On May 30, 2025, one of the world’s leading manufacturers of condensed aerosol fire suppression systems submitted a formal legal communication to the United States Environmental Protection Agency (EPA), requesting that the agency expand its ongoing review of a specific extinguishing agent to include all aerosol-based fire suppression systems currently available on the market. The letter was submitted through a major international law firm and was officially registered in the EPA’s public comment system as part of the Significant New Alternatives Policy (SNAP) program review.
This marks the first known instance in which a major industry participant has publicly called on EPA to apply equal safety and toxicity evaluation standards across all products in the aerosol fire suppression category, regardless of manufacturer or brand. The request suggests that safety risks identified in relation to one specific product may, by extension, be present in similar systems across the market, due to the widespread use of comparable formulations, construction principles, and chemical mechanisms.
Most condensed aerosol systems rely on the same core technology: a solid-phase pyrotechnic composition that, upon activation, generates a fire-inhibiting aerosol cloud containing a mixture of active particles and combustion byproducts, including gases such as carbon monoxide (CO), nitric oxide (NO), and nitrogen dioxide (NO₂). These systems are typically deployed without integrated gas filtration or toxicity mitigation features. Investigative findings — including those documented in the official report on the Resurgam vessel fatality by the UK Marine Accident Investigation Branch (MAIB, 2023) — confirm that the resulting atmospheric concentrations may reach levels hazardous to human life in occupied spaces.
If EPA accepts the request outlined in the May 30 letter, the implications for the global aerosol fire suppression sector may include the following:
– temporary suspension of installed systems pending renewed safety evaluations;
– interruption of manufacturing activities until updated toxicological and thermal testing is completed;
– mandatory reformulation of pyrotechnic agents and redesign of generator hardware to reduce hazardous emissions;
– full recertification of all product lines under revised safety and health standards;
– delay or suspension of active supply contracts and distribution agreements.
Even in the best-case scenario, independent expert assessments suggest that comprehensive modernization of manufacturing processes — including the elimination of high-risk substances — will require a minimum of 3 to 5 years. In practice, given that no manufacturer currently possesses proven technology capable of achieving safe and effective performance within newly emerging safety thresholds, a realistic timeline could extend to 10 years or more.
The original letter confirming the above was published in the EPA’s public docket system and is available for public access (e.g., on Regulations.gov under Docket ID: EPA-HQ-OХХ-2ХХ-ХХХХ or related records). To avoid misuse or misinterpretation outside of a professional context, we have chosen not to reproduce the full document here. However, we are prepared to provide the official link or a certified copy of the document upon justified individual request.
To request the document or obtain a professional consultation on its content, please contact:
fire@impulse-storm.com
LEGAL NOTICE / DISCLAIMER
This document is intended solely for informational use by technical professionals, industry participants, regulatory bodies, and other stakeholders in the fire safety sector. All referenced information is based on publicly available regulatory documents, comments submitted to the EPA through official legal channels, and findings from recognized national authorities.
The purpose of this notice is to provide timely awareness of an active regulatory development that may have long-term implications for system certification, market access, and end-user safety. No part of this document constitutes a legal accusation, commercial judgment, or defamatory statement against any company or individual.
The authors and distributors of this statement disclaim any liability for third-party decisions or actions taken on the basis of this information. The referenced document may be shared only in the context of technical or regulatory review.
