Update on the Draft EC Regulation

1
Update on the Draft EC Regulation

• Presented by Pacific Scientific
• at the
• International Halon Replacement Working Group
  Meeting
• Bremen - May 2000

2
Update on the Draft Regulation

• Background and Status
• Halon
• Controls
• Critical Use
• Import / Export
• Impact for Aerospace
• Airline Strategy

3
Background

• New Regulation first seen in draft form in Aug
  1998.
• Proposes controls on the production, use, sale,
  import, export and recovery of ODSs, including
  Halon.
• Includes Halons, CFCs HCFCs etc.
• Will replace regulation 3093/94, which prohibited
  production of Halon and other ODSs.

4
Current Status

• 2nd reading of the EU Parliament Dec 99
• Some outstanding issues on HCFCs
• Halon aspects are agreed.
• Could be adopted June 2000.

5
Current Status - Entry into Force

• Probable date is 1st October 2000.
• UK and others suggested 1st Jan 2001 to allow
  time for national ratification.
• Will supersede current national legislation in
  those countries which already have local controls
  (e.g. Germany)

6
Halon Controls (Article 4)

• Prohibits sale or use of Halons after entry into
  force, except as allowed below
• Use and sale of recovered/reclaimed Halons in
  existing systems until 31 Dec 2002
• All systems and extinguishers must be
  de-commissioned by 31 Dec 2003.
• Exceptions for critical uses which are listed in
  Annex VII of the regulation.

7
Critical Uses of Halons (Aircraft)

• Halon 1301
• In Aircraft for the protection of crew
  compartments, engine nacelles,cargo bays and dry
  bays.
• Halon 1211
• In hand-held fire extinguishers and fixed
  extinguisher equipment for engines for use on
  board aircraft
• In Aircraft for the protection of crew
  compartments, engine nacelles, cargo bays and dry
  bays

8
Import Controls (Articles 6 7)

• Import Licensing
• The restrictions are similar to those in 3093/94.
• An Import Licence issued by the Commission is
  required for bulk imports. There will be
  quantitative limits.
• Affects both Free Circulation and IPR imports.
• Free Circulation import only permitted for
  essential or critical use or destruction.
• In the event of a Halon shortage, obtaining an
  import Quota/Licence is likely to be a protracted
  process.
• No restrictions on products for critical uses.

9
Export Controls (Articles 11 12)

• Export of products and equipment containing Halon
  will be permitted for Critical Uses
• It is understood that bulk export of Halon will
  not be permitted, even for Critical Uses
• Applies from Entry into Force date.
• Export Licences issued annually with quantity
  limits and stated destinations.
• Applications will need the support of the
  national enforcement agency.

10
Impact for Aviation

• Users need to secure supplies before phase-out
  date.
• Affects non-EC users that are dependant on EC
  Service Providers.
• Airline is the Critical User, not Service
  Provider.
• Service Providers are unlikely to accept the full
  risk of Investment / Destruction Costs.
• US shortage of Halon could affect new aircraft
  deliveries ?
• Waste Bin Extinguisher not a Critical Use?

11
Factors Affecting Future Needs

• Unknown existing stocks (Banked or Installed)
• Unknown end dates for each application.
• Fleet growth
• New regulation (D to C, etc.)
• Consumption ( Fires, False Warnings, Hydrostatic
  Testing)
• Economics, Feasibility and Timescale for a
  changeout on existing aircraft.
• Emergence of new technologies.

12
Airline / Airframe Mfr Strategy

• Forecast of Future Needs is a priority.
• Strategy for continued availability.
• Airline Halon Bank
• Contracted Halon Bank or Contracted Supplies.
• Plan should consider the risk of a US Shortage
• Possible need to source the Halon needed for new
  aircraft.
• Regular purchases during Phase-out
• Minimise Financial Impact/Availability risks.

13
Support from Service Providers

• Provider/Repair Station probably can
• Assist with the Airlines requirements forecast.
• Assist with the sourcing of Halon before
  Phase-out.
• Provide recovery and banking facilities.
• Provide ongoing Overhaul and Recharging
  facilities.
• Provider/Repair Station probably wont/cant
• Provide or guarantee the needs of the industry
  from their own resources.
• Take the risk of subsequent destruction costs
  unaided.
• Stabilise Halon prices - now a commodity.

14
Conclusion

• Airlines and Manufacturers need
• A forecast of future Halon requirements, which
  includes a What if analysis.
• A plan on how this will be provided.
• The plan should be reviewed regularly to take
  account of changing availability and alternatives
  progress.
• Active management of their Halon source, either
  through an Airline Bank, a Contracted Bank or a
  Supply agreement.
• Waste Bin Extinguisher replacement ?

15
Finally

• If an Airline is going to rely on a Supplier
  agreement alone
• They need to be pretty confident the supplier
  will still be in business and able to supply when
  Halon is needed.
• They are gambling on the Airlines future,
  because the Halon price could be nothing, or a
  fortune.