U.S. Refrigerant Policies Continue to Evolve
Wisconsin opens the door for DIY refrigerant use.
In recent discussions with U.S. Environmental Protection Agency (EPA) officials, it is evident that the development of U.S. refrigerant policies is ongoing at the federal level. In the last couple of years, the EPA heard comments on refrigerant substitutes and provided alternatives to the automobile industry. A limited number of manufacturers have begun using the latest substitute available.
States are not immune from refrigerant policymaking this year either. The governor of Wisconsin signed legislation this year that blocks the state environmental agency from promulgating regulations prohibiting the sale or offering for sale refrigerant substitutes. This new law allows distributors to sell refrigerant in containers smaller than 15 pounds. Wisconsin had the only state law that prohibited the sale of the hydrofluorocarbon (HFC) refrigerant R-134a in containers for the do-it-yourself (DIY) customer. R-12 is not available for use in the United States, having been phased out in the mid 1990s.
The EPA reports that since the mid 1990s, motor vehicle air conditioning (MVAC) has used HFC refrigerant R-134a, which does not deplete the ozone layer but does have high global warming potential (GWP) that is approximately 1,400 times greater than carbon dioxide. In the United States, MVACs consume 7 billion gallons of gasoline every year, emitting more than 58 million metric tons of carbon dioxide. Refrigerant leakage adds the equivalent of more than 50 million metric tons of carbon dioxide to the atmosphere each year.
How was R-134a selected as a replacement for the chlorofluorocarbon (CFC) refrigerant R-12 in automobile air-conditioning systems? The EPA discloses that engineers for automotive manufacturers conducted research and testing on many potential substitutes for R-12 before selecting R-134a. As part of this research and testing, they reviewed the potential health effects, toxicity, flammability and corrosivity of each potential substitute; evaluated the effect of each compound on the life and performance of the air conditioning components in the various models made by each manufacturer; and investigated the effect of each compound on the system’s cooling capacity. They determined that R-134a was the most suitable alternative.
Under its Significant New Alternatives Policy (SNAP) program, the EPA is revising a requirement for the use of the hydrofluoro-olefin (HFO) refrigerant R-1234yf as an acceptable substitute for ozone-depleting substances in MVAC systems. The agency found this alternative acceptable, subject to use conditions, in March 2011. In that same month, the SNAP program issued a final rule allowing the use of the refrigerant R-1234yf, subject to certain use conditions to ensure safe use.
The Automotive Service Association (ASA) submitted comments on R-1234yf in January 2010, emphasizing that:
“Although our members certainly understand the continued development of alternative products for use in motor vehicle air conditioning systems, ASA does believe there should be some additional criteria for the use of the HFO-1234yf. As indicated in the proposed regulation, there has been some research relative to the flammability of the proposed substitute HFO-1234yf.
“ASA asks that the EPA include both a certification process and an equipment requirement for any purchasers of HFO-1234yf for use in motor vehicle air conditioning systems. This is a new substitute and should require a new test for those persons applying the product. Proof of certification should be a prerequisite to purchasing the product for use in air conditioning systems. In addition, purchasers of HFO-1234yf should also be required to have the proper equipment to use this product.
“These products are designed for professional use. Allowing those persons not trained and certified and without the proper equipment to purchase HFO-1234yf is not in the best interest of the consumer.
“We respectfully ask that the EPA include provisions in the final regulation for the use of HFO-1234yf as a substitute in mobile vehicle air conditioning that require a new test to certify those persons purchasing HFO-1234yf and that the purchaser have the proper equipment prior to the purchase of the product.”
It is ASA’s understanding that the agency has no plans to allow the sale of R-1234yf in small containers. In addition, refrigerant-testing entities will be asked to develop new tests and certifications for R-1234yf. There will be no retesting, due to R-1234yf, for technicians already certified for refrigerants.
A list of acceptable and non-acceptable EPA refrigerant substitutes can be found on the agency’s website at www.epa.gov/ ozone/snap/refrigerants/lists/mvacs.html.
From a policy perspective, ASA is most interested in assuring that these alternative refrigerants are installed by professionals, that testing and certification processes remain in place and that no additional servicing mandates be established. Finally, current regulations should be enforced.To learn more about regulatory and legislative issues that impact independent automotive repairers, please go to ASA’s legislative website, www.TakingTheHill.com.
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