Proposed EPA SNAP Rule Expands Flammable Refrigerant Listings

Earlier this year, in April, there was a new development with the EPA Significant New Alternatives Policy (SNAP) Program when a HFC court decision unfolded that clarified the latest with SNAP Rule 20.

Well, now, there’s another new development with the EPA SNAP Program. This time, it’s with a different issue—not Rule 20—but rather a proposed new rule, SNAP Rule 23. Needless to say, it’s never a dull moment in the world of refrigerant compliance, refrigerant tracking, and environmental sustainability. 

This post covers the most important elements of the new proposed rulemaking SNAP Rule 23. It’s important to understand this for your compliance, corporate sustainability initiatives, ESG reporting, and answering sustainability audit questions.
 

Proposed Rule Lists Numerous Substitutes As Acceptable With Use Restrictions in Refrigeration and Air-Conditioning Sector

On June 12, 2020, the EPA SNAP Program published a proposed rulemaking, Rule 23, that expands the list of acceptable refrigerants in certain end-uses subject to use restrictions.

In essence, the Rule makes proposed listings subject to use restrictions in these two specific end-uses:

1) retail food refrigeration—medium-temperature stand-alone units for new equipment; and

2) residential and light commercial air conditioning (AC) and heat pumps for new equipment. 

If you aren’t already aware, the EPA SNAP Program has five types of listing decisions, including:

• Acceptable
• Acceptable subject to use conditions*
• Acceptable subject to narrowed use limits*
• Unacceptable
• Pending

*The “acceptable subject to use conditions” and “acceptable subject to narrowed use limits” decisions both fall under what’s considered “use restrictions.” The SNAP Rule 23 proposed listings in the end-uses 1) and 2), addressed above, are subject to such use restrictions, which we will look at more closely in the sections below. 
 
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Retail Food Refrigeration—Medium-Temperature Stand-Alone Units

First, the proposed rulemaking lists R-448A, R-449, and R-449B as acceptable, subject to narrowed use limits, in new equipment only for new medium-temperature stand-alone units in retail food refrigeration.

If you are wondering what “narrowed use limits” means, the proposed rule provides such clarification.

In fact, under the narrowed use limits, users, including manufactures,  would have to “ascertain that other alternatives are not technically feasible” due to “the concern about designing equipment capable of complying with ADA requirements.”

It should be noted that the EPA previously listed R-448A, R-449A, and R-449B as acceptable in several other retail food refrigeration end-use categories. See Notice 30, 32, 33, 34, and 35 respectively here.

Let’s move on now to other proposed listings in the residential and light commercial air conditioning and heat pumps end-use that also have use restrictions. 
 

Residential and Light Commercial Air Conditioning and Heat Pumps

The proposed listings in this sector would expand the mildly flammable refrigerants, or A2Ls, acceptability under the EPA SNAP Program.

Five refrigerant blends, including R-452B, R-454A, R-454B, R-454C, and R-457A, along with R-32 would be listed under this proposed rulemaking.
 

Mildly Flammable Refrigerants Listed

More specifically, R-452B, R-454A, R-454B, R-454C, and R-457A would be listed as acceptable subject to use conditions in new residential and light commercial air-conditioning (AC) and heat pumps for both self-contained and split systems. 

R-32 would be listed as acceptable subject to use conditions in residential and light commercial air conditioning and heat pumps for split systems and “for specific types of self-contained systems that are part of the residential and light commercial air conditioning and heat pump end-use but for which R-32 has not been previously listed.”

(R-32 was previously listed as acceptable, subject to use conditions in self-contained room air conditioners in Rule 19. This proposed rule does not impact Rule 19.) 
 

Use Conditions for Proposed Flammable Refrigerants Listings

These A2L substitute refrigerants that would be listed as acceptable in these end-uses, are subject to use conditions, which include the following: 

1) Meet all requirements in UL Standard 60335-2-40;

2) Applies to new equipment only;

3) Display warning labels on the equipment, such as on the equipment packaging; on the nameplate; and/or outside of the product; and

4) Have distinguishing red color-coded hoses and piping to indicate use of a flammable refrigerant.

For the complete information in regards to these proposed listings and use conditions, please see the Rule in its entirety here. 

The EPA is accepting comments on this proposed rule and such comments must be received by July 27, 2020. 

What do you think of this proposed rulemaking? Let us know in the comments below

Be sure to stay tuned here on the Trakref blog, as we will provide an update if and when this proposed rule is finalized. Thanks for reading.
 
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