Exploring EPA Regulations, HVAC/R Technology Changes, and their intersection between Clean Air Act Revisions, EU’s CSRD, and SEC Scope 1 Reporting on Maintenance, record-keeping, reporting and planning for the year ahead.

Trakref® / EPA  / Exploring EPA Regulations, HVAC/R Technology Changes, and their intersection between Clean Air Act Revisions, EU’s CSRD, and SEC Scope 1 Reporting on Maintenance, record-keeping, reporting and planning for the year ahead.
Exploring EPA Regulations HVACR Technology Changes

Exploring EPA Regulations, HVAC/R Technology Changes, and their intersection between Clean Air Act Revisions, EU’s CSRD, and SEC Scope 1 Reporting on Maintenance, record-keeping, reporting and planning for the year ahead.

Navigating the evolving regulatory landscape of the refrigerant industry starts with understanding that 12.5 Billion Pounds of refrigerant have been vented since 1994 in the US.

Refrigerants known by names like freon and F-gasses serve a critical need and serve as a great coolant keeping food fresh, drugs safe, people comfortable, data moving but they are also powerful greenhouse gas gasses, with potential CO2 equivalent emissions for common refrigerants ranging from approximately 1 LB of refrigerant = 1 -11 tons of equivalent.

The EPA has received authority from Congress under the AIM act to manage the transition from high GWP refrigerants to lower global warming potential refrigerants. At the same time, refrigerants profile is growing in importance as corporate social responsibility is focused on efforts to reduce greenhouse gas emissions.

The significant impact to the environment caused by refrigerants, means that in addition to EPA regulations, other initiatives are being developed by organizations like the securities and exchange commission (SEC) and EU Climate related financial disclosures.

Refrigerant regulations and scope 1 disclosures serve as operational cornerstones and provide fundamental operational elements. As energy and resources are invested into emissions reduction programs governance and guidance are needed to provide a new business model to support carbon accounting and the increasing significance of ESG (Environmental, Social, and Governance) reporting.

Combined refrigerant regulations and scope 1 of climate related risks disclosures serve as operational cornerstones aspects serve as essential pillars for understanding material impact. Investors growing concern over risk and caused by sustainability and regulatory compliance business as usual model the service industry has applied to solving the leak.

 

Operations impact on Sustainability Accounting

The investment decision is a selection process based on return considerations, market conditions, and risk assessment. ESG is a tool that when transparent and supported by well developed frameworks is able to broaden the investors’ risk universe and improve the quality of their investment decision. For the firms, it comprises a reporting and compliance requirement and a conceptual framework to analyze and manage the associated operational and the same of climate related risks and related risks. In this respect, ESG reporting is an important facilitator for better investment decisions and management.

Moreover, when evaluating investment opportunities, it is crucial to consider the business model financial condition operational and environmental performance aspects related to refrigerants. Higher refrigerant emissions within a company’s operations suggest a greater need for maintenance dollars to be invested in break-fix repair models. Additionally higher emissions may indicate that a company owns an older fleet of equipment, which may require more frequent repairs and replacements which are less efficient and more costly to operate.

Conversely, lower leak rates of refrigerants might indicate a proactive approach to preventive maintenance. Companies with lower leak rates tend to invest in regular inspections and maintenance practices, minimizing the need for costly repairs and reducing the risk of equipment failures.

It is important to note that higher leak rates not only result in increased environmental impact, but increases in maintenance costs and higher energy use. Refrigerant loss or leaks result in systems working harder to maintain optimal performance levels. This increased energy consumption results in higher electricity bills and reinforces the need for additional electricity purchases. Then there is the concept of the source of the energy, is it coal, gas, solar, wind? How does that further impact greenhouse gas GHG emissions. This issue will have a material impact and a compounding net impact.

By incorporating these operational considerations such risks as climate related risks to refrigerants into the ESG analysis, investors can gain insights into risks facing a company’s maintenance practices, equipment age, leak rates, and energy efficiency. This comprehensive understanding allows investors to assess the potential financial risks and opportunities associated with climate related risks and with refrigerant management, ultimately enabling better investment decision-making and more effective risk management strategies.

This week, we’re highlighting the status of some emerging regulatory requirements. While the specifics may change, this will give a sense of the extensive and comprehensive nature of the increasing demands around refrigerant management.

 

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Shareholder interests will likely outperform Regulatory Frameworks in driving Change

Ever Since the Montreal Protocol (MP) brought attention to the significant impact caused by refrigerants on the environment, the world has been wrestling with the challenge of balancing innovative products with reducing impact to the environment related to preserving food, expanding population growth into warmer climates and keeping people, data and drugs safe. In my 30 years in business I have observed the failure of numerous initiatives and well intentioned regulations but I have never seen so many changes all occurring at once.

Shareholder interests hold considerable potential in driving transformative change, often surpassing the influence potential impact and benefits of regulatory frameworks. Investors’ voices have the power to directly shape business, and affect corporate strategies and encourage innovative, sustainable business practices. Unlike rigid regulations, shareholders bring flexibility and a keen alignment with the company’s financial success, which can be effective catalysts for significant change

Shareholder interests don’t operate in a vacuum. They are broad and encompassing, requiring an overarching understanding of the company’s mission and strategies. These interests demand measurable and tactical means to monitor progress and steer outcomes, highlighting the need for comprehensive awareness and active engagement other stakeholders in various aspects of the business.

Two great examples of shareholder activism outperforming regulatory frameworks can be seen in the realm of executive compensation.

  1. Say on Pay: “Say on Pay” is a term used for a rule in U.S. securities law (part of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010) that requires a non-binding shareholder vote on executive compensation. While the regulation simply gives shareholders a voice, it doesn’t necessitate the company to act on it. However, it is common practice for many companies to adjust their executive compensation structures based on shareholder votes, even though they are not legally obligated to do so. This demonstrates how shareholders can influence company policies effectively, sometimes even more than legal requirements.
  2. Executive Compensation at McDonald’s: In 2020, shareholders at McDonald’s Corporation put forth a proposal to limit executive bonuses unless the company made progress on reducing its contribution to the public health crisis associated with its food products. While there were no regulatory mandates requiring McDonald’s to tie executive pay to public health metrics, the shareholder proposal led to a public discussion and put pressure on the company to consider the societal impacts of its products.

Markets and industries have acknowledged the inadequacy of current regulatory frameworks, moving beyond the traditional ‘Business as Usual Model’. They are now expanding governance and control mechanisms, establishing more comprehensive structures aimed at achieving better outcomes and even tying executive compensation to outcomes.
 

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Markets and Industries Pioneer New Governance Structures, Transcending Traditional Regulatory Frameworks: The Evolution of Refrigerant Regulations

The EPA, California, Washington, the EU, the Securities and Exchange Commission, GRI(Global Reporting Initiative), SASB (Sustainability accounting standards board), TCFD, NRDC, EIA, and others are uniting their authority and expertise to meet shareholder demands to balance environmental stewardship, product safety challenges and profitability, to better understand risk and improve company performance. Here is a compilation of initiatives currently being deployed by various groups, each accompanied by a brief analysis of their potential impact on markets amidst the existing patchwork of regulations.
 

Updates to EPA 608

EPA 608 is a subsection of the Clean Air Act, specifically targeted toward Ozone Depleting chemicals is the main certification required for HVAC technicians in the U.S. Although the main intention of this section was to reduce the release of harmful refrigerants, it focused exclusively on ozone-depleting which have been phased out for 30 years. But the program remains relevant and after 30 years of case law and operational impacts this regulation has been known as the center point of refrigerant policy. These are the most recent updates still impacting the markets:
 
quotes about EPA 608
 
These rules will remain in place and be supplemented by new regulations soon to be put in place by EPA from authority granted to them by Congress under the AIM Act signed in 2022.
 

New Amendments to the Clean Air Act to accommodate HFC controls.

The Clean Air Act (CAA) is the United States’ primary federal air quality law, intended to reduce and control air pollution nationwide. Initially enacted in 1963 and amended many times since (EPA 608 resides under this section) it is one of the United States’ first and most influential modern environmental laws. Under the CAA there are many programs which are presently not aligned. Here are some of the KPIs that are being updated in the various programs, and refrigerants will be a key part of this update:
 
quotes about New Amendments to the Clean Air Act
 
U.S. facilities are responsible for identifying any specified toxic chemicals above certain thresholds, or if they have emissions related to certain equipment. Responsibilities extend from record-keeping to reporting their annual releases into the environment. This includes recording details of their calculations and methodologies, which they must submit to the Environmental Protection Agency (EPA) annually. EPA’s authority to manage these types of reporting programs is well established and expected to extend to a broader group of refrigerant stakeholders.
 

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The Aim Act – the newest authority in the EPA regulatory framework

The American Innovation and Manufacturing Act (AIM Act) of 2020 aims to combat climate change by significantly reducing hydrofluorocarbons (HFCs), chemicals commonly used in refrigerants.

The AIM Act directs the EPA to spearhead an aggressive phase-down of U.S. HFC production and use by approximately 85 percent over the next 15 years. HFCs are intentionally-made fluorinated greenhouse gases used in the same applications where ozone-depleting substances have been used, including cars, trucks, fire extinguishers, air conditioning, refrigeration and process cooling systems.
 
Quotes about the Aim Act
 
There are three legs to the AIM Act, 1) Technology transition 2) Reduce production and imports and 3) Management and Handling practices. We share more details on items 1 & 2, and in later sections we address pending items and dates here.

  • EPA will not expand 608. – this is big news, since this means the EPA will launch a new section to the CAA. This means that techs will need new licensing/testing.
  • New training will reduce mistakes and confusion in updates to regulations, but require new training
  • EPA’s plan to move beyond the 50 LB threshold for equipment.

 
EPA Administrator Cindy Newberg Quotes
 
The EPA said to expect to see proposed regulatory changes related to the AIM updates to be publisihed by or before September 21, 2023 (less than 90 days).
 

GWP Technology Transition

“Technology Transitions,” subsection (i) of the AIM Act provides authority for EPA to promulgate rules restricting the use of HFCs in sectors or sub-sectors where they are used. EPA can either initiate a rule-making on its own accord, or a person may petition EPA to promulgate a rule to restrict the use of HFCs in certain sectors or sub-sectors.

EPA has received 18 petitions so far and they have only denied 2 and granted 16, but granted does not mean the EPA has accepted them as law, only that they agree to review them through the transition from high GWP refrigerants to low GWP refrigerants.

The petition process was introduced in the AIM Act by congress in order to help EPA receiver input from the marketplace. Congress had previously restricted EPA from engaging consultants when making decisions and creating rulings, so that bias was not introduced to the EPA rule making process.

Petition topics ranged from Re-establishing SNAP 20 & 21, limiting use of small canisters, lowering the. GWP of allowable refrigerants, restricting use of HFCs in certain applications, a reference to Energy Star Labelling, motor vehicle restrictions, and then wording from foam agents and hard board insulation production.

The petitioners include, DuPont, Environmental Investigation Agency (EIA), American Chemistry Council’s Center for the Polyurethanes Industry (CPI), International Institute of Ammonia Refrigeration (IIAR), Institute for Governance & Sustainable Development (IGSD), Association of Home Appliance Manufacturers (AHAM), Air-Conditioning, Heating, and Refrigeration Institute (AHRI) (this group has been very vocal), California Air Resources Board (CARB), Gebauer Company, A.V.W Inc, National Aerosol Association (NAA) and the Household & Commercial Products Association (HCPA).
 

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Cylinder handling and gas reporting

Cylinders are the medium we transport refrigerant to/from work sites. As such tracking cylinders is a crucial element in the supply chain integrity issue. The agency caps maximum annual HFC production and consumption at a percentage of previous years baselines — for instance, sixty percent in 2023. Id. § 7675(e)(2)(B), (C). Over time, the caps come down, eventually reaching fifteen percent in 2036. Id. 

To ensure that production and consumption stay under the respective caps, the Act puts in place a system of “allowances.” Id. § 7675(e)(2)(D). An allowance is like a license; without one, “no person shall . . . produce” or “consume” HFCs. Id. § 7675(e)(2)(A).

Allowances are distributed to HFC users by the EPA. Once allocated, the HFC refrigerants users can buy and sell allowances from one another to adjust their production or consumption capacity. Id. § 7675(g).

Tracking who buys what from whom and where it went or originated are key to EPA ensuring that no illegal materials enter the supply chain.

Late last year, when EPA issued its final Phase-down Rule, implementing the cap-and-trade program. 40 C.F.R. pt. 84. Among other things, the Phase down Rule calculates the annual production and consumption caps, explained how the agency planned to distribute allowances, and establish reporting and auditing requirements for HFC consumers.  Cylinder tracking and reporting were one of the key tools EPA intended to use to manage this process.

Three trade associations, HARDI, Air Conditioning Contractors of America (ACCA), and Plumbing-Heating-Cooling Contractors (PHCC), along with US cylinder manufacturer Worthington Industries, filed petitions against EPA claiming that the non-refillable cylinder ban and the requirement to track individual cylinder provisions exceeded its authority granted by the Act. By a 2-1 margin the court agreed with the petitioners, bit not without a few highlights:

  1. The court did find that the EPA had authority to manage any regulated blend of material containing HFCs
    • “HFC in a blend of other chemicals is like a blue M&M in a bag of red M&Ms. The blue one does not stop being blue just because it is tossed in with a bunch of red ones. In the same way, an HFC mixed with other chemicals does not stop being a regulated substance under the Act.7675(k)(1)(A), empowers EPA to “promulgate such regulations as are necessary to carry out the functions of the Administrator.
  2. Although the justices did not agree on the specific authority granted EPA, related to cylinders, the court did agree that this was not a “major question” like WV vs EPA where the court fenced the EPA’s ability to regulate carbon emissions in the power sector so the court essentially accepted the EPAs domain responsibility.
  3. The non-delegation issue was dismissed for failure to raise the issue with the EPA. Essentially the court accepted the concept of clear statement.

So the court agrees that the EPA has authority to manage, limit, and require reporting. And in some specific circumstance they have authority to control the packaging, as long as it does not put undue financial burden in the market.

What to Watch: Banning disposables would have quickly reduced illegal trade since these cylinders are hard to track provenance. But the EPA has been given a gift by the court, and this is the first case law item to firmly establish EPAs control and domain responsibility. So expect more tracking via different means.

The Dissenting justice stated: To the extent EPA’s compliance authority might be viewed as “broad,” Maj. Op. 14, that reflects Congress’ deliberate choice to leave specific compliance measures to EPA’s discretion. “Congress knows to speak in plain terms when it wishes to circumscribe, and in capacious terms when it wishes to enlarge, agency discretion.” City of Arlington v. FCC, 569 U.S. 290, 296 (2013). 
 

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HFC Allocation

The American Innovation and Manufacturing (AIM) Act authorizes EPA to phase down production and consumption of Hydrofluorocarbons (HFCs) in the United States by 85 percent by 2036. This phase down is consistent with the Kigali Amendment to the MP, a global agreement to phase down HFCs. To accomplish this, EPA has established a methodology for allocating HFC production and consumption allowances. The phase down will happen in 5 phases over 15 years.
 
HFC Phasedown Schedule and Consumption and Production Allowance Caps
 
Although records are poorly kept for the total amount of refrigerant consumed, the market grows by approximately 6-8% annually and with a baseline in 125 Million pounds in 1995, it is widely assumed that approximately 680 Million LBS of refrigerant were used annually in 2021.

Approximately 80 Million lb. are used in new equipment and the balance or approximately 600 Million lb. were used for leaks and other uses such as bear and pepper spray and specialty items like insulations, foams, medical devices and electronics manufacturing.

Specialty uses account for less than 15% of market and so the total reduction of 10% would still apply to the entire market, reducing refrigerant in the market to 612 Million Lb. with approximately 80 Million going to new installs and 532 Million available for leaks, servicing etc.

In 2024 the total amount available will drop to 408 Million LB. however 80 Million is still targeted for new installs since new refrigerants are not yet on the market to replace the old refrigerants (this author has ordered a cylinder of 454B and I have had to wait many months without a delivery date in sight).

This would leave between 328-360 Million pounds for servicing – a massive reduction from the 2021 market supply availability. However as I will document later, the EPA has also correspondingly disallowed the use of these high GWP refrigerants for install after 2025.
 
Phasedown Schedule
 
So what should you be doing?

  1. Figure out your exposure, do an inventory and ask your service providers for some help in better understanding your exposure to this shortfall.
  2. Careful installing obsolete equipment. On average we replace about 5% of all the HVAC/R equipment in our installed base annually. Some stretch this out a but rarely over 30 years. Also we tend to grow our needs and install newer service to expand a space. Everything you install with 410A (most common refrigerant) is technically obsolete and in 18 months you wont be able to install any 410A new systems at all. But the good news is that 454B is similar to 410A and it looks like it will be an easy transition, but questions still remain. Talk to your vendors and ask them for a plan.
  3. Stop letting gas leaks happen and just classifying it as a cost of business – this type of thinking is the reason we are still leaking this much refrigerant. Track it, set profiles and triggers and be ready to act to replace coils, and invest in better response management.

Our clients typically see leak rates drop dramatically once they start tracking and they shift from break fix to preventative models of proactively addressing issue before they become leaks.
 

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GreenChill

Launched in 2007, GreenChill is an EPA voluntary partnership program that works cooperatively with the food retail industry to reduce refrigerant emissions and decrease their impact on the ozone layer and climate related risks due to change. EPA is working closely with their partners to revamp the program to support this best in class group of companies so they can pioneer solutions for the rest of us, here is what to expect:

  • Disciplined and structured evolution of GreenChill
  • A future free of Fluorine refrigerants
  • Creating a network of Best-in-Class Friends of the EPA
  • Focus on environmental protection and sustainability
  • New guidelines: increased accountability, transparency, and continuous improvement
  • Revamp the renewal process
  • Upgrade of their reporting to include more weighted values reflective of climate related disclosures
  • Aligning with EPA’s vision to reduce greenhouse gas emissions and protect the ozone layer.

it is important to note that team members from these forward-thinking companies can offer guidance and support to other companies and the wider industry, facilitating their own transitions. By leveraging their knowledge and sharing lessons learned, these pioneers are playing a critical leadership role, in accelerating industry and business-wide change and shaping the future of sustainability beyond the refrigeration industry.
 

SNAP – Significant new Alternative program.

The Significant New Alternatives Policy (SNAP) program, run by the Environmental Protection Agency (EPA), is a key tool that the EPA uses to regulate and control the use of certain substances in various equipment applications. By identifying and approving environmentally friendly alternatives, SNAP aims to reduce the demand for high-global warming potential substances like hydrofluorocarbons (HFCs) in refrigeration and air conditioning equipment, among others.

The most recent approved SNAP update was: Final Rule 25, although SNAP 26 is pending.
 

60335 – ASHRAE 15

Underwriters Laboratories (UL) Standard 60335 is a safety standard for household and similar electrical appliances. This standard provides detailed guidelines for the design and manufacture of appliances to ensure they are safe for consumer use. It covers a wide range of products, from refrigerators to air conditioners, and addresses potential hazards such as electrical, mechanical, thermal, fire, and radiation risks.

One of the product safety challenges is the transition risks associated with UL 60335-2-40 equipment is climate related risks to refrigerant handling and leakage. An integral component to mitigate this risk is a refrigerant leak detection system. Refrigerant leak detectors that sense loss of pressure are required for all systems in the occupied space exceeding a prescribed refrigerant charge limit, which typically consists of approximately 2.5-4 pounds of refrigerant per ton of cooling.
 
Servicing Refrigerant System Summary
 
UL 60335-2-40 is a test-based standard that will become mandatory in January of 2024. It applies to air conditioners, heat pumps, liquid chillers, hydronic fan coil units, hot water pumps, dehumidifiers, supplemental heaters, and equipment with flammable refrigerants. It is replacing safety standards UL 1995, UL 484, and UL 474 for HVAC systems and appliances, room air conditioners, and dehumidifiers respectively. The state of Washington has already accepted the upgrade to 60335 effective July 1, 2023.

60335 includes policies, practices and procedures on everything from install to recovery and placement, keep an eye out for your states adoption of this engineering and safety cornerstone.
 

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Inflation Reduction Act

The Inflation Reduction Act(IRA) , a groundbreaking legislation signed into law by President Biden, has sent ripples throughout various industries, including the Environmental Protection Agency (EPA) and the refrigerant industry. Its effects on the environment, financial well, job market, and energy costs are already being felt, but what does it mean for the world of refrigerants.
 

Summary of Exposure

    • The Inflation Reduction Act is an effort to tackle inflation, healthcare costs, taxation and climate change – it is in this box that refrigerant is impacted.
    • The refrigerant industry must invest in sustainable solutions presented by the Act in order to remain successful & reduce greenhouse gas emissions..
    • Impact to installation of obsolete equipment using R-410A.
  • Refrigerant Recovery and Reclaim/Destruction programs to be studied and funded
  • Certain End use can require reclaim only (why the cylinder issue may come back)
  • Presently reclaim is only processing about 2% of all refrigerants produced – this is not good enough.

There are billions of investment dollars in the IRA, somewhere between $4-13 Billion. Some investment is available for refrigerant reclaim, the intention is to enhance or bolster reclaim.
 

State Specific Regulations

Back in 2012, The U.S. Climate Alliance was formed. It is a bipartisan coalition of governors committed to reducing greenhouse gas emissions. This organization was formed largely in response to a perceived lack of sufficient federal action regarding climate change. Its mission is to coordinate and support climate policy initiatives and efforts at the state level.

Improved refrigerant management has been in development for 30 years and each successful generation of refrigerant provides new reasons to update the evolving regulatory landscape.

Due to the high global warming potential of many common refrigerants, states like California, Washington, and New Jersey have been at the forefront. They along with other states like Vermont, Maine, Massachusetts and others have been developing and implementing regulations to phase out the use of hydrofluorocarbons (HFCs) and other harmful refrigerants.

Policy creation at the state level often involves a more iterative process than at the federal level. States, which behave similarly to the European Union, tend to establish a policy frameworks that sets out specific and focused goals and mechanisms. These frameworks are then nurtured, tested, and debated over time before being fully deployed – in some cases many years. This approach allows for flexibility and adaptability in the face of new challenges or information.

Contrarily, federal policies are often designed to accommodate a broader, more diverse set of stakeholders. As such, federal policy decisions may aim for a more generalized solution that can be broadly applied but may lack the specificity to address local or regional nuances.

  • California’s Senate Bill 1383, passed in 2016, sets specific targets for reducing HFCs and other short-lived climate pollutants. The state has also established the Refrigerant Management Program and a registry to reduce emissions of GWP refrigerants from stationary sources.
  • In Washington state, the Climate Commitment Act (SB 5126) enacted in 2021, established a comprehensive program to cap and reduce greenhouse gases, including HFCs.
  • New Jersey, as part of its broader effort to achieve 100% clean energy by 2050, has introduced regulations to limit the use of HFCs, which includes reporting and promote the use of alternatives with lower GWP.

These state-level actions are creating a patchwork of regulations across the country. The U.S. Climate Alliance plays a crucial role in facilitating knowledge exchange between states and providing a forum for shared learning and collaborative policy development. This helps to ensure that efforts are not duplicated and that best practices can be shared and adopted more widely.

In essence, the collaboration between states and organizations like the U.S. Climate Alliance can lead to the creation of robust and effective policies that can be tailored to meet local and regional needs, while also contributing to the broader goal of mitigating climate change.

Be on the look out for key aspects of state level regulations including: Registry – State operated, Record-keeping – Refrigeration and Comfort Cooling, Reporting, Reclaim, limits on Refrigerant sales and GWP Limits.
 

 

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PFAS- TSCA

The Toxic Substances Control Act (TSCA) is a U.S. law, administered by the Environmental Protection Agency (EPA), that regulates the introduction of new or already existing chemicals.

PFAS are a group of man-made chemicals that have been in use since the mid-20th century. They are used in a wide range of products because of their resistance to heat, water, and oil. Due to their stability, PFAS persist in the environment for a long time, which has led to widespread environmental and human exposure. Certain PFAS can accumulate in the body and have been associated with adverse health effects, which is why they have come under scrutiny under the Toxic Substances Control Act (TSCA).

Refrigerants are part of the PFAS family of chemicals, and the The EU is already evaluating PFAS for further regulations.

Under the TSCA, the EPA can review and regulate the manufacturing process of Refrigerant X due to the use and release of PFAS. The EPA could require the manufacturer to limit or prevent the release of PFAS into the environment, or even to substitute the PFAS with a safer alternative. In this way, TSCA would affect the use of Refrigerant “X,” not directly because of the refrigerant itself, but due to the associated use of PFAS in its production process.
 

Shareholders impact via SEC and ESRS

 
The Refrigerant Problem
 
Voluntarily reporting environmental, social issues aka non-financial data, have been around for years, their lack of regulation has led to concerns about consistency, comparability, and reliability. Companies have had significant latitude in what they disclose, leading to wide variances and sometimes misleading information.

Recognizing the importance of this non-financial data to investors and stakeholders, both the Securities and Exchange Commission (SEC) in the U.S. and the European Union authorities are introducing new regulations. These aim to standardize ESG reporting, enhancing its transparency and usefulness.

The EU’s Corporate Sustainability Reporting Directive (CSRD) and the SEC’s own ESG reports and disclosure requirements represent efforts to bring order and consistency to these periodic reports and disclosures. Both are intended to ensure companies provide accurate, comparable, and reliable information about their ESG performance and impacts, thereby reducing the potential for misleading or ‘greenwashed’ claims.

This shift in regulatory focus reflects the growing understanding that non-financial data, such as a company’s environmental impact or social responsibility efforts, can be just as critical as financial data in assessing a company’s overall health, risk profile, and long-term environmental sustainability too.There are emerging protocols to enable Carbon Credits from refrigerant destruction – but they are hard to qualify.
 

Refrigerant Management: An Unavoidable Route to Enhanced Sustainability, Operational Maturity, and Profitability

 
The Refrigerant Problem Illustration
 
Environmental sustainability is top of mind for Managing and minimizing refrigerant usage can be complex given the diverse behaviors, advantages, performance, and risk profiles of various systems. However, proficient refrigerant management signals operational maturity. As managers delve into non-financial aspects of equipment operations, such as refrigerant usage and energy expenditure, they embark on a path of discovery and improvement.

Evidence shows this process can lead to enhanced energy efficiency,, improved environmental outcomes, and heightened profitability, albeit necessitating a shift from business as usual. This unavoidable transition, despite necessitating a shift from conventional practices, promises substantial returns: improved energy efficiency, minimized environmental impact, and bolstered bottom lines.

Navigating through the fragmented policy landscape and governmental silo effects — culminating in policy misalignment and documentation duplication — poses an ongoing challenge.. and at Trakref we recognize the challenges and are well positioned to be a partner in this process. As sustainability ascends corporate agendas, effectively managing refrigerants has become a non-negotiable aspect of business strategy, pivotal for our shared sustainable future.
 
 
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