Jun 13, 2016· Comment submitted by Simon Lie, Chairman, International Coordinating Council of Aerospace Industries Association (ICCAIA)· EPA-HQ-OAR-2015-0663-0051
The International Coordinating Council of Aerospace Industries Associations (ICCAIA) strongly supports EPA's proposal to list 2-BTP as an acceptable substitute fire suppression agent under specified conditions. 1. The atmospheric impacts of 2-BTP are much lower than common alternative aircraft fire suppression agents. 2. The potential for adverse human health effects is limited by proposed conditions of 2-BTP use and exposure scenarios for releases on operating aircraft. 3. Timely EPA SNAP approval of 2-BTP is needed to meet an international target for elimination of halon from handheld fire extinguishers. Our complete comments are included in the attached letter. Simon Lie Chairman ICCAIA Airworthiness Committee