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The fine print

By: Elvis Hoffpauir

On July 2, 2015, the final rule Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the Significant New Alternatives Policy Program was signed by EPA Administrator Gina McCarthy. Specifically, this action changes the listings from acceptable to unacceptable for certain hydrofluorocarbons (HFCs) and HFC-blends in various end-uses in the aerosols, refrigeration and air conditioning, and foam blowing sectors.

This final rule also changes the status from acceptable to unacceptable for certain hydrochlorofluorocarbons (HCFCs) being phased out of production under the Montreal Protocol on Substances that Deplete the Ozone Layer and Section 605(a) of the Clean Air Act. The rule, published in the Federal Register on July 20, has an effective date of August 19, 2015.

Regarding the mobile A/C industry, this rule makes the use of HFC–134a unacceptable in new automobiles and light trucks as of Model Year (MY) 2021, except where allowed under a narrowed use limit through MY 2025.

Of primary importance to the mobile A/C service industry, the published rule notes that “EPA did not propose and is not making any changes that would alter the ability to service existing motor vehicles designed to use HFC-134a.”

R-1234yf label in a new car

R-1234yf label in a new car

SAE International and Alliance of Automobile Manufacturers (AAM) commented that there are aerosol products available for servicing MVAC systems which contain additives in a can propelled by HFC–134a which the commenters believe should be acceptable, subject to use conditions. The commenters stated that the use of propellants other than HFC–134a could cause technical problems, could contaminate refrigerant so that EPA approved Recovery, Recycling and Recharging (RRR) equipment cannot be used, or could be incompatible with SAE standards if the propellant goes into the MVAC systems.

In its response, EPA noted that the Agency considers an aerosol can containing HFC–134a used to recharge an MVAC system to fall under the MVAC end-use and not the aerosol propellant end-use. Under the SNAP lists for the MVAC end-use, HFC–134a remains an acceptable substitute for servicing existing systems. An aerosol can containing HFC–134a refrigerant and oil or leak sealant, which is used to inject oil or repair leaks and to then recharge MVAC systems, would also fit in the MVAC end-use and remains acceptable for use on existing systems. These cans must have the unique fittings required by SNAP for HFC–134a as a motor vehicle air conditioner refrigerant. However, an aerosol can primarily intended to inject additives, e.g., dye, rather than to add HFC–134a as a refrigerant would be considered an aerosol, and use of HFC–134a as the propellant would not be allowed as of July 20, 2016, under this final rule.

There are also several blend refrigerants that have been listed as acceptable or acceptable, subject to use conditions, since 1994, but that have never been developed for use in MVAC or used in manufacture of new vehicles. This rule will change the status of these refrigerant blends to unacceptable as of MY 2017 for use in newly manufactured light-duty vehicles.

Commenters suggested that EPA should change the SNAP status for the blend refrigerants to unacceptable for retrofit (in addition to new) MVAC uses. EPA responded that additional information, as well as an opportunity for public comment, would be necessary before the Agency “would be able to potentially find the refrigerant blends unacceptable for use in retrofits.”

The results of a 2014 industry survey submitted by AAM and the Association of Global Automakers (Global Automakers) and cited by EPA as a public comment to the rule found that automobile manufacturers who responded to the survey had plans in place to transition 90% of light-duty models sold in the United States by or before MY 2021.

EPA expects that the industry will begin with a 20 percent transition from HFC-134a beginning in MY 2017, to be followed by a 20 percent increase in substitution in each subsequent model year, completing transition in MY 2021.

The complete rule has 90 pages of fine print, 12 pages of which relate specifically to the mobile A/C industry. As published, the rule reflects a dialogue among voices from the industry and the EPA. While the CliffsNotes version of the rule appears above, a review of pages 42888 through 42900 in the Federal Register provides insight from the perspective of many within the industry, as well as EPA’s approach and rationale regarding the subject. It makes for interesting reading.

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