To: All Stat-X Distributors

Re: Comments on Deceptive Claims Promulgated by Firepro

Over the years Firepro has made a number of preposterous claims regarding their
product. Recently they have begun to make and publish false statements about
Stat-X – presumably due to the fact that more and more former Firepro customers
have switched to Stat-X due to the quality difference. We have always taken the
position that all aerosols are effective due to the inherent benefits of the
technology, but that there are real differences in quality, manufacturing
procedures, and degree of effectiveness.

Believing that Stat-X stands on its own merits, we have never stooped to the level
of trying to promote our product by “negative selling” against other aerosol
manufacturers. However, Firepro has recently embarked on a program to disparage
Stat-X that is completely false. As a result we offer the following information so
that you are prepared to respond if any of their false claims are presented to you.

False Firepro Claim 1: Stat-X products are one of the first aerosol forming
compounds developed in Russia.

Response: The original work on Stat-X compounds was originally done in Russia
just as all other aerosols. However, the Stat-X precursors were later generation
formulations incorporating significant enhancements. The technology was
transferred to the United States in the late 1990’s and has been further enhanced
and refined to produce the most effective condensed aerosol in the world. This is
evidenced by the fact that in all comparative tests done by multiple testing
authorities such as, UL, ULC, and MCA the required application rate for Stat-X is
significantly lower than any other condensed aerosol – demonstrating its
effectiveness. Results and required application rates per the MCA tests in the UK
are as follows:

Application Density Required per Published UK Marine and Coastguard

Agency Tests and Published Certifications/Test Reports

Application Density Required (g/m3) Stat-X Firepro Pyrogen

Class B 58 82 117

Class A 72 100 N/A

Clearly, there is a significant difference between the condensed aerosol produced by

the Stat-X devices when compared to either Firepro or Pyrogen. These are not
claims, but rather, facts based on real world comparative testing by a third party
certifying body.

11503 K-Tel Drive • Minnetonka, MN 55343

Phone: 952.935.9745 • Fax: 952.935.9757 • www.statx.com
Stat-X is manufactured using only pure reagent grade chemicals in the United
States – unlike other manufacturers who “claim” to be manufacturing their agent
but in many cases continue to source their aerosol forming compounds from Russia
(with questionable quality control).

False Firepro Claim 2: Firepro’s product is not a pyrotechnic.

Response: Firepro has put forward this bit of deception for years in an effort to try
to (inaccurately) distinguish their product from other aerosols which they claim are
pyrotechnic. All condensed aerosols are formed by a combustion process involving a
solid aerosol forming compound. The only difference between them is the actual
formulation, method of manufacture, and speed of the combustion process. The
internationally accepted definition of a pyrotechnic is (excerpt from US Department
of Defense):

“A mixture of chemicals which, when ignited, is capable of reacting exothermically

to produce light, heat, smoke, sound or gas.”

Clearly, all condensed aerosols are formed by what can be termed as a pyrotechnic
reaction and Firepro’s claims are either disingenuous or demonstrate a real lack of
knowledge about the technology they are involved with.

False Firepro Claim 3: Firepro product is Classified under Dangerous Goods

Classification Codes as Class 9.1 (Miscellaneous, Solid, n.o.s.) while Stat-X is
classified as 1.4S (Explosives).

Response: Stat-X is classified by the US Department of Transportation (competent

authority) as Class 4.1 (flammable solid). A copy of our classification letter from the
DOT is available on request.

Firepro has shipped their product deceptively for many years – originally claiming it
was “non-hazardous”, then moving to Class 5.1 (Oxidizer), and now claiming Class
9.1. It appears that they have self-declared their product for many years and we
have no idea what competent authority, if any, classed their product as 9.1. This
would not be the case if regulated in the USA or Canada or any major international
regulating body we are aware of.

Class 9.1 does not indicate that the product is in any way “safer” or non-hazardous.
Class 9 is a category of items that would normally be classified as some other
category, but for primarily political reasons are placed into Class 9. Examples of this
would be the various Class 1 (explosive) items that are used in automotive safety
systems such as airbag inflators, which by most countries’ standards should be in
Class 1.3 or Class 1.4, and seatbelt pre-tensioners, which would be otherwise
classified as a 1.4.

False Firepro Claim 4: Stat-X compound is a homogenous, fragile compound with

low mechanical stability which disintegrates at a touch while the Firepro compound
is varied in color showing the different color shades of the various ingredients and
is very mechanically strong. According to Firepro this is due to the inherent
properties of pyrotechnic materials.
Response: Firepro attempts to substantiate their argument by showing a picture of
compound which has clearly been deliberately broken by mechanical means.

Stat-X generators are designed to withstand all the environmental stresses they
will be subjected to - whether industrial or military. Stat-X is the only condensed
aerosol generator that has been successfully tested and listed to the strenuous
requirements of UL 2775 and is installed in the engine compartments of every M-
ATV vehicle being produced for the US Army and Marines (over 21,000 units).
These vehicles (and the Stat-X units installed) have been subjected to extreme
survivability and environmental tests as part of the vehicle qualifying program –
including being exposed to direct IED explosive devices!

The uniform appearance of the Stat-X compound is a result of very careful

production techniques to assure a completely homogenous composition with very
consistent, repeatable burn rates and discharge characteristics.

The blotchiness and varied colors of the Firepro compound only illustrates the in-
homogenous nature of their production process and the possibility of some internal
reactions between the components causing significant colored decomposition
products to form. The fact that Firepro in their Design Manual has significantly
different “effective” ratings for their several models (actual amount discharged vs.
starting mass) is a good indication of the variability of their production methods.

The Firepro formulation has no better temperature stability or mechanical

properties, or life expectancy than Stat-X, and Stat-X products have been granted
a UL listing which requires explicit testing for these exact properties. Firepro has
not.

The Firepro composition contains metallic magnesium as well as potassium nitrate

which are very common ingredients in pyrotechnic compositions. Magnesium when
used in such pyrotechnic compositions is known to quickly degrade causing
variations in burn rate unless hermetically sealed - which is very unlikely based on
the construction of the Firepro units

False Firepro Claim 5: Firepro uses a simple and reliable heat element to activate
their units while Stat-X utilizes a primitive methodology containing pyrotechnics.

Response: Stat-X uses a highly reliable ignition device which is hermetically

sealed with a silicone coating to insure long life and reliability as evidenced by
reliability testing under UL 2775. Over 1200 devices were tested under various
electrical and environmental conditions without failure during the listing process.
The device is highly reliable, and operates with low power requirements making it
easy to interface with a wide range of commercially available releasing panels.

The Firepro activator has relatively high power requirements making it difficult to
interface with standard panels.

False Firepro Claim 6: Firepro uses a physical coolant (crushed marble) while
Stat-X utilizes a chemical coolant (activated alumina spheres).

11503 K-Tel Drive • Minnetonka, MN 55343

Phone: 952.935.9745 • Fax: 952.935.9757 • www.statx.com
Response: We are not sure whether Firepro is just being disingenuous or whether
they really are ignorant regarding the properties of the two coolant materials in
question.

Activated Alumina (aluminum oxide) is manufactured to be strong, porous, and dry

and provides large surface area interaction with the discharged aerosol resulting in
very effective cooling by physical means. There is no chemical interaction with the
aerosol and no chemical by-products formed as a result.

The crushed marble utilized by Firepro is primarily calcium carbonate with an

unknown number and amount of impurities. These decompose during the reaction
with unknown products produced. The only advantage of the crushed marble is that
it is readily available and cheap. It has no technical advantages.

Firepro also asserts that their product has been tested and the output certified by
KEMA while Stat-X has no data on output. The true fact is Stat-X output has been
tested by Talley Laboratory which is certified by the American Association for
Laboratory Accreditation an internationally recognized body (which Firepro lists in
their own documentation to support the reliability of KEMA) which is the
accreditation required by UL for all laboratory results and instrumentation
certifications used in testing. A copy of our results is available upon request.

The fact is both Stat-X and Firepro have been approved under the US EPA SNAP
program under identical use restrictions. To claim that Stat-X is somehow
uncertified or less environmentally friendly is ridiculous.

False Firepro Claim 7: Firepro claims that the resin used in the Stat-X
formulation (which they erroneously try to associate with formaldehyde) is
somehow dangerous while their own resin is not.

Response: Here we have another case of deliberately misleading information (or

ignorance) by Firepro. They equate a ‘phenol-formaldehyde’ resin with
‘formaldehyde’. Since the resin is formed by a chemical reaction between the
phenol and the formaldehyde there is no free formaldehyde left in the resin. The
resin used by Firepro contains phenol and it is interesting to note that they do not
point out any ‘danger’ from the phenol in their own product as their product would
then come under the same attack. This argument by Firepro is completely
disingenuous.

If the reader wishes to obtain their own solid information they can search on the
web for CAS 9003-35-4 and discover for themselves that there is no significant
hazard associated with this resin. We could point out the hazard of the other
compound used in the Firepro epoxy system but since it, too, reacts and is no
longer present - to do so would lower us to the same level of the deliberate
dissemination of misinformation as Firepro.

We should also point out that the resin in Stat-X amounts to only 8.5% while the
resin contained in the Firepro composition is 18%.
There is no point in dealing with the individual components of either formula in
isolation. The output of the condensed aerosol is a product of a combustion process
with attendant reactions between the chemical components influenced by the
method of manufacturing the compound, the purity of the base chemicals, and the
construction of the generator housing itself. All play a role in the characteristics of
the aerosol produced.

False Firepro Claim 8: Firepro claims a fifteen year life for their product while the
10 year life for Stat-X, somehow, indicates an instability in the product.

Response: While Firepro claims a fifteen year life but, again, as in most of their
claims it is disingenuous due to the “qualifiers” contained in their design manual:

“Life (of the container and activator):

A- three years with inspection every three months for very aggressive
environments
B- five years with inspection every six months for aggressive chemical
environments
C- 10 years with an inspection every year for commercial and industrial
environments
D- 15 years with an inspection every year for offices, computer centres,
shopping centres, environments with air conditioning”

Not exactly 15 years!

The fact is, life testing is conducted at temperature and is a function of the
temperature and time in the oven. Stat-X tests were done at a temperature and
time which yield a 10 year life under UL criteria, 12 years under ULC criteria, and
19.8 years under the criteria proposed under the pending ISO and CEN Draft
Standards. To claim that the Firepro device is somehow more stable than Stat-X is
completely disingenuous. On the contrary, the Firepro 20 (which like the Firepro 80
was not able to achieve listing by ULC) is little more than a marine flare, unsealed
and exposed to the environment. Marine flares have a life expectancy of 2-3 years
and there is no reason to believe that the FP20 is any different.

All Stat-X models from the 30g up through the 2500g utilize stainless steel housing
and are hermetically sealed from the elements insuring consistent performance
over time.

False Firepro Claim 9: Firepro claims that Stat-X lacks approvals and significant
real world references while Firepro has 59 approvals and a host of large project
references fro major customers.

Response: Quantity is not to be confused with Quality. There are only three
significant approvals relative to condensed aerosols from Listing Bodies with a
history in both the evaluation and testing of fire protection equipment in general
and condensed aerosol technology in particular. The three are Underwriters
Laboratories in the United States (UL), Underwriters Laboratories of Canada (ULC),
and CSIRO (Active Fire) in Australia. The facts are simple. Stat-X is the only
condensed aerosol product Listed by all three and the only condensed aerosol
product in the world Listed by UL! Firepro has up to now been unable to get

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Phone: 952.935.9745 • Fax: 952.935.9757 • www.statx.com
through the listing process with UL and has only recently been approved by CSIRO
after several years of trying.

Stat-X also has many of the other approvals that Firepro claims such as MCA, ECB,
etc. The fact is that Stat-X in all cases has been approved and listed by these
organizations with more favorable application densities – proof of its superior
effectiveness.

Firepro does indeed have a long list of clients – but based on the large number
converting to Stat-X we can only assume that many of them have found the reality
of using Firepro to be much less the than their exaggerated claims.

Stat-X, as a later generation product, is rapidly gaining acceptance as the highest

quality aerosol product available and can claim NASA, the US Department of
Defense, and many other knowledgeable major clients.

False Firepro Claim 10: Firepro claims that Stat-X is not being applied at the
correct application rate.

Response: This is completely false. Stat-X application rates are determined as

part of the UL Listing process and include a 30% safety factor.

In an earlier section we alluded to the fact that there is wide variability in the actual
amount discharged by the various Firepro models. This variability in the amount
discharged is very significant. Firepro has, to our mind, an odd method for
calculating application density. Generally, per UL and ULC test procedures all
models are tested at .7692 of Design Application Density during fire tests (this
yields a 30% safety factor in application). This number is the Extinguishing Density
and, if, at any time a higher Extinguishing Density is required in any test or for any
model – than the entire product line must use this “worst case” result. For example,
if all tests are successful at 40g/m3 (based on the gross amount of compound in the
generator) but one test or model takes 50g/m3 than all models are required to be
applied at 50/.7692 = 65g/m3. This effectively eliminates any possibility of negative
variability between models.

In their design manual Firepro uses an Extinguishing Rate multiplied by 1.3 to

derive a “Net Application Rate” which is then divided by an “Efficiency Factor” to
derive their Gross Application Rate. The problem they face is that there is a great
deal of variability from model to model in their line with respect to how much
aerosol is actually discharged from the unit (varies widely from 63% up to 90% on
units with limited cooling). The problem with this approach is twofold - One, it
assumes that all units of a given size are identical in the amount discharged
(questionable based on their production methods) and Two, it requires the
distributor to remember to divide by the “Efficiency Factor” in order to apply the
proper amount of agent. If this is not done the Application Rate is in error.

In addition, Firepro gives no method in their design manual for compensating for
leakage or height of enclosure which are significant design factors since the aerosol
will leak from openings during discharge and will rise due to its buoyant nature.
All Stat-X systems are designed by trained, certified distributors using a computer
aided design program which allows them to design for all factors including leakage
and adjustments for height. This dramatically improves the quality and reliability of
the system as designed, insuring the correct amount of aerosol is applied for the
specific parameters of the hazard – including the 30% safety factor. This method of
design is approved as part of our UL Listing.

Summary:

Firepro has made a number of false claims about Stat-X in an effort to confuse an
uninformed audience unfamiliar with the technology. We have no idea whether they
are doing this with the intention to deceive or whether they are doing so out of
technical ignorance. The fact is the data they are disseminating is wrong!

We have always taken the high road in discussions of aerosol technology. All
aerosols will be very effective in extinguishing fires. It is a simple function of the
technology. The difference between aerosols and their effectiveness is a function of
the quality and purity of the chemicals used in the formulation, methods and quality
control during the manufacturing process, and the technical aspects of mating the
solid composition with the generator. All of these are important factors in the
characteristics of the aerosol produced.

In addition, proper application of the product is a function of design control, training

and certification of distributors, and fire protection experience.

With our focus on customer service, quality control, computer aided design, and
management with over 50 years in combined fire protection experience we believe
Stat-X is the highest quality and most effective condensed aerosol product on the
market. This is evidenced in fact by our Listings with UL, ULC, and CSIRO, the US
EPA, and other significant Listing Bodies such as MCA, ECB, and ABS.

We will let the facts speak for themselves.

11503 K-Tel Drive • Minnetonka, MN 55343

Phone: 952.935.9745 • Fax: 952.935.9757 • www.statx.com