Technician testing a central air conditioning unit

How Will EPA's HCFC Phaseout Affect the AC-Refrigeration Industry?

On Jan. 1, 2010, two important federal rules take effect: Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export and the Ban on Sale or Distribution of Pre-Charged Appliances.

Their main purpose is to further restrict the use of substances that harm the Earth's protective ozone layer and contribute to climate change. The restrictions are required both by the Montreal Protocol and federal law to combat health hazards – skin cancer, cataracts, and weakened immune systems – caused by excessive exposure to ultraviolet radiation.

The targeted chemicals are hydrochlorofluorocarbons primarily used as refrigerants:

  • HCFC-22, better known as R-22,
  • HCFC-142b,
  • HCFC-123,
  • HCFC-124,
  • HCFC-225ca, and
  • HCFC-225cb.
While many people in the industry have heard about upcoming changes, they and others still may have questions about how the rules will affect their businesses. Here are some of the answers provided by the rules' authors in the Stratospheric Protection Division of the U.S. Environmental Protection Agency.

What do the rules do?

The Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export rule reduces the amount of virgin R-22 and other HCFCs that will be available after Jan.1, 2010. The R-22 that will be produced may be used only to service equipment that is in use by the end of 2009.

The Ban on Sale or Distribution of Pre-Charged Appliances rule prohibits the sale and distribution (including import) of any appliances and appliance components that are "pre-charged" with R-22 or R-142b – if they are manufactured or imported after Jan. 1, 2010.

When will R-22 (or blends containing R-22 and/or R-142b) no longer be available for purchase?

Currently, technicians who are certified under Section 608 of the Clean Air Act may purchase newly manufactured R-22 to service existing appliances. EPA has restricted the total amount of produced and imported R-22 available in 2010 and will completely stop its production and import in 2020. The agency expects that sufficient amounts of recycled and reclaimed R-22 will remain available after 2020 to service or maintain equipment.

Technicians should properly recover and recycle R-22 from existing refrigeration and air-conditioning equipment to help ensure the availability of future supplies. Recovered refrigerant cannot be resold to a new owner for use as a refrigerant. Instead, it must be sent to a reclaimer.

Are there any exceptions to the rules?

EPA is providing an exception to the allocation rule that allows virgin R-22 to be used in the onsite "manufacture" of appliances for a particular project between Jan. 1, 2010, and Dec. 31, 2011, if the components have been specified for use at that project under a building permit or contract dated before Jan. 1, 2010.

Also, under the allocation rule, HCFC-22 produced prior to Jan. 1, 2010, may be used until Jan. 1, 2015, for the manufacture of thermostatic expansion valves and medical equipment.

What alternatives to R-22 are acceptable and available?

A number of alternatives to R-22 do not deplete the ozone layer, including R-134a, R-404A, R-407C and R-410A. In the United States, R-410A is the most popular choice for home air conditioners. R-410A is sold under several trade names, including GENETRON AZ-20®, SUVA 410A®, Forane® 410A and Puron®.

EPA evaluates and regulates substitutes for ozone-depleting chemicals through the agency's Significant New Alternatives Policy (SNAP) Program. EPA maintains a list of acceptable and unacceptable substitutes according to end use, including end uses in the refrigeration and air-conditioning sector. To help technicians decide which alternatives are best for specific uses, the agency developed a list of questions to ask before purchasing alternative refrigerants. If substitutes are used in retrofitted equipment, technicians should be trained on proper retrofit installation and servicing techniques. Note that some alternatives, including R-410A, are not allowed in retrofits.

May technicians use recovered HCFC refrigerants?

Yes. A technician may recover material from an owner's equipment and recharge equipment belonging to that same owner, with the recovered material. The technician may recycle the recovered refrigerant, which involves extracting it and cleaning it for reuse without meeting the requirements for reclamation. This recovered, recycled refrigerant may only be recharged into equipment belonging to the owner of the equipment from which the refrigerant was recovered. The technician also may send the recovered material to an EPA-certified reclaimer; once the refrigerant is reclaimed, it may be sold and used for servicing any existing equipment.

How should HCFC refrigerants be disposed of?

Recovered HCFC refrigerants should be sent to an EPA-certified refrigerant reclaimer. Only EPA-certified reclaimers may reclaim and sell used refrigerants to a new owner. Technicians and contractors may also send HCFC refrigerants to be destroyed. HCFCs and other controlled substances that are destroyed must be completely destroyed at a destruction efficiency of 98 percent or greater, by using one of the approved destruction technologies, such as incineration.

How should equipment containing HCFC refrigerants be disposed of?

Under Section 608 regulations, the refrigerant contained in the equipment must be disposed of safely. EPA developed Safe Disposal Requirements that must be followed for the environment's sake. Equipment that is typically disassembled on-site before disposal has to have the refrigerant recovered following EPA's requirements for servicing. For equipment that typically enters the waste stream with the charge intact (such as household refrigerators and freezers, room air conditioners), the final person in the disposal chain (such as a scrap metal recycler or landfill owner) must make sure that the refrigerant is recovered from the equipment before its final disposal. However, persons earlier in the chain can remove the refrigerant and provide documentation of its removal to the final person. EPA has a voluntary partnership program, Responsible Appliance Disposal (RAD), where partners use best practices to properly recover refrigerants, foam blowing agents, plastics, glass, mercury and polychlorinated biphenyls.

Should technicians discuss the HCFC phase-out with customers?

Yes. Technicians should explain that HCFCs are being phased out worldwide and that the future availability of R-22 is restricted to the servicing of existing equipment. Consumers should be aware that the continued use of existing appliances with R-22 is not banned. Nor is there an EPA mandate for the conversion of existing R-22 equipment. Technicians can also send customers to the portion of the agency Web site that is designed for them.

Are there any restrictions on the purchase of HFC refrigerants?

HFCs are not ozone-depleting substances, but they have high global warming potential. At this time, the purchase of HFC refrigerants is not restricted. (For example, there is no technician certification requirement for those who purchase HFC refrigerants, such as R-410A or R-134a.)

Are there any limitations on the use of HFC refrigerants?

Yes, a specific HFC refrigerant must be found acceptable as a substitute for a specific end use by the SNAP Program. In addition, it is illegal to knowingly vent or release these refrigerants. The venting prohibition applies to R-134a, R-410A, and all other HFC refrigerants, just as it does for ozone-depleting refrigerants like R-22.

Why is this transition important?

The environmental and public health effects of this transition will not be felt immediately. But the ozone layer is on track to recover later this century, assuming the United States and other countries continue to meet their international commitments. The EPA thanks you for your hard work in helping us protect the environment. Our children and our children's children will thank you as well, as they will live under less dangerous skies as a result of our combined efforts.

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