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Regulatory news

SNAP

EPA’s Significant New Alternatives Policy (SNAP) program was established to evaluate substitutes for the ozone-depleting substances. Through SNAP Rules and Notices, EPA generates and maintains lists of acceptable and unacceptable products (i.e. refrigerants, foam blowing agents, etc…) by industry and by specific application.  

 

EPA has recently issued two major “delisting” rules, which establish sunset dates for a number of HFCs and HFC blends for use in refrigeration, air conditioning, foam blowing, and other applications:

 

Rule 20 (SNAP1), issued on July 20, 2015, sets sunset dates for a number of HFCs and HFC blends used in the following applications (some of the dates are already in effect):

  • In refrigeration, 404A, 407, 507A and others, used in supermarket systems, remote condensing units, standalone units, and vending machines;
  • In PU Foams, 134a, 245fa, and 365mfc as well as blends and several other products.

 

For a complete list of products and applications affected by Rule 20, please refer to EPA’s fact sheet at: https://www.epa.gov/snap/final-rule-protection-stratospheric-ozone-change-listing-status-certain-substitutes-under

 

Rule 21 (SNAP2) was issued on December 1, 2016, and affects HFCs and HFC blends in the following applications:

  • In refrigeration, sunset dates are set for the use of certain HFCs and bends in chillers, retail food and food processing and dispensing, and household refrigerators;
  • In air conditioning, use of ASHRAE Class 3 flammables (most hydrocarbons) is prohibited in residential and light commercial applications;
  • In PU spray foam, sunset dates are set for use of 134a, 245fa, 365mfc, and several other products and blends.

 

For complete list of products and applications affected by Rule 21, please refer to EPA’s fact sheet found here: https://www.epa.gov/snap/fact-sheet-final-rule-21-protection-stratospheric-ozone-significant-new-alternatives-policy

 

It is important to understand that when a refrigerant is listed as unacceptable as of a certain date, it applies only to new systems or retrofits. As long as the refrigerant is commercially available and your equipment is working, you can continue to use it.

There were also two Notices of Acceptability published in 2016, which allow HFC blends, such as 448A, 449A, 449B, 513A, and others, in a number of applications. Please refer to https://www.epa.gov/snap/snap-regulations for a complete list of EPA SNAP publications.

 

On July 21, 2017 the EPA issued a new “determination of acceptability” adding a number of new refrigerant blends to the list of approved substitutes and expanding the list of approved end uses for some of the previously approved substitutes.  Arkema’s Forane 452C and Forane 449B are among the products on the list.

SUMMARY OF ACCEPTABLE SUBSTITUTES End-Use

Substitutes

Refrigeration & Air Conditioning

Cold Storage Warehouses (New & Retrofit)

R-448A, R-449A, R-449B, R-453A

Industrial Process Refrigeration (New & Retrofit)

R-448A, R-449A, R-449B, R-453A, R-458A

Non-Mechanical Heat Transfer Systems (New & Retrofit)

HFE-7300 (1,1,1,2,2,3,4,5,5,5-decafluoro-3-methoxy-4-(trifluoromethyl)pentane)

Refrigerated Transport – Refrigerated Trucks and Trailers (New & Retrofit)

R-452A, R-452C

Retail Food Refrigeration – Remote Condensing Units (New & Retrofit)

R-407H, R-442A, R-452A, R-452C, R-453A, R-458A

Residential Dehumidifiers (New & Retrofit)

R-513A

Residential and Light Commercial Air Conditioning and Heat Pumps (Retrofit)

HFC-134a, R-458A

Cleaning Solvents

Electronics Cleaning, Metals Cleaning, Precision Cleaning

HFE-7300 (1,1,1,2,2,3,4,5,5,5-decafluoro-3-methoxy-4-(trifluoromethyl)pentane)

 

The new listing rule is effective immediately and a fact sheet can be found here: https://www.epa.gov/sites/production/files/2017-07/documents/snap_notice_33_fact_sheet.pdf

 

Section 608 – refrigerant management

The updated Section 608 was published in November 2016, and it extends the refrigerant safe handling requirements to HFCs. The rule lowers the leak rate thresholds that trigger mandatory repairs of refrigeration and air-conditioning equipment, requires quarterly/annual leak inspections or continuous monitoring devices for refrigeration and air-conditioning equipment that have exceeded the threshold leak rate, and requires owners/operators to submit reports to EPA, if the equipment containing 50 or more pounds of refrigerant leaks 125% or more of its full charge in one calendar year, and new recordkeeping is required for the disposal of appliances containing 5 to 50 lbs of refrigerant. These requirements will become effective on January 1, 2018, at the exception of the revised leak repair provisions, which will become effective on January 1, 2019.


EPA has issued several fact sheets to assist appliance disposal and recycling facilities, distributors and wholesalers, refrigerant reclaimers, supermarkets, and other properties and facilities, and technicians. Fact sheets are available at https://www.epa.gov/snap/snap-regulations.

Montreal Protocol

The Kigali Amendment (adding HFCs to the Montreal Protocol) will go into effect in 2019 if ratified by at least 20 countries.  With the recent decision by the Council of the European Union to ratify the amendment, it is expected to go into effect on schedule.

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