Response to John Sexton Signed_040618

United States
=_;,_...—— Department of
Agriculture

USD

Forest
Service

Washington Of■ce

1400 Independence Avenue, SW
Washington, D.C. 2025!]

File Code:

5160

Date: APR 05 2018
Mr. John Sexton

Pyrocool
201 Verbena Ave.

Floral Park. NY 11001
(516) 448-8712
Dear Mr. Sexton

This letter provides a responseto a seriesol'six email messages(sent on January 31 and
February 1. 2018) to David Haston. Equipment and Chemicals Branch Chief. regarding the 1.1.8.
Department of Agriculture's Forest Service quali■cation process for wildland ■rechemicals.
The concerns raised in your email are addressedas follows:
Laboratory Accreditation:
in your email messages.you made :1number ofrcfercnces to the lack ot':—1eereditation
at the
Forest Service Wildland Fire Chemicals (WFCS) Laboratory. In consultation with the USDA
Of■ce oI‘General Council. we have con■rmed that there is no legal requirement for accreditation
(ISO certi■cation) for government laboratories. Moreover. the WFCS lab hasevaluated
wildland ■rechemicals. in accordancewith Forest Service speci■cations,for over 50 years.
Most of the tests performed in the WFC‘S laboratory were either developed in close consultation
with professional researchlaboratories 01'adhere to established test protocols as promulgated by
various testing organizations. including the American Society for Testing:Iand Materials
International. and the National Association ofCorrosion Engineers International. as well as
several governmental agencies.including the Environmental Protection Agency and the Of■ce of
Prevention. Pesticides.and 'l‘oxie Substances. The WFCS laboratory performs only those tests
required in Forest Service speci■cationsfor use by the Forest Service and other wildland ■re
agencies. It does not act as a third party laboratory to qualify products for other entities. vendors
or usersoutside ol‘the federal wildland ■recommunity.
With respectto your statement regarding the amount ol'time required to complete quali■cation
testing. the majority ol‘produets complete testing in about 18 months (not 2.4months as stated in
your email), particularly for Class A foams and water enhancerswhich are not generally required
to go through ■eld testing. The timelinc re■ectsthe time necessaryto complete the one-year
stability test, the ■nal uniform corrosion (perlormed on the onC-ycar stability sample) and ■nal
intergranular corrosion. Manufacturers will often decide to wait until the results ot‘the one-year
stability tests are complete before proceeding to more expensive tests {such as toxicity). You are
correct that most tests are two to three weeks in duration (or less). Whenever possible. the
WFCS laboratory will run tests concurrently.

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Caring for the Land and Serving People

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Mr. John Sexton

Corrosion Test Requirement:

Thecorrosiontestrequiredin ForestServicespeci■cationswasdevelopedthroughextensive

consultation with Ocean City ResearchCorp“ a widely respectedbusinessspecializing:]in
corrosion testing and which also works extensively with the U.S. Military. The test protocol
follows both NACE TMOl69/‘G3 l -l2a and ASTM G 31 guidelines. It should be noted that both
documents state that the nature Ofeorrosion testing precludes complete standardization.
Concerning the issuesraised by Mr. KD. Elird regarding the corrosion test! AS'I‘M G 31 states
that "set rules cannot be applied to specimen cleaning becauseprocedures will vary.
ASTM
.
Gl-U3 (Standard Practice for Preparing, Cleaning. and Evaluating Corrosion Test Specimens).
Section 7.4 statesthat “Mechanical cleaning can include scraping. scrubbing. brushinv.
ultrasonic cleaning, mechanical shocking. and impact blasting". Our procedures specify using a
1'lOl‘l-3bl‘tlSi\-“€
spatula when scraping is necessary. Although historically it was more common
with lire chemical products. lire chemicals today rarely require scraping. The Standard further
notes that removing corrosion products by scraping or impact blasting (i.e. grit blasting. waterjet) prior to cleaning is pi‘elerable in some casesto prevent reactions that may result in excessive
removal ofmctal.
ASTM Gl does not addressthe use mechanical drying through the use oi‘towels. Our standard
operating procedures specify the use seientitieflaboratory grade lint- and stutie-free. one-use
tissues.

The evaluation ot‘loealized corrosion (pitting) 01‘dealloying ol'brass coupons is not applicable to
the needsOfthe Forest Service. WFCS is only looking:Ifor broad indications ot’corl‘osion when
speci■calloys are exposed to tire chemicals. not researching a specific type to determine the best
way to alleviate certain corrosion trends in the future. Mitigating corrosive tendenciesis the
responsibility of the ■rechemical manufacturer.
The actual yellow brassalloy used in our tests is found in the USPS speci■cationand in our
revised lab procedures(UNS 26000) (not yet posted to the website}. There is no reasona
chemical company can't usean alternative coupon supplier for their own in-house tests. As long
asa coupon supplier can meet our speci■cations. our lab will consider them for purchase.
Use of Other Laboratories:
The Forest Service coordinates all testing for ■re chemical quali■cation. Some 01'the tests are
performed at the WFCS laboratory. while others are perlbrmed directly for the Gtwernment by
third party laboratories. All tests are performed on product supplied by the Government from the
manufacturer‘s submission sample. In this manner. the Government maintains a chain ofcustody
ot‘all test samplesthroughout the qualification test process.
Cost Estimate:
The Forest Service routinely provides cost estimates to parties interested in pursuing,
quali■cation testing. We will be happy to provide your company with :1cost estimate upon
request.

Mr. John Sexton

3

Information-Only Tests:
Fire suppressantfoams are used on a wide range oftactical scenariosand conditions. The Forest
Service requires some tests that every product must passto comply with mandatory performance
requirements. such as mammalian and ■shtoxicity. uniform and intergranular corrosion. and
stability. Other tests. such as the level 01‘foaming and the drain time as a function ot‘water
temperature and quality. are performed for “information only" over a wide variety ofconditions
to help users determine which products best [it their operational needsbasedon the application.
Collection of Information:
WFCS annually makes a request through 0MB to advertise to potential ot‘t‘erorsthe opportunity
to submit products that may be useful in wildland ■re■ghting. After successful testing in
accordancewith Speci■cations5100-3040. 5100-3063 01-5100-307a.a product may be added to
the Quali■ed Products List (QPL). As a result. the Ql’L for Class A foams includes 14 products

from 10 different suppliers and the QI’L for water enhancersincludes [0 products Fromseven

suppliers.The long-tcrmretardantQPI. includessevenproducts,all ol‘which are manufactured

by one company. The reason for a singular company has;nothing to do with the Speci■cation
Changerequiring a minimum Viscosity as indicated in your email. The toxicity 01"older
retardants was signi■cantly higher than those currently found on the QPL.

In summary. we thank you for your interest in chemicals for wildiaod ■re■ghting. If you would
like to pursue quali■cation testing, please contact David Haston. Equipment and Chemicals
Branch Chiel’at (208) 387-5642. dhastonr■‘d‘s.t‘cd.usor Shirley Zylstra. WFCS Program Leader at

(406) 329-4859. szvlstra■ill‘s.led.tts.They will be happy to provide an outline ofthe quali■cation
process.timeline. and a cost estimate.
Sincerely.

SI-IAWNA A. LHGARZA. PSY
Director Fire and Aviation Mgt
Enclosure

cc: Dave Haston. Shirley Zylstra