Do fire extinguisher refills count in Scope 1?

Yes, when the refill replaces gas that was released. The kilograms refilled after a discharge or leak are a Scope 1 fugitive emission. CO2 extinguishers count kg for kg. HFC agents such as HFC-227ea (FM-200) count at their GWP and can be material. Dry powder, water, foam and FK-5-1-12 add nothing material.

Which refills are emissions

• Refill after a fire, a drill or an accidental discharge: the gas went to the air, so the kilograms refilled are the emission.
• Top-up after a slow leak found at inspection: same rule, the top-up equals the loss.
• First fill of a new extinguisher or system: no emission, nothing has been released yet.
• Gas recovered into a cylinder during hydrostatic testing and put back: no emission, provided it was really recovered.
• Disposal of an old unit: count any gas vented rather than recovered.

What each agent is worth

• CO2 extinguishers and CO2 flooding systems: 1 kg released = 1 kg CO2.
• HFC-227ea (FM-200), common in server rooms and panel rooms: GWP 3,600 under IPCC AR6 (3,350 under AR5), so 1 kg released is 3.6 t CO2e.
• FK-5-1-12 (Novec 1230 type agents): GWP under 1, so negligible.
• Dry chemical powder (ABC, mono ammonium phosphate), water mist and foam: no greenhouse gas.
• Halons 1211 and 1301: ozone depleting substances under the Montreal Protocol. The GHG Protocol keeps them out of the Scope 1 total; report them separately if you still hold any.

When it is worth the effort

For a site with only CO2 and powder extinguishers, refills after drills add a few hundred kilograms of CO2 a year at most. Record them for completeness, but they will not move your total.

A clean agent system on HFC-227ea is different. One accidental discharge of a 100 kg system is 360 t CO2e under AR6, more than many MSMEs emit from diesel in a year. Track these systems by serial number.

Records to keep

1. The refill or service invoice showing agent name and kilograms filled.
2. The reason for the refill: fire, drill, leak, test or first fill.
3. The GWP edition used, AR5 or AR6, applied to the whole inventory.
4. For fixed systems, the cylinder weight log from each inspection, since a weight drop is a leak.

Worked example: one year at a warehouse

• 30 CO2 extinguishers refilled after a drill, 4.5 kg each: 30 x 4.5 = 135 kg CO2
• Server room FM-200 system discharged by fault, 80 kg refilled: 80 x 3,600 = 288,000 kg CO2e (AR6)
• Total fire suppression Scope 1: 135 + 288,000 = 288,135 kg, about 288.1 t CO2e
• Same FM-200 refill under AR5: 80 x 3,350 = 268,000 kg CO2e

The HFC line includes a gas other than CO2, so the total is CO2e.

What Senseible does here

Senseible reads refill and service invoices with the agent and kilograms and keeps them as evidence for a Scope 1 line. A refill invoice alone does not prove a release, so record why each refill happened, then multiply the kilograms released by the agent's GWP and note the IPCC edition.

• Refrigerant top-up invoice to CO2e
• AR5 or AR6 GWP values
• Scope 1 for Indian manufacturers

Sources: US EPA Center for Corporate Climate Leadership, Direct Fugitive Emissions from Refrigeration, Air Conditioning, Fire Suppression, and Industrial Gases (mass balance method), IPCC AR6 WG1, Chapter 7 Supplementary Material, Table 7.SM.7 (GWP100), GHG Protocol Corporate Standard

Last reviewed 2026-10-17.