Advisory Circular (AC) No. 500-030

Subject: Alternative Agents for Aircraft Fire Extinguisher System

Issuing Office:	Civil Aviation, Standards
Document No.:	AC 500-030
File Classification No.:	Z 5000-34
Issue No.:	01
RDIMS No.:	16095108-V10
Effective Date:	2021-10-13

1.0 Introduction
2.0 References and requirements
3.0 Background
4.0 Relevant Canadian environmental legislation
5.0 International and domestic aeronautical standards and regulations
6.0 Alternative extinguishing agents
7.0 Acceptable means of compliance
8.0 Information management
9.0 Document history
10.0 Contact us

1.0 Introduction

(1) This Advisory Circular (AC) provides information and guidance about alternative agents for aircraft fire extinguisher system. It describes acceptable means, but not the only means, of demonstrating compliance with regulations and standards. This AC on its own does not change, create, amend or permit deviations from regulatory requirements, nor does it establish minimum standards.

1.1 Purpose

(1) The purpose of this AC is to:
- (a) Explain the need to discontinue the use of halon 1211 and halon 1301 in aircraft fire extinguisher systems (including hand-held fire extinguishers);
- (b) Identify the Canadian environmental and aeronautical regulations applicable;
- (c) Provide information about available alternative extinguishing agents;
- (d) Describe acceptable means of compliance to certify alternative agents for aircraft fire extinguisher systems; and
- (e) Complement Federal Aviation Administration (FAA) AC 20-42D by providing information that is missing and replacing information that is not applicable to Canada.
This AC does not provide guidance related to hand-held fire extinguisher number, location, accessibility, and markings. For guidance on these topics refer to FAA’s ACs 20-42D and 25-17A, or later revision.

1.2 Applicability

(1) This AC is applicable to all Transport Canada Civil Aviation employees, to individuals and organizations when they are exercising privileges granted to them under an External Ministerial Delegation of Authority. This information is also available to the aviation industry for information purposes.

1.3 Description of changes

(1) Not applicable.

2.0 References and requirements

2.1 Reference documents

(1) It is intended that the following reference materials be used in conjunction with this AC:
- (a) Aeronautics Act (R.S.C., 1985, c. A-2);
- (b) Part VI, Subpart 2 of the Canadian Aviation Regulations (CARs) — Operating and Flight Rules;
- (c) Part VI, Subpart 4 of the CARs — Private Operations;
- (d) Part VII, Subpart 4 of the CARs — Commuter Operations;
- (e) Part VII, Subpart 5 of the CARs — Airline Operations;
- (f) Chapter 523 of the Airworthiness Manual (AWM) — Normal, Utility, Acrobatic and Commuter Category Aeroplanes;
- (g) Chapter 525 of the AWM — Transport Category Aeroplanes;
- (h) Chapter 527 of the AWM — Normal Category Rotorcraft;
- (i) Chapter 529 of the AWM — Transport Category Rotorcraft;
- (j) Canadian Environmental Protection Act S.C., 1999, c. 33;
- (k) Federal Halocarbon Regulations (SOR/2003-289);
- (l) Ozone-depleting Substances and Halocarbon Alternatives Regulations (SOR/2016-137);
- (m) New Substances Notification Regulations (Chemicals and Polymers) (SOR/2005-247);
- (n) Environment and Climate Change Canada and Health Canada Guidelines for Notification and Testing of New Substances: Chemicals and Polymers;
- (o) Environment and Climate Change Canada and Health Canada Guidance Document for the Notification and Testing of New Chemicals and Polymers;
- (p) Environment and Climate Change Canada Domestic Substance List;
- (q) 2016 Joint Federal and Provincial Plan — Pan-Canadian Framework on Clean Growth and Climate Change;
- (r) Canadian Council of Ministers of the Environment, May 2001 — Canada’s Strategy to Accelerate the Phase-Out of CFC and Halon Uses and to Dispose of the Surplus Stocks;
- (s) United Nations Environment Program Ozone Secretariat — The Handbook for the Montreal Protocol on Substances that Deplete the Ozone Layer (Thirteenth Edition, 2019);
- (t) International Civil Aviation Organization (ICAO) Annex 6 — Operation of Aircraft (July 2018 Edition);
- (u) ICAO Annex 8 — Airworthiness of Aircraft (July 2018 Edition);
- (v) United States Title 14 of the Code of Federal Regulations part 25 — Airworthiness Standards: Transport Category Airplanes;
- (w) Federal Aviation Administration Advisory Circular 20-42D, January 14, 2011 — Hand Fire Extinguishers for Use in Aircraft;
- (x) United States Department of Transportation Report DOT/FAA/AR-96/122, February 1997 — Development of a Minimum Performance Standard for Lavatory Trash Receptacles Automatic Fire Extinguishers;
- (y) United States Department of Transportation Report DOT/FAA/AR-01/37, August 2002 — Development of a Minimum Performance Standard for Hand-Held Fire Extinguishers as a Replacement for Halon 1211 on Civilian Transport Category Aircraft;
- (z) United States Department of Transportation Report DOT/FAA/TC-14/50, February 2016 — Stratification and Localization of Halon 1211 Discharged in Occupied Aircraft Compartments;
- (aa) United States Environmental Protection Agency — Significant New Alternative Policy Program;
- (bb) European Union Aviation Safety Agency — Certification Specifications and Acceptable Means of Compliance for Large Aeroplanes (CS-25);
- (cc) ASTM International Standard ASTM D6064-11 — Standard Specification for HFC-227ea, 1,1,1,2,3,3,3-Heptafluoropropane (CF3CHFCF3);
- (dd) ASTM International Standard ASTM D6541-11 — Standard Specification for HFC-236fa, 1,1,1,3,3,3-Hexafluoropropane (CF3CH2CF3);
- (ee) ASTM International Standard ASTM D8060-17 — Standard Specification for 2-Bromo-3,3,3,-Trifluoro-1-Propene (CF3CBr=CH2);
- (ff) ASTM International Standard ASTM D8061-16 — Standard Practice for Handling, Transportation, and Storage of 2-Bromo-3,3,3-Trifluoro-1-Propene (CF3CBr=CH2);
- (gg) Radio Technical Commission for Aeronautics DO-160G, December 8, 2010 —Environmental Conditions and Test Procedures for Airborne Equipment;
- (hh) Underwriters Laboratories of Canada Standard ULC-S508:2018 (UL-711), Eight Edition, August 6 2018 — Rating and Fire Testing of Fire Extinguishers;
- (ii) Underwriters Laboratories of Canada Standard ULC-S566:2017 (UL-2129), January 5, 2017 — Standard for Halocarbon Clean Agent Fire Extinguisher; and
- (jj) Colton B. and Poet T., August 27, 2021 Revision 1 — Setting Acute Exposure Limits for Halotron^® BrX (2-Bromo-3,3,3-Trifluoropropene) Clean Agent On Board Aircraft Using Physiologically Based Pharmacokinetic Modeling.

2.2 Cancelled documents

(1) Not applicable.

2.3 Definitions and abbreviations

(1) The following definitions are used in this AC:
- (a) Ozone-Depletion Potential: Relative value that indicates the potential of a substance to destroy ozone gas as compared with the potential of chlorofluorocarbon-11 (CFC-11), which has a reference value of one.
- (b) Global Warming Potential: It is a measure of how much heat a greenhouse gas traps in the atmosphere up to a specific time horizon (usually 100-year time horizon), relative to carbon dioxide. It compares the amount of heat trapped by a certain mass of the gas in question to the amount of heat trapped by a similar mass of carbon dioxide and is expressed as a factor of carbon dioxide (whose global warming potential is standardized to one).
- (c) No Observable Adverse Effect Level: Greatest concentration or amount of a substance, found by experiment or observation, which causes no detectable adverse alteration of morphology, functional capacity, growth, development, or life span of the target organism under defined conditions of exposure.
(2) The following abbreviations are used in this AC:
- (a) AC: Advisory Circular
- (b) APU: Auxiliary Power Unit
- (c) AWM: Airworthiness Manual
- (d) CAR: Canadian Aviation Regulation
- (e) CAS: Chemical Abstract Services
- (f) CEPA: Canadian Environmental Protection Act
- (g) CFC: Chlorofluorocarbon
- (h) CPA: Cabin Pressure Altitude
- (i) ECCC: Environmental and Climate Change Canada
- (j) FAA: Federal Aviation Administration
- (k) FHR: Federal Halocarbon Regulations
- (l) GWP: Global Warming Potential
- (m) HC: Health Canada
- (n) HF: Hydrogen fluoride
- (o) HFC: Hydrofluorocarbons
- (p) ICA: Instructions for Continued Airworthiness
- (q) ICAO: International Civil Aviation Organization
- (r) MPS: Minimum Performance Standards
- (s) ODP: Ozone-Depletion Potential
- (t) ODS: Ozone-Depleting Substance
- (u) ODSHAR: Ozone-depleting Substances and Halocarbon Alternatives Regulations
- (v) PBPK: Physiologically Based Pharmacokinetic
- (w) RTCA: Radio Technical Commission for Aeronautics
- (x) SARPs: Standards and Recommended Practices
- (y) SNAP: Significant New Alternative Policy
- (z) UL: Underwriters Laboratories
- (aa) ULC: Underwriters Laboratories of Canada
- (bb) US EPA: United States Environment Protection Agency
- (cc) UV: Ultraviolet
- (dd) UVB: Ultraviolet-B
- (ee) UVC: Ultraviolet-C

3.0 Background

(1) In the stratosphere, the ozone-oxygen cycle (Chapman Cycle) permanently creates and destroys ozone molecules. As long as the cycle remains in equilibrium, the amount of ozone in the stratosphere remains constant. The benefit of atmospheric ozone is its capacity to absorb ultraviolet (UV) radiation from the sun, including particularly harmful ultraviolet-C (UVC) (99%) and ultraviolet-B (UVB)-type (90%) rays. Exposure to UVB radiation increases risk of skin cancer and cataracts, as well as damage to plants and marine ecosystems. Atmospheric ozone is sometimes labeled as the "good" ozone, because of its protective role, and should not be confused with tropospheric, or ground-level, "bad" ozone, a key component of air pollution that is linked with respiratory disease.
(2) In 1974, Mario Molina and Sherwood Rowland, two chemists at the University of California, Irvine, published an article in the scientific journal Nature detailing threats to the ozone layer from chlorofluorocarbon (CFC) gases. At the time, aerosol sprays and coolants in many refrigerators used CFCs. As they reach the stratosphere, the sun's UV rays break CFCs down into substances that include chlorine. The groundbreaking research—for which they were awarded the 1995 Nobel Prize in chemistry—concluded that the atmosphere had “finite capacity for absorbing chlorine” atoms in the stratosphere. By a chain reaction process, one atom of chlorine can destroy more than 100,000 ozone molecules, according to the United States Environmental Protection Agency, eradicating ozone much more quickly than the ozone-oxygen cycle can replace it, and disrupting the equilibrium of the ozone creation-destruction cycle.
(3) Molina and Rowland’s work received validation in 1985, when a team of English scientists found a hole in the ozone layer over Antarctica later linked to CFCs. The "hole" is actually an area of the stratosphere with extremely low concentrations of ozone that reoccurs every year at the beginning of the Southern Hemisphere spring (August to October). Spring brings sunlight, which releases chlorine into the stratospheric clouds.
(4) The recognition of the harmful effects of CFCs and other ozone-depleting substances (ODS) led to the Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol) in 1987; this agreement to phase out those substances was ratified by 197 United Nations member countries. According to the United Nations Environment Programme, in the decades that followed, the implementation of the Montreal Protocol helped prevent millions of cases of skin cancer and eye cataracts and phased out 98% of the production and consumption of ODS.
(5) Unfortunately for the aviation industry, the fire extinguisher agents of choice are ODS (halon 1211 and 1301). Similar to CFCs, when halons escape into the atmosphere they are broken down by solar radiation and release chlorine, fluorine and bromine atoms, which, in a chain reaction, destroy ozone molecules. This reaction also disrupts the equilibrium of the ozone creation-destruction cycle, contributing for the thinning of the ozone layer.
(6) Two types of fire extinguisher agent delivery methods are employed in the aviation industry: total-flood and streaming.
(7) In the total-flood method, the flight crew discharges an extinguishing agent into an enclosed space to achieve a concentration sufficient to extinguish or suppress an existing fire. The agent concentration that a system/agent combination is designed to produce is termed the “design concentration.” Total-flood extinguishment usually uses fixed systems with either manual or automatic activation. Automatic systems detect a fire and automatically discharge the extinguishing agent. Total-flood applications include protection of enclosed spaces, such as lavatory waste compartments, aircraft cargo compartments, engine and auxiliary power unit (APU).
(8) In the streaming method, a fire fighter applies the extinguishing agent directly onto a fire, or into the region of a fire. This is usually accomplished using manually operated portable extinguishers. Hand-held portable extinguishers used in aircraft cabins are one example of streaming application.
(9) Since their development, the most widely used fire extinguishing agents in civil aviation are halon 1301, bromotrifluoromethane (CBrF₃), used primarily as a total-flood agent; and halon 1211, bromochlorodifluoromethane (CBrClF₂), used primarily as a streaming agent. A joint venture between the United States Army and DuPont developed and introduced halon 1301 as an effective gaseous fire extinguisher agent for fixed systems in the 1960s. Also in 1960, halon 1211 first appeared as an effective gaseous fire extinguisher agent. These clean (residue-free) chemicals are effective against several classes of fires. However, they are not effective against combustible metal fires (Class D).

4.0 Relevant Canadian environmental legislation

(1) This AC briefly describes the following act and regulations due to their relevance to the subject discussed. The complete text of the legislation described herein, as well as additional information, is available at the Environment and Climate Change Canada (ECCC) website.
(2) The information provided in this section is based on the act and regulations presently in force. However, future revisions to this legislation will also be applicable.

4.1 Canadian Environmental Protection Act, 1999

(1) The Canadian Environmental Protection Act, 1999 (CEPA 1999) is one of the most important environmental laws in Canada governing the assessment and management of chemical substances. The purpose of the Act is to protect the environment, and the health and well-being of Canadians. A major part of the Act is to sustainably prevent pollution and address the potentially dangerous chemical substances to which Canadians might be exposed.
(2) CEPA first became a law in 1988. A review in the 1990's further strengthened its human health and environmental protection components. To distinguish between the two, "CEPA 1999" is the short name for the renewed Act.
(3) Together, ECCC and Health Canada (HC) are responsible for CEPA 1999. However, managing chemical substances in Canada requires the collective efforts of the Government of Canada, provinces and territories, municipalities, industry, health and environmental groups and other countries.

4.2 Federal Halocarbon Regulations, 2003

(1) In Canada, the federal, provincial and territorial governments have legislation in place for the protection of the ozone layer and management of ODS and their halocarbon alternatives. The use and handling of these substances are regulated by the provinces and territories in their respective jurisdictions, and through the Federal Halocarbon Regulations, 2003 (FHR 2003) for refrigeration, air-conditioning, fire extinguishing, and solvent systems under federal jurisdiction.
(2) ECCC published the FHR 2003 in August 2003 followed by an amendment in July 2009 under the authority of the CEPA 1999. The purpose of the FHR 2003 is to reduce and prevent emissions of ozone-depleting substances from air-conditioning, refrigeration, fire-extinguishing, and solvent systems that are:
- (a) Located on federal or aboriginal lands; or
- (b) Owned by federal departments, boards and agencies, Crown corporations, or federal works and undertakings.
(3) ECCC is responsible for the Federal Halocarbon Regulations.

4.3 Ozone-depleting Substances and Halocarbon Alternatives Regulations

(1) These regulations control the export, import, manufacture, sale and certain uses of ozone-depleting substances and products containing or designed to contain them. They also control the import, export and manufacture of hydrofluorocarbons.
(2) The Ozone-depleting Substances and Halocarbon Alternatives Regulations (ODSHAR) are the means by which Canada meets its obligations under the Montreal Protocol.
(3) The ODSHAR 2017 replaces the former Ozone-depleting Substances Regulation, 1998.
(4) ECCC is responsible for the ODSHAR.

4.4 Pan-Canadian Framework on Clean Growth and Climate Change

(1) The Pan-Canadian Framework on Clean Growth and Climate Change is Canada’s plan, developed with the provinces and territories and in consultation with Indigenous peoples, to meet our emissions reduction targets, grow the economy, and build resilience to a changing climate. The plan includes a pan-Canadian approach to pricing carbon pollution, and measures to achieve reductions across all sectors of the economy. It aims to drive innovation and growth by increasing technology development and adoption to ensure Canadian businesses are competitive in the global low-carbon economy. It also includes actions to advance climate change adaptation and build resilience to climate impacts across the country.

4.5 New Substances Notification Regulations (Chemicals and Polymers)

(1) The purpose of the New Substances Notification Regulations (Chemicals and Polymers) is to ensure that the Canadian Government is able to assess new substances (chemicals and polymers) for potential risks to human health and the environment and, if required, put in place control measures before they enter the Canadian marketplace.
(2) The regulations require any person (individual or company) proposing to import or manufacture a substance that is new to Canada above certain quantities to submit prescribed information to the Government of Canada.
(3) The government assesses the information to determine whether there is a potential risk to human health and to the environment. When the assessment identifies a risk, various mechanisms exist under the CEPA 1999 to manage that risk.
(4) For the purpose of complying with several sections of CEPA the Minister shall maintain a list to be known as the Domestic Substance List. This list is available to the public in the form of a database through the link below.

https://pollution-waste.canada.ca/substances-search/Substance?lang=en
(5) The New Substances Notification Regulations (Chemical and Polymers) came into to force in October 30, 2005.
(6) ECCC and HC are responsible for the New Substances Notification Regulations (Chemical and Polymers).

5.0 International and domestic aeronautical standards and regulations

5.1 International Civil Aviation Organization

(1) The following SARPs contain standards addressing aircraft fire extinguisher systems:
- (a) Annex 6, Operation of Aircraft; and
- (b) Annex 8, Airworthiness of Aircraft.
(2) Table 1 describes the sections of Annex 06, July 2018 edition, specifying the dates when the use of ODS listed in Annex A, Group II, of the Montreal Protocol, as fire extinguisher agents for newly manufactured aircraft, shall be stopped.
(3) Table 2 describes the sections of Annex 8, July 2018 edition, specifying the dates when the use of ODS listed in Annex A, Group II, of the Montreal Protocol, as fire extinguisher agents for new designs, shall be stopped.
(4) Annex A, Group II, of the Montreal Protocol, lists Halon 1211 and 1301.

(5) The information provided in this section is based on the SARPs presently in force. However, future revisions will also be applicable.

Table 1. ICAO Annex 6 (July 2018 Edition) Phase-Out Dates
for Halon 1211 and Halon 1301 Fire Extinguisher Agents
First Issue of Certificate of Airworthiness (Newly Manufactured)
Part	Aircraft Type	Chapter	Section	Extinguishing System	Phase-Out Date
I	Commercial Air Transport Aeroplanes	6	6.2.2.b	Lavatory Waste Compartment	31-Dec-2011
I	Commercial Air Transport Aeroplanes	6	6.2.2.1
II	General Aviation Aeroplanes	2.4	2.4.2.2.b
II	General Aviation Aeroplanes	2.4	2.4.2.3
III	Helicopters	4	4.2.2.b
III	Helicopters	4	4.2.2.1
I	Commercial Air Transport Aeroplanes	6	6.2.2.b	Cabin (portable)	31-Dec-2018
I	Commercial Air Transport Aeroplanes	6	6.2.2.1
II	General Aviation Aeroplanes	2.4	2.4.2.2.b
II	General Aviation Aeroplanes	2.4	2.4.2.3
III	Helicopters	4	4.2.2.b
III	Helicopters	4	4.2.2.1
n/a not applicable	n/a not applicable	n/a not applicable	n/a not applicable	Engine and APU	n/a not applicable
n/a not applicable	n/a not applicable	n/a not applicable	n/a not applicable	Cargo Compartment	n/a not applicable

Table 2. ICAO Annex 8 (July 2018 Edition) Phase-Out Dates
for Halon 1211 and Halon 1301 Fire Extinguisher Agents
Application for Type Certificate (New Design)
Part	Aircraft Type	Weight	Date of Application	Part/Chapter	Section	Extinguishing System	Phase-Out Date
IIIB	Large Aeroplanes	> 5700 kg	On or after 2-Mar-2004	II/1	1.1.c 1.2.6	Lavatory Waste Compartment	31-Dec-2014
IVB	Helicopters	n/a not applicable	On or after 13-Dec-2007
VA	Small Aeroplanes	> 750 kg ≤ 5700 kg	On or after 13-Dec-2007 but before 7-Mar-2021
VB	Small Aeroplanes	≤ 5700 kg	On or after 7-Mar-2021
n/a not applicable	n/a not applicable	n/a not applicable	n/a not applicable	n/a not applicable	n/a not applicable	Cabin (portable)	n/a not applicable
IIIB	Large Aeroplanes	> 5700 kg	On or after 2-Mar-2004	II/1	1.1.c 1.2.6	Engine and APU	31-Dec-2014
IVB	Helicopters	n/a not applicable	On or after 13-Dec-2007
VA	Small Aeroplanes	> 750 kg ≤ 5700 kg	On or after 13-Dec-2007 but before 7-Mar-2021
VB	Small Aeroplanes	≤ 5700 kg	On or after 7-Mar-2021
IIIB	Large Aeroplanes	> 5700 kg	On or after 2-Mar-2004	II/1	1.1.d 1.2.7	Cargo Compartment	28-Nov-2024

5.2 Transport Canada Civil Aviation

(1) The Canadian civil aviation legislative and regulatory structure consists of four elements: the Aeronautics Act, the Canadian Aviation Regulations (CARs), the associated Standards, including the Standards of Airworthiness in the Airworthiness Manual (AWM) and Advisory Materials.
(2) As of the time of writing of this AC, the following standards of airworthiness address aircraft fire extinguisher systems:
- (a) AWM Chapter 523, Normal, Utility, Acrobatic and Commuter Category Aeroplanes;
- (b) AWM Chapter 525, Transport Category Aeroplanes;
- (c) AWM Chapter 527, Normal Category Rotorcraft; and
- (d) AWM Chapter 529, Transport Category Rotorcraft.

(3) Table 3 identifies the applicable sections of the AWM presently in force.

Table 3. AWM Applicable Sections
AWM Chapter	AWM Change	Section	Title	Extinguishing System
523	12	851	Fire Extinguishers	Cabin (portable)
		855	Cargo and Baggage Compartments Fire Protection	Cabin (portable)
		1195	Fire Extinguishing System	Engine/APU
		1197	Fire Extinguishing Agents	Engine/APU
525	23	851	Fire extinguishers	Cabin (portable) Generic (built-in)
		854	Lavatory Fire Protection	Lavatory
		857	Cargo Compartment Classification	Cargo Compartment
		1195	Fire Extinguishing System	Engine/APU
		1197	Fire Extinguishing Agents	Engine/APU
527	10	859	Heating Systems	Combustion heater
529	8	851	Fire Extinguishers	Cabin (portable) Generic (built-in)
		853	Compartment Interiors	Cabin (portable)
		1195	Fire Extinguishing System	Engine/APU
		1197	Fire Extinguishing Agents	Engine/APU
		1307	Miscellaneous Equipment	Cabin (portable)

(4) The only standard from Table 3 that makes reference to halon 1211 or 1301 is subparagraph 525.851(a)(6) of the AWM. It is applicable to hand-held fire extinguishers and requires that at least one of the fire extinguishers located in the passenger compartment of an aeroplane with a passenger capacity of at least 31 and not more than 60, and at least two of the fire extinguishers located in the passenger compartment of an aeroplane with a passenger capacity of 61 or more must contain halon 1211, or equivalent, as the extinguishing agent.
(5) No other standard in Table 3 specifies the type of extinguishing agent.
(6) Presently, the AWM standards do not include any date to phase out the use of ODS listed in Annex A, Group II, of the Montreal Protocol, as fire extinguisher agents in new designs.
(7) As of the time of writing of this AC, the following CARs address aircraft fire extinguisher systems:
- (a) Part VI, Subpart 2 of the CARs — Operating and Flight Rules;
- (b) Part VI, Subpart 4 of the CARs — Private Operators;
- (c) Part VII, Subpart 4 of the CARs — Commuter Operations; and
- (d) Part VII, Subpart 5 of the CARs — Airline Operations.

(8) Table 4 identifies the applicable sections of the CARs presently in force.

Table 4. Applicable Sections of the CARs
CAR Subpart	Change	Section	Title	Extinguishing System
602	21	59	Equipment Standards	Cabin (portable)
602	21	60	Requirements for Power-Driven Aircraft	Cabin (portable)
604	7	119	Hand-Held Extinguishers	Cabin (portable)
704	8	83	Hand-Held Fire Extinguishers	Cabin (portable)
705	14	76	Lavatory Fire Protection	Lavatory Waste Compartment
705	14	93	Hand-Held Fire Extinguishers	Cabin (portable)

(9) The only provision of the CARs in Table 4 that requires a specific type of fire extinguisher agent is subsection 705.93(6) of the CARs. It is applicable to hand-held fire extinguishers and requires that at least two hand-held fire extinguishers shall contain halon 1211 or its equivalent.
(10) No other provision of the CARs in Table 4 specify the type of extinguishing agent.
(11) Presently, the CARs do not include any date to phase out the use of ODS listed in Annex A, Group II, of the Montreal Protocol, as fire extinguisher agents in existing or newly manufactured aircraft.

5.3 Federal Aviation Administration

(1) Similarly, the present Federal Aviation Administration (FAA) regulations addressing fire extinguisher systems do not include dates to phase out the use of ODS listed in Annex A, Group II, of the Montreal Protocol, as fire extinguisher agents in new designs of existing or newly manufactured aircraft.

5.4 European Union Aviation Safety Agency

(1) Since 2012, the European Union Aviation Safety Agency has included advisory material (Acceptable Means of Compliance 25.851(c)) in its Certification Specifications and Acceptable Means of Compliance for Large Aeroplanes (CS-25) indicating dates to phase out the use of ODS listed in Annex A, Group II, of the Montreal Protocol, as fire extinguisher agents in new designs and existing aircraft.

6.0 Alternative extinguishing agents

6.1 Lavatory fire extinguisher systems

(1) Paragraph 525.854(b) of the AWM and paragraph 705.76(b) of the CARs require lavatories to be equipped with a built-in fire extinguisher for each disposal receptacle for towels, paper, or waste. The extinguisher must discharge automatically into each disposal receptacle upon occurrence of a fire in that receptacle.
(2) Lavatory waste receptacles were the first area of application to have alternative extinguishing agents successfully developed.

(3) Since 2001 there are alternative extinguishing agents approved. Table 5 provides information about two agents.

Table 5. Lavatory Alternative Extinguishing Agents
Name	Mfr.	Chemical Formula	CAS Number	Specification	ODP	GWP (100 years)
HFC-227ea	n/a not applicable	C₃HF₇	431-89-0	ASTM D6064-11	0.0	3,220
1,1,1,2,3,3,3-Heptafluoropropane	n/a not applicable
FE-227^TM	DuPont
FM-200^®	DuPont
HFC-236fa	n/a not applicable	C₃H₂F₆	690-39-1	ASTM D6541-11	0.0	9,810
1,1,1,3,3,3-Hexafluoropropane	n/a not applicable
FE-36^TM	DuPont

(4) Both agents are technically and financially feasible alternatives to the use of halon 1301 and will have a less harmful impact on the environment and on health.
(5) At the same time, both alternatives have high global warming potential (GWP) and are listed in the Montreal Protocol, Appendix F as controlled substances. For this reason, their level of production and consumption must be progressively reduced in the coming years leading to a future need to replace them.
(6) The Domestic Substance List includes both extinguishing agents. These substances do not require a New Substance Notification under the New Substances Notification Regulations (Chemicals and Polymers) before being imported into Canada.

6.2 Cabin fire extinguisher systems

(1) Several standards of airworthiness in Table 3 and sections of the CARs in Table 4 define the requirements for quantity, distribution, location, approval, capacity and limitations applicable to hand-held fire extinguishers used in the aircraft flight deck, passenger cabin and accessible cargo compartments.

(2) Until 2016, no technically and financially feasible alternatives to halon 1211 existed. After a long process of development, a new extinguishing agent, which is a technically and financially feasible alternative, became available. Table 6 provides information about this agent.

Table 6. Cabin Alternative Extinguishing Agent
Name	Mfr.	Chemical Formula	CAS Number	Specification	ODP	GWP (100 years)
2-BTP	n/a not applicable	CF₃CBr=CH₂	1514-82-5	ASTM D8060-17 D8061-16	0.0028	0.23-0.26
2-Bromo-3,3,3-Trifluoro-1-Propene	n/a not applicable
Bromotrifluoropropene	n/a not applicable
Halotron^®BrX	American Pacific

(3) At the time of writing of this AC, the Domestic Substance List does not include 2-BTP. Therefore, any company or individual who plans to manufacture or import more than 100 kg/year of 2-BTP or products (including fire extinguishers and aircraft) containing more than 100 kg/year of 2-BTP as a fire extinguisher agent needs to follow the new substance notification regime as described in the ECCC/HC documents below.

Current Document at the time of writing this AC:
Guidelines for Notification and Testing of New Substances: Chemicals and Polymers
https://publications.gc.ca/site/eng/280464/publication.html

New Amendment that Will Replace Current Document:
Guidance Document for the Notification and Testing of New Chemicals and Polymers
https://www.canada.ca/en/environment-climate-change/services/managing-pollution/evaluating-new-substances/chemicals-polymers/guidance-documents/guidelines-notification-testing.html
(4) Companies or individuals manufacturing or importing less than 100 kg/year of 2-BTP or products (including fire extinguisher and aircraft) containing less than 100/year of 2-BTP as a fire extinguisher agent do not need to provide any notification.
(5) After 2-BTP is include in the Domestic Substance List it would not be considered a new substance anymore and no notification would be required regardless of quantity.

6.3 Baggage compartment, engine and auxiliary power unit fire extinguisher systems

(1) Despite the efforts of several organizations to develop alternative extinguishing agents for baggage compartments, engines and auxiliary power units, until the date of writing of this AC, no technically and financially feasible alternative has been found.
(2) Therefore, in order to continue using halon 1301 while in compliance with the FHR, it is necessary to seek ECCC authorization through the application for a permit. This authorization is necessary to install a fire extinguisher system using halon 1301, to import halon 1301, to import a product containing halon 1301 and to export halon 1301.
(3) This AC will provide information about alternative extinguishing agents for baggage compartment, engine and APU built-in fire extinguishing and/or suppression systems on a future revision when information becomes available.

7.0 Acceptable means of compliance

(1) The means of compliance in this section provide guidance on how to demonstrate that the integration of a previously developed alternative extinguishing agent into a fire extinguisher system complies with the applicable environmental and aeronautical acts and regulations.
(2) This section does not address the more complex and less frequent case, where an applicant develops from the start to the end and integrates an alternative extinguishing agent. The occurrence of these cases are rare due to the larger amount of resources and time required.
(3) For the purposes of this AC, any reference to “approved data” means information contained in authoritative documents such as Type Certificates and Supplemental Type Certificates. It includes equivalent foreign documents, which have undergone airworthiness review resulting in their acceptance in Canada. Other forms of “approved data” include drawings or methods approved by the Minister, or by delegated authorities, such as Design Approval Organizations, Airworthiness Engineering Organizations and Design Approval Representatives. With the exception of instructions for continued airworthiness (ICA), whatever is on a design approval document is “approved data”.

7.1 Lavatory fire extinguisher systems

(1) The justification for the use of alternative fire extinguisher agents in built-in fire extinguishers for lavatory disposal receptacles is to eliminate the threat to the ozone layer posed by halon 1301. However, halon 1301 is very good at extinguishing the types of fire expected in these receptacles. Any candidate alternative extinguishing agent must match or exceed halon 1301 fire extinguishing performance while not harming the environment.
(2) Extinguishing agent environmental aspects
- (a) Ozone depleting potential
  - (i) The Montreal Protocol, Annex A, Group II, lists halon 1301 as a controlled substance due to its high ODP. Both alternative extinguishing agents in Table 5 have been previously developed for this application. They are not included in the list of controlled substances of Annex A, Group II because they have zero ODP. Positive evidence that they do not deplete the ozone layer (ODP=0) is found in the United States Environmental Protection Agency (US EPA) Significant New Alternative Policy (SNAP) Program table Substitutes in Total Flooding Agents. Reference to the Montreal Protocol, Annex A, Group II and to the US EPA SNAP table Substitutes in Total Flooding Agents are acceptable means of compliance.
- (b) Global warming potential
  - (i) The Pan-Canadian Framework on Clean Growth and Climate Change (ref. section 4.4 of this AC) is Canada’s plan to address climate change. One of its proposals is to use clean technology to reduce the emission of substances with high GWP, like halon 1301. Unfortunately, the two alternatives previously developed and listed in Table 5 cannot be qualified as having low GWP. Between the two, HFC-227ea should be the preferred choice since it has one third of the GWP of HFC-236fa and around one-half of the GWP of halon 1301. Until better extinguishing agents become available, both are acceptable.
(3) Extinguishing agent toxicological aspects
- (a) A balance between the firefighting performance and the toxicity of the extinguishing agent is necessary.
- (b) Aircraft safe use
  - (i) Subparagraph 525.851(b)(1)(i) of the AWM requires that no extinguishing agent likely to enter personnel compartments will be hazardous to the occupants. A test of a built-in fire extinguisher system installation, conforming to the proposed design, demonstrating that the levels of alternative extinguishing agent detected in any adjacent personnel compartment are not hazardous, is an acceptable means of compliance. Hazardous levels are levels above the no observable adverse effect level for each substance.
(4) Extinguishing agent performance
- (a) Material specification
  - (i) Paragraph 525.603(b) of the AWM requires that the suitability of materials used for parts, the failure of which could adversely affect safety, must conform to approved specifications that ensure their having the properties assumed in the design data. Data demonstrating that the alternative extinguishing agent used meets the applicable material specification in Table 5 is an acceptable means of compliance. An official document (statement of compliance, drawing, chemical/physical analysis, etc.) from the manufacturer of the built-in fire extinguisher bottle with supporting evidence is acceptable data.
- (b) Equivalence to halon 1301
  - (i) To ensure the same or better level of safety, it is necessary to present substantiation that the alternative extinguishing agent is, at least, as efficient as halon 1301 when used to extinguish fires likely to occur in lavatory disposal receptacles for towels, paper, or waste. Both previously developed alternative extinguishing agents in Table 5 meet the minimum performance standard above and are equivalent to halon 1301 as per FAA’s AC 20-42D, Chapter 2, paragraph 2b(3). Reference to FAA's AC 20-42D is an acceptable means of compliance.
- (c) Material compatibility
  - (i) Although not a specific airworthiness requirement, it is desirable that the alternative extinguishing agent be compatible with the materials it is/may be in contact with during storage and discharge. The same applies to the propellant, products of pyrolytic breakdown and by-products of combustion resulting from its interaction with fire.
  - (ii) Analysis demonstrating that the pure alternative extinguishing agent and its propellant do not deteriorate its storage vessel and the aircraft parts it may be in contact with when discharged is an acceptable means of compliance.
  - (iii) Analysis demonstrating that the quantity of products of pyrolytic breakdown and products of combustion generated do not deteriorate the aircraft parts it may be in contact with, from discharge time until cleanup, is an acceptable means of compliance.
(5) System performance
- (a) Quantity of extinguishing agent
  - (i) Subparagraph 525.851(b)(2) of the AWM requires that the capacity of each required built-in fire extinguishing system must be adequate for any fire likely to occur in the compartment where used, considering the volume of the compartment and the ventilation rate. Fires likely to occur in lavatory disposal receptacles for towels, paper, or waste are Class A fires. A laboratory test demonstrating that a built-in fire extinguisher system installation, conforming to the proposed design, has adequate capacity for the compartment where used is an acceptable means of compliance.
- (b) Automatic discharge
  - (i) Paragraph 525.854(b) of the AWM and paragraph 705.76(b) of the CARs require that the built-in fire extinguisher system must be designed to discharge automatically into each disposal receptacle upon occurrence of a fire in that receptacle. A laboratory test of a built-in fire extinguisher system installation, conforming to the proposed design, demonstrating that it discharges automatically into each disposal receptacle upon occurrence of a fire is an acceptable means of compliance.
- (c) Structural damage
  - (i) Subparagraph 525.851(b)(1)(ii) of the AWM requires that each built–in fire extinguisher must be installed so that no discharge of the extinguisher can cause structural damage. A laboratory test or analysis demonstrating that a built-in fire extinguisher system installation, conforming to the proposed design, does not cause structural damage when discharged, are acceptable means of compliance.
- (d) Operating conditions
  - (i) Paragraph 525.1309(a) of the AWM requires that the equipment, systems, and installations whose functioning is required must perform its intended function under any foreseeable operating condition. To that end, the applicant must demonstrate that the temperature, altitude, operational shock, vibration and humidity variation expected during operation do not negatively affect the system performance.
  - (ii) A laboratory test or approved data from a previous test, demonstrating that the system still meets all requirements referred to in sections 7.1(5)(a) to 7.1(5)(c) after the test specimen was subjected to all environmental conditions described below, are acceptable means of compliance.
    - (A) Temperature and altitude
      - (I) The test specimen must be subjected to the conditions specified in the Radio Technical Commission for Aeronautics (RTCA) standard DO-160G, Section 4, Category A1. The test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher system (standby equipment with short operating time). No operation of the fire extinguisher system is required while in the test chamber.
    - (B) Operational shock
      - (I) The test specimen must be subjected to the conditions specified in RTCA DO-160G, Section 7.0, Categories A and D. The test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher system (standby equipment with short operating time). No operation of the system is required while mounted to the shock table.
    - (C) Vibration
      - (I) The test specimen must be subjected to the conditions specified in RTCA DO-160G, Section 8, for the categories applicable to the type of aeroplane where installed. The certification office must agree with the determination of the applicable categories. In addition, the test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher system (standby equipment with short operating time). No operation of the system is required while mounted to the vibration table.
    - (D) Temperature variation
      - (I) The test specimen must be subjected to the conditions specified in RTCA DO-160G, Sections 5, Category C. The test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher system (standby equipment with short operating time). No operation of the fire extinguisher system is required while in the test chamber.
    - (E) Humidity
      - (I) The test specimen must be subjected to the conditions specified in RTCA DO-160G, Section 6, category A. The test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher system (standby equipment with short operating time). No operation of the fire extinguisher system is required while in the test chamber.
(6) Instructions for continued airworthiness
- (a) Section 525.1529 of the AWM requires the applicant to prepare ICA that are acceptable to the Minister. Those instructions must include, but are not limited to, information about the shelf-life of the built-in fire extinguisher bottle, its useful life after installation, method of disposal (the bottles are discardable after discharge or end of life) and information on how to prevent incorrect bottle installation. The latter is especially significant because most alternative fire extinguisher bottles are drop-in replacements for halon 1301 bottles.
- (b) Incorporation of the information required in the ICA as well as submission of the corresponding substantiation, including substantiation for shelf life, useful life, and prevention of incorrect bottle installation, are acceptable means of compliance.

7.2 Cabin fire extinguisher systems

(1) This section does not address means of compliance with requirements for number, location, accessibility and markings of hand-held fire extinguishers. For guidance on these subjects, refer to FAA’s ACs 20-42D and 25-17A, or later revision.
(2) The justification for the use of alternative fire extinguisher agents in hand-held fire extinguishers located in the passenger cabin, flight deck and some accessible baggage compartments is to eliminate the threat to the ozone layer posed by halon 1211. However, halon 1211 is very good at extinguishing the types of fire likely to occur in these locations. Any candidate alternative extinguishing agent must match or exceed halon 1211 fire extinguishing capacity while not harming the environment.
(3) Extinguishing agent environmental aspects
- (a) Ozone depleting potential
  - (i) The Montreal Protocol, Annex A, Group II, lists halon 1211 as a controlled substance due to its high ODP. The extinguishing agent in Table 6 has been previously developed for this application and is not included in the list of controlled substances of Annex A, Group II. The US EPA SNAP table Substitutes in Streaming Agents presents the applicable ODP value. Reference to the Montreal Protocol, Annex A, Group II, and US EPA SNAP table Substitutes in Streaming Agents are acceptable means of compliance.
- (b) Global warming potential
  - (i) The Pan-Canadian Framework on Clean Growth and Climate Change (ref. to section 4.4 of this AC) is Canada’s plan to address climate change. One of its proposals is to use clean technology to reduce the emission of substances with high GWP, like halon 1211. The industry recently completed the development of the extinguishing agent in Table 6, which is now available and meets the objectives of the Framework. The US EPA SNAP table Substitutes in Streaming Agents, presents the applicable GWP value. Reference to the US EPA SNAP table Substitutes in Streaming Agents is an acceptable means of compliance.

(4) Extinguishing agent toxicological aspects

(a) A balance must be achieved between the firefighting capacity and the toxicity of the extinguishing agent.
(b) Aircraft safe use
- (i) The impact of a hand-held fire extinguisher discharge in the toxicity of a personnel compartment is much larger than the impact of a lavatory waste receptacle built-in fire extinguisher. This difference is caused by the weight of extinguishing agent (a 2-BTP 5B:C hand-held fire extinguisher has 14 times more agent than a HFC-227ea lavatory waste receptacle built-in fire extinguisher) and the unconfined environment where it is discharged.
- (ii) Subparagraphs 523.851(c)(2), 525.851(a)(8), 529.851(a)(3) of the AWM, subparagraph 602.60(1)(e)(ii) and subsection 705.93(2) of the CARs require that extinguishers intended to be used in a personnel compartment must be designed to minimise the hazard of toxic gas concentrations.
- (iii) When assessing toxic gas concentrations from discharge of a hand-held fire extinguisher, the applicant must consider three sources: (1) The pyrolytic breakdown products from interaction of the extinguishing agent with the fire; (2) The by-products of combustion from the interaction of the extinguishing agent with the fire; and (3) The pure extinguishing agent.
- (iv) For pyrolytic breakdown products and by-products of combustion, section A.2 of Appendix A of report DOT/FAA/AR-01/37 provides a test method and pass/fail criteria to demonstrate that the extinguishing agent is equivalent to halon 1211. For the pyrolytic breakdown products and by-products of combustion of 2-BTP, reference to the data in Table 7 indicates compliance with the hydrogen fluoride 1-minute average limit of 200 ppm and 4.5-minute limit of 100-ppm pass/fail criteria and is an acceptable means of compliance.
- (v) For the pure extinguishing agent, all phases-of-flight and dispatchable ventilation /pressurization configurations, applicable to the aircraft in which the equipment will be installed, must be considered. The assessment should also, at least, include the Master Minimum Equipment List dispatch configurations that adversely affect the smaller personnel compartment (flight deck, if a separated compartment) ventilation rate. Analysis demonstrating that the discharge of the fire extinguishers intended to be used in a personnel compartment do not produce hazardous concentrations of toxic gases as per guidance from FAA’s AC 20-42D, Chapter 4, sections 2 and 3 and Appendix 4, section 2, are acceptable means of compliance. However, the data in the AC 20-42D do not include 2-BTP. The required data is provided in Tables 9, 10 and 11.
- (vi) The toxicity analysis above assumes perfect mixing and instantaneous extinguishing agent discharge. Additional testing has determined that this assumption is not realistic. To account for that, a multiplication factor, which yields lower concentrations due to stratification and localization of the alternative extinguishing agent after discharge, may be used. As per recommendation of the report DOT/FAA/TC-14/50, the multiplication factor calculated for halon 1211 due to stratification and localization (MFSL) is applicable to other extinguishing agents, if their boiling point is greater than halon 1211 and their vapour pressure at 25°C is less than halon 1211, as is the case for 2-BTP (see Table 11).
- (vii) In flight deck compartments where it is not possible to meet the requirements for toxicity and where full-face masks or portable breathing equipment are available to all occupants, it is acceptable to rely on operational procedures mandating the use of that equipment before discharge of the fire extinguisher.

Table 7. 2-BTP Seat Fire Toxicity Test Results
Test No	HF 1-Minute Average (ppm)	HF 4.5-Minute Average (ppm)	Agent Used (lb.)	Discharge Time (s)
1	47.8	23.9	1.85	3.2
2	65.7	34.5	1.76	3.8
3	88.2	47.7	1.55	2.9

Table 8. 2-BTP PBPK Modeling Results – Maximum Safe Weight/Volume (lb./cu. ft.) ^{Footnote 1} ^{Footnote 2} ^{Footnote 3}
Sea Level (For Info Only)	Pressurized Aircraft		Unpressurised Aircraft
Sea Level (For Info Only)	6k ft. CPA	8k ft. CPA	12.5k ft.	14k ft.	18k ft.	25k ft.
0.00450	0.00361	0.00334	0.00281	0.00264	0.00225	0.00167

Table 9. 2-BTP PBPK Modeling Results – Multiplication Factors ^{Footnote 1}
blank space	0.5	1	1.5	2	3	4	5	6	> 6
blank space	Effective Ventilation Rate (min. per air exchange)
Multiplication Factors (MF_ventilated)	2.39	1.92	1.71	1.62	1.49	1.43	1.38	1.33	1.00

Table 10. Minimum Cabin Volume Requirements for 3.75 lb. 2-BTP Extinguisher ^{Footnote 1} ^{Footnote 2} ^{Footnote 3}
Effective Vent. Rate (min. per air exchange)	Pressurized Aircraft		Unpressurised Aircraft
	6k ft. CPA	8k ft. CPA	12.5k ft.	14k ft.	18k ft.	25k ft.
	Minimum Volume Required, cu. ft.	Minimum Volume Required, cu. ft.	Minimum Volume Required, cu. ft.	Minimum Volume Required, cu. ft.	Minimum Volume Required, cu. ft.	Minimum Volume Required, cu. ft.
0.5	435	470	560	594	699	940
1	541	584	696	738	869	1169
1.5	610	658	784	831	979	1317
2	642	692	825	876	1031	1387
3	698	752	897	951	1120	1506
4	729	786	937	994	1170	1574
5	752	811	966	1025	1206	1623
6	782	843	1005	1066	1255	1688
No Vent.	1040	1122	1337	1419	1669	2246

Table 11. Boiling Point and Vapour Pressure
	Halon 1211	2-BTP
Boiling Point	-3°C	34°C
Vapour pressure (25°C)	2.8 bar	0.82 bar

(5) Extinguishing agent performance
- (a) Material specification
  - (i) Subparagraph 523.603(a)(2)and paragraphs 525.603(b), 525.603(b) and 529.603(b) of the AWM require that the suitability of materials used for parts, the failure of which could adversely affect safety, must conform to approved specifications that ensure their having the properties assumed in the design data. Data demonstrating that the alternative extinguishing agent used meets the applicable material specification in Table 6 is an acceptable means of compliance. An official document (statement of compliance, drawing, chemical/physical analysis, etc.) from the manufacturer of the hand-held fire extinguisher with supporting evidence is acceptable data.
- (b) Equivalence to halon 1211
  - (i) To ensure the same or better level of safety, it is necessary to substantiate that the alternative extinguishing agent is, at least, as efficient as halon 1211 when used to extinguish fires likely to occur in the passenger cabin, flight deck and some accessible baggage compartments. At the same time, subparagraph 525.851(a)(6) of the AWM and subsection 705.93(6) of the CARs require that a certain number of fire extinguishers must contain halon 1211 or equivalent.
  - (ii) The minimum performance standard defined in Appendix A of report DOT/FAA/AR-01/37 requires successful completion of two tests to establish equivalence: (1) the hidden fire test; and (2) the seat fire/toxicology test.
  - (iii) Performance in test (1) is dependent on the joint performance of the alternative extinguishing agent and the delivery system (fire extinguisher hardware). Therefore, a laboratory test conducted as per Appendix A, section A.1, of report DOT/FAA/AR-01/37, demonstrating that the alternative extinguishing agent combined with the delivery system meets the minimum performance standard, is an acceptable means of compliance.
  - (iv) Test (2) is exclusively dependent on the extinguishing agent. The alternative extinguishing agent in Table 6 meets the minimum performance standard as per results in Table 7. Therefore, reference to Table 7 in this AC is an acceptable means of compliance.
- (c) Material compatibility
  - (i) Although not an airworthiness requirement, it is desirable that the fire extinguisher alternative extinguishing agent be compatible with the materials it is/may be in contact with during storage and discharge. In addition to the extinguishing agent itself, this concern must extend to products of pyrolytic breakdown and by-products of combustion due to the interaction of the extinguishing agent with the fire.
  - (ii) Analysis demonstrating that the pure alternative extinguishing agent and its propellant do not deteriorate its storage vessel and the aircraft parts it may be in contact with when discharged is an acceptable means of compliance.
  - (iii) Analysis demonstrating that the quantity of products of pyrolytic breakdown and products of combustion generated do not deteriorate the aircraft parts it may be in contact with, from discharge until cleanup, is an acceptable means of compliance.
- (d) Appropriateness to types of fire
  - (i) Subparagraphs 523.851(c)(1), 525.851(a)(6) and 529.851(a)(2) of the AWM, subparagraph 602.60(1)(i) and subsection 705.93(2) of the CARs require that the extinguishing agent must be appropriate to the kinds of fire likely to occur where it is expected to be used. Fire extinguishers for use in the flight deck and passenger cabin must contain extinguishing agent appropriate for Classes B (flammable fluids and gases) and C (energized electrical equipment) fires. In addition, aircraft with accessible cargo compartments must have fire extinguishers containing agent appropriated to Class A fires (ordinary combustible materials, such as wood, cloth, paper, rubber, and many plastics). A laboratory test or approved data from previous test of the hand-held fire extinguisher demonstrating compliance with its rating as per ULC-S508 (equivalent to UL-711) is an acceptable means of compliance.

(6) Portable fire extinguisher performance

(a) Approval and marking
- (i) Subparagraphs 525.851(a)(5) and 529.851(a)(1) of the AWM require that the hand-held fire extinguisher must be approved. AWM 521.03 specifies several ways an applicant can approve an appliance or part. Data demonstrating that the hand-held fire extinguisher is approved is an acceptable means of compliance. A statement of compliance with ULC-S566 (equivalent to UL-2129) along with evidence of markings stating “Meets MPS DOT/FAA/AR-01/37” are acceptable data.
(b) Throw range
- (i) Paragraph 523.1301(a), subparagraph 525.1301(a)(1), paragraphs 527.1301(a) and 529.1301(a) of the AWM require that each item of installed equipment must be of a kind and design for its intended function. A laboratory test or approved data from previous test demonstrating that the fire extinguisher using alternative agent meets the minimum throw ranges in Table 12, for the size and location in the aircraft where used, is an acceptable means of compliance.

(i) Subparagraphs 523.851(c)(1), 525.851(a)(7) and 529.851(a)(2) of the AWM and subsection 705.93(2) of the CARs require that the quantity of agent used in each extinguisher must be appropriate for the kinds of fires likely to occur where used. However, the quantity of extinguishing agent alone is not sufficient to predict performance. Nozzle design, pressurization and other characteristics of the delivery system affect performance.
(ii) ULC-S508 (equivalent to UL-711) specifies test procedures used to measure the fire extinguisher (agent + delivery system) extinguishing potential for each class of fire. Based on the performance during this test it assigns a rating-class to the fire extinguisher. The rating consists of numerals, indicating the extinguishing potential, and letters indicating the class of fire.
(iii) Data demonstrating that the fire extinguisher (agent + delivery system) meets the minimum rating-class in Table 12 indicates that the tested quantity of alternative extinguishing agent is appropriate for the kinds of fire likely to occur where used.

Table 12. Fire Extinguisher Minimum Rating
	Application	Minimum Rating-Class	Minimum Throw Range
1	Small Aircraft Cabin and Flight Deck	UL 2B:C	5 ft.
2	Large Aircraft Passenger Cabin	UL 5B:C	8 ft.
4	Large Aircraft Flight Deck	UL 5B:C^{Footnote 1}	8 ft.
5	Accessible Cargo Compartment < 200 cu. ft.	UL 2A:10B:C	10 ft.

(d) Operating conditions
- (i) Subparagraph 523.1309(a)(1) and paragraphs 525.1309(a), 527.1309(a) and 529.1309(a) of the AWM require that the equipment, systems, and installations whose functioning is required must perform its intended function under any foreseeable operating condition. To that end, the applicant must demonstrate that the temperature, altitude, operational shock, vibration and humidity variation expected during the aircraft operation do not affect the performance of the hand-held fire extinguisher.
- (ii) A laboratory test or approved data from previous test, demonstrating that the fire extinguisher still meets all requirements in section 7.2(6)(b) and 7.2(6)(c) after the test specimen was subjected to all environmental conditions described below, are acceptable means of compliance.
  - (A) Temperature and altitude
    - (I) The test specimen must be subjected to the conditions specified in RTCA DO-160G, Section 4, for the categories applicable to the type of operation. The certification office must agree with the determination of the applicable categories. The test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher (standby equipment with short operating time). No operation of the fire extinguisher is required while in the test chamber.
  - (B) Operational shock
    - (I) The test specimen must be subjected to the conditions specified in RTCA DO-160G, Section 7.0, Categories A. The test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher (standby equipment with short operating time). No operation of the fire extinguisher is required while mounted to the shock table.
  - (C) Vibration
    - (I) The test specimen must be subjected to the conditions specified in RTCA DO-160G, Section 8.0, for the categories applicable to the type of aircraft where the system is installed. The certification office must agree with the determination of the applicable categories. The test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher (standby equipment with short operating time). No operation of the fire extinguisher is required while mounted to the vibration table.
  - (D) Temperature variation
    - (I) The test specimen must be subjected to the conditions specified in RTCA DO-160G, Sections 5, for the categories applicable to the type of aircraft where the system is installed. The certification office must agree with the determination of the applicable categories. In addition, the test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher (standby equipment with short operating time). No operation of the fire extinguisher is required while in the test chamber.
  - (E) Humidity
    - (I) The test specimen must be subjected to the conditions specified in RTCA DO-160G, Section 6, category A. The test plan must customize the applicable RTCA DO-160G test procedure to the operating characteristics of the fire extinguisher (standby equipment with short operating time). No operation of the fire extinguisher is required while in the test chamber.

(7) Instructions for continued airworthiness
- (a) Sections 523.1529, 525.1529, 527.1529 and 529.1529 of the AWM require the applicant to prepare ICA that are acceptable to the Minister. Those instructions must include, but are not limited to, information about the shelf life of the hand-held fire extinguisher, its useful life after installation and method of disposal/recharging.
- (b) Incorporation of the information required in the ICA as well as submission of the corresponding substantiation and instructions, including substantiation for shelf life and useful life, and instructions for disposal/recharging, are acceptable means of compliance.

7.3 Baggage compartment fire extinguisher systems

(1) This AC will provide acceptable means of compliance for this application when technically and financially feasible alternatives become available.

7.4 Engine and auxiliary power unit fire extinguisher systems

(1) This AC will provide acceptable means of compliance for this application when technically and financially feasible alternatives become available.

8.0 Information management

(1) Not applicable.

9.0 Document history

(1) Not applicable.

10.0 Contact us

For more information, please contact:

Civil Aviation, Standards (AARTC)
E-mail:
TC.AARTCDAircraftStandards-NormesdeconceptiondesaeronefsAARTCD.TC@tc.gc.ca

We invite suggestions for amendment to this AC. Submit your comments to:
E-mail:
AARTDocServices-ServicesdocAART@tc.gc.ca

Original signed by

Félix Meunier
Director, Standards Branch
Civil Aviation

AC 500-030 - Alternative Agents for Aircraft Fire Extinguisher System
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