they could be invited to a suitable airfield with a practice fuselage and invited to control a fire from inside the aircraft (simulating problems at altitude), first with a halon system, and then with the proposed alternative."
All for it, it would make great TV.

Then make sure that the actual court case, as the first manifestation of "common sense against euro-mania" gets full publicity as well.

And what about a little flyer in each safety instruction booklet in the aircraft?
"This aircraft is protected by Halon fire extinguishing systems. Unless YOU act, Eurocrats will soon be removing that protection".
Follows a brief description, and a protest to fill out. Make it easy to fold, and make it Freepost.

CJ
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