Washington’s New HFCs Refrigerant Regulations

Washington is the latest state to reduce greenhouse gas emissions by placing regulations on hydrofluorocarbons (HFCs refrigerant). Many states are beginning to understand the ozone depletion potential of HFCs and are creating regulations for environmental sustainability and decreasing companies’ environmental footprints. Most notably has been California, with many states following suit and creating regulations for HFC refrigerant and HFC refrigerant blends, including Colorado, Delaware, Maine, Massachusetts, New Jersey, New York, Rhode Island, Vermont, and Virginia. We will likely continue to see this trend develop, with Washington being the latest to tackle phasing out these gases.
These latest regulations are important to understand for refrigerant tracking and compliance. They also will come into play with corporate sustainability initiatives, including ESG reporting and answering sustainability audit questions for investors.

 

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HFCs Cause Greenhouse Gas Emissions

To understand where legislation around HFCs comes from, we first have to understand legislation surrounding HCFCs. Legislation such as the Clean Air Act under the EPA in the US and the Montreal Protocol internationally phased out HCFC refrigerants.

This led industrial sectors to look for alternative cooling solutions. Facility managers overseeing refrigerant and air conditioners often turned to HFC refrigerants as a substitute. They seemed to have less global warming impact and be better for the ozone layer.
 

HFCs are more impactful than carbon dioxide

However, as time and research have gone on, we’ve realized the high global warming potential of HFC refrigerants. They are one of the more potent greenhouse gases and are massively more impactful than other alternative refrigerants and other greenhouse gases. In fact, they are 15,000 times more impactful than carbon dioxide in global warming.

Despite this, they continue to be used in everything from commercial refrigeration to residential air conditioning. In fact, over the next 15 years, commercial refrigeration will account for 40% of end-uses of HFC refrigerants.

With this in mind, new legislation and agreements are arising both nationally and internationally. Internationally, the Kigali Amendment to the Montreal Protocol advocates for the gradual phasing out of HFC refrigerants. Nationally, there are some factions in the US lobbying President Biden and EPA Administrator Michael Regan to take the issue up through the Environmental Protection Agency. In the meantime, individual states are tackling HFCs’ impact on the climate crisis and encouraging the use of alternative refrigerants.
 
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HB 1050 Aims to Reduce Greenhouse Gas Emissions From HFCs

Washington’s HB 1050, passed last year, aims to fight the climate crisis and the use of HFC by working with Washington’s Department of Ecology.

Now that the bill has been passed, the Department of Ecology is beginning work on a number of initiatives that HB 1050 asks them to do regarding HFCs in air conditioners and refrigerant equipment. They are creating new global warming potential (GWP) thresholds to encourage companies to use lower GWP chemicals rather than extremely ozone-depleting ones. They are also developing a Refrigerant Management Plan for equipment with 50 pounds or more charge size. They’re creating legislative reports on end-of-life management and leak rate estimates, and are creating requirements for the handling of ozone-depleting substances that extend to HFCs. Finally, they are also creating new labeling options for SNAP-restricted products.
 

Optional Elements of HB 1050

In addition to the above efforts that HB 1050 requires the Department of Ecology to do, there are also some optional elements that may be considered to lessen HFCs’ environmental impact.

The Department of Ecology can create GWP thresholds for refrigeration and air conditioning equipment greater than 50 pounds. They can also create new labeling, reporting, and recordkeeping requirements, and adopt a process for exemptions and variances. Finally, they can establish fees to support the Refrigerant Management Program under the Air Quality Fee Rule.
 
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What HVAC/R Pros Need To Know

As the Department of Ecology has b

egun work, they’ve put together a list of prohibited substances.

What is most notable for the HVAC/R industry, service technicians, and our technologies is the ban on HFCs with a GWP of 150 or higher in equipment with 50 pounds or more of refrigerant. Refrigerant systems with less than 50 pounds will be exempt. If all goes according to plan, this will go into effect January 1, 2024 for the production of new equipment. Dates for retrofitted equipment and existing systems still need to be determined.

There is also a notable difference from California’s HFC rules. California went with the company weighted average for measuring HFC and refrigerants. While Washington’s direction is not entirely clear yet, they have decided that they have stated that they will go in a different direction.
 

Air Conditioning Changes

There will also be new rules surrounding air conditioning systems and units.

For air conditioners, HFCs with GWP of 750 or more will be prohibited. This will apply to room, wall, and window ACs, PTACS, PTHPs, portable ACs, and residential dehumidifiers.

Similar to the rules for refrigerants, these rules would go into effect on January 1, 2024. For other types of AC equipment, rules would go into effect in January 2025. Finally, for variable refrigerant flow or volume systems, rules would go into effect on January 2026.
 

New Disclosure and Recordkeeping Requirements

Washington has decided to stay consistent with California when it comes to new disclosure, labeling, and recordkeeping requirements.

For on-product labels, the information required will be refrigerant type, charge size, and date of manufacture. This will be required for refrigeration 50 pounds and greater.

For recordkeeping, records must be maintained for five years.
 

What We Want More Clarity On

While the Department of Ecology has laid out many commonly asked questions on their HFC ruling, there are still some questions that we hope will become more clear as time goes on.

First, we want more clear definitions of air conditioning versus refrigeration. We know that standards and technologies can change based on these definitions.

We also hope for more clarity on what will be happening with older systems. What will happen if an older system is using HFCs, but is within the GWP limit?
 
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Where We Go From Here

The final rule and implementation of these rules are a long way off. If all goes to according to plan, they won’t go into effect until January 24, 2024 – so we still have two more years.

The Department of Ecology’s next refrigeration and AC discussion is in March, and their Refrigerant Management Plan will take the most time, with rulemaking and information about it coming last. In the meantime, public comment is open and the department will continue to hold periodic stakeholder meetings.

Here at trakref, we’ll continue to keep an eye on HB 1050 and its effects. We plan to attend the department’s sessions and write more as information becomes available.

If you’re interested in talking more about these new policies and procedures, as well as the trend of phasing out HFCs in general, join us at our next open mic on Thursday, March 17.
 
And if you’re looking to work with a company that is always staying on top of the latest in compliance, get in touch with us today. We’re a software corporation that has been in the regulatory compliance software and environmental compliance calendar software space for years. As an environmental software provider, we make sure our refrigerant capabilities will keep you in compliance.