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AIM Act HFC Phasedown Checklist for Clean Agent Owners

What facility managers, engineers, EHS leaders, and risk owners need to do now if they rely on FM-200, ECARO-25, or other HFC clean agent systems.

At a Glance

  • The AIM Act phases down new HFC production and consumption in staged reductions, it does not ban your installed suppression system.
  • Owners feel the impact most during recharge, upgrades, and new projects, when lead times and cost volatility matter.
  • Your best moves are to prevent accidental discharge, protect room integrity, and build a recharge plan before a real event forces your hand.
  • Code and performance still rule, maintain compliance with NFPA 2001, NFPA 72, and local fire code requirements for your jurisdiction.
  • SSI helps industrial owners plan service continuity, recharge strategy, and upgrade pathways across Pennsylvania and the East Coast region.

What the AIM Act Is

The American Innovation and Manufacturing Act, commonly called the AIM Act, authorizes the US Environmental Protection Agency to reduce hydrofluorocarbon production and consumption in stages. HFCs are used across refrigeration, air conditioning, and fire protection. In clean agent suppression, common HFC agents include FM-200 (HFC-227ea) and ECARO-25 (HFC-125).

Fire Suppression Systems Association logo, industry guidance reference

SSI tracks regulatory and industry guidance through organizations such as the Fire Suppression Systems Association and aligns recommendations to real field constraints, commissioning realities, and AHJ expectations.

HFC Phasedown Schedule, Why Timing Matters

The phasedown does not happen overnight. It reduces available new HFC supply in steps. Owners typically feel pressure when a discharge occurs, when cylinders need recharge, or when a new project forces a technology decision.

HFC phasedown schedule chart for AIM Act hydrofluorocarbon reductions

Practical takeaway, staged reductions reward planning. Waiting until after a discharge is how owners get trapped into expensive, rushed decisions.

Milestone What it means for owners
Early reductions Start system inventory, tighten service discipline, and validate enclosure integrity before it becomes urgent.
Mid-phase reductions Expect higher sensitivity to lead time and pricing for new agent, build a recharge plan that accounts for realistic procurement scenarios.
Long-horizon reductions Treat HFC systems as lifecycle assets, plan modernization and migration on your timeline, not on a crisis timeline.

Is My FM-200 or ECARO-25 System Banned

No. The AIM Act targets production and consumption of new HFC material, not the continued operation of existing installed clean agent equipment. Your system can remain in service when it is inspected, maintained, and recharged according to applicable codes and manufacturer guidance.

SSI technology pages for common HFC agents: FM-200 clean agent systems , ECARO-25 clean agent systems.

Owner Checklist, What to Do Now

1) Build a defensible fleet inventory

  • List every protected room, location, agent type, and system manufacturer.
  • Capture cylinder quantities, cylinder size, fill status, last inspection date, and any discharge history.
  • Record releasing panel model, detection type, releasing logic approach, and monitoring pathways to the fire alarm system.
  • Assign criticality, identify rooms where downtime and collateral damage are unacceptable.

2) Reduce accidental discharge risk

  • Fix nuisance detection issues and validate releasing logic, accidental discharges destroy budgets and disrupt operations.
  • Verify supervision points and signaling, low pressure, valve status, power, trouble reporting, and monitoring integrity.
  • Confirm warning appliances, time delay, abort, signage, and occupant procedure alignment in normally occupied spaces.

3) Validate the room, not just the cylinders

Clean agent performance depends on holding concentration long enough to complete suppression. If the enclosure leaks or HVAC interfaces are not controlled, the system can discharge and still fail real-world performance.

  • Confirm protected volume boundaries, including ceiling plenum and raised floor decisions.
  • Identify leakage paths, door frames, cable penetrations, conduit, duct openings, access floors, and construction gaps.
  • Use integrity testing and sealing to prevent commissioning failure loops and false confidence.
  • SSI enclosure guidance: Proper sealing of clean agent rooms and Room integrity testing and sealing.

4) Keep compliance and documentation audit-ready

  • Maintain a room packet, as-builts, calculation basis, nozzle schedule, cylinder schedule, and sequence of operation.
  • Document inspections, deficiencies, corrective actions, and any room modifications that could change enclosure integrity.
  • Keep discharge, recharge, and cylinder handling records, including chain-of-custody where applicable.

SSI design and lifecycle context: Design considerations for special hazards and Service and maintenance support.

Recharge Planning, Reclaimed Agent, and Return-to-Service Reality

If your clean agent system discharges, the clock starts. The real question is not only whether you can source agent, it is how quickly you can restore full protection while maintaining AHJ and insurer confidence. As HFC supply tightens, reclaimed and recycled HFC agent can play a larger role in recharge work.

Ask these questions before an event forces them

  • What is your worst-case downtime exposure if the room is out of service for weeks?
  • Do you have a documented interim plan, fire watch, temporary shutdown, or operational controls?
  • Are cylinder weights, pressures, and supervision trending stable, or are you already bleeding reliability?
  • Can you standardize components across sites to reduce spares complexity and speed recovery?

Alternatives and Upgrade Paths for New Projects

The AIM Act does not remove your protection, but it changes the long-horizon economics of new HFC projects. For new buildouts and major upgrades, many owners evaluate low-GWP or non-HFC technologies to reduce regulatory and budget exposure.

Novec brand lockup historically associated with FK-5-1-12 technology

FK-5-1-12 clean agent systems are commonly evaluated as a low-GWP clean agent pathway for many critical room applications.

DuraQuench water mist technology logo

Water mist and specialty water systems can be a fit for certain hazards and are separate from HFC phasedown dynamics.

Technology path Best fit scenarios SSI starting point
FK-5-1-12 clean agent Critical rooms that want clean agent performance with very low global warming potential. SF-1230 / FK-5-1-12 clean agent systems
Inert gas (IG-55, IG-541) Owners who want non-halocarbon, long-horizon suppression for mission critical spaces. ProInert2 inert gas systems
Water mist and specialty water Select hazards where fine water droplet suppression fits the risk and room constraints. Specialty water suppression systems

Authoritative External Resources

Service Area Focus

SSI is headquartered in Breinigsville, Pennsylvania. This AIM Act guidance is written for industrial and critical facility owners across Pennsylvania, New Jersey, New York, Delaware, and Maryland, and for organizations with East Coast footprints that need consistent clean agent strategy, documentation, and response capability.

FAQ

Should I replace my HFC system immediately

Usually no. A smarter path is to inventory what you have, validate room integrity, keep service current, and time modernization with renovations, expansion, or end-of-life components. Replacement decisions should be driven by risk, uptime needs, and lifecycle planning, not panic.

What is the biggest hidden risk for HFC clean agent rooms

Leakage and enclosure changes. Cable pulls, door replacements, new penetrations, and HVAC changes quietly destroy performance. Room integrity work is often the difference between a system that looks compliant and a system that performs.

Does the AIM Act affect inert gas or water mist systems

No. Inert gas uses naturally occurring gases, and water mist uses water. These are not HFCs and are not controlled by the AIM Act phasedown, which is why many owners consider them for long-horizon programs.

Plan Your AIM Act Strategy With SSI

If you manage FM-200, ECARO-25, or other HFC clean agent systems, SSI can help you build a defensible inventory, reduce discharge risk, plan recharge scenarios, and map upgrade paths that fit your budget and timeline.

Fastest start, share the facility location, protected room names, agent type, cylinder count, last inspection date, and whether you have recent room integrity test results.

Related SSI Pages

Suppression Systems Inc., 155 Nestle Way, Suite 104, Breinigsville, PA 18031.