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Learnings from Safety Professionals: Refrigerant Rule Revisions

Tamara Parris

During our Refrigerant Rule Revisions discussion with Kirk Lowry we learned a great deal of information and knowledge about the phase out schedule and significant changes to refrigerant management regulations. 

Kirk discussed the following during this live session:

  1. Recent SNAP (Significant New Alternatives Policy) delistings and accepted alternative blends

  2. Kigali Amendment to the Montreal Protocol

  3. Extension to non-ODS (ozone depleting substance) containing substitutes

  4. Revised appliance disposal requirements

  5. Revised leak repair provisions for appliances with full charge ≥ 50 lbs

  6. Compliance deadlines

It was an extensive discussion that is challenging to summarize in one post. I encourage members to view the recording at this link, and please share out with your network.

We did get insights from our member participant through several discussion questions.

We asked our members if their organizations had a "Facility preparing for eventual retrofit and/or retirement of refrigerant systems that contain R-22, R-134a, or R-410A?" 83 members participated.

26 members shared they have No Plan, 17 rely on Repair Replacements,12 on Vendors and 12 Upgrades. The remaining 16 stated either 6 Consultants, 4 Inventory, 3 Procedures, or it was not applicable.

When asked "How does your facility track the servicing of refrigerant containing appliances?" 

31 members shared they had a Conractor, 23 rely on Maintenance and 18 use software. The remaining few stated either they do not track or it was not applicable to them.

The last question we asked memebrs was "How does your facility track the disposal of refrigerant containing appliances?"

35 members shared they had a Conractor, 25 rely on Maintenance  Logs  and 10 use software. The remaining few stated either they are not sure or do not track.

Kirk shared with us how the EPA’s SNAP Program would play a role in  the phase Out Schedules. Sharing that the SNAP Program reviews, and approves or disapproves substitute refrigerants for specific end-uses. That the EPA has used the “worst first” approach to first identify approved or disapproved substitutes for CFCs (e.g., HCFCs such as R-22 approved as replacements), then identified approved/disapproved substitutes for HCFCs (e.g., HFCs such as R-410A approved as replacements) and lastly, disapproved previously approved uses of HFCs.

To briefly summarize the discussion about the Kigali Amendment; Kirk mentioned the HFC phase down requirements for developed countries. We invite members to watch the recording at this link of the session for full details. He did state that if ratified, EPA could amend 40 CFR 82 to implement the phase down of HFCs.

There was much more covered during the live session, however to wrap up this post here are his concluding points.

  1. HFC refrigerants (e.g., R-134a, R-410A) are EPA’s new target since they are potent global warmers
  2. Watch for additional SNAP disapprovals for HFC refrigerants
  3. Watch for U.S. ratification of Kigali Amendment and phase down on production of HFC refrigerants (10% by 2019, 40% by 2024, 70% by 2029, 80% by 2034, & 85% by 2036)
  4. Expect prices for HFC refrigerants to rise
  5. Analyze new AC unit installations and retrofits based on available cost data and unit lifetimes
  6. Use EPA required work practices for ODS-containing refrigerants (e.g., R-12, R-22) on non-ODS substitutes (e.g., R-134a, R-410A)
    • •Certified technicians
    • •Certified recovery/recycling equipment
    • •Required refrigerant evacuation levels
  7. Prepare for new leak repair provisions on ≥ 50 lb units
    • •Conduct initial and follow-up verification testing for all leaks
    • •Implement system to maintain new records
    • •Test drive in 2017 and/or 2018

July 12, 2017 @ 11:02 AM EDT

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