EPA Provides Answers to R-22 Questions

How will these rules will affect HVACR businesses?

A new year usually brings big changes, and that will be especially true for the people who make, sell and service air-conditioning and refrigeration equipment – beginning Jan. 1, 2010. On that day, two important new federal rules take effect. Their main purpose is to further sharply restrict the use of substances that harm the earth’s protective ozone layer and contribute to climate change. The restrictions are required both by an international treaty and by federal law to combat health hazards caused by excessive exposure to ultraviolet radiation, namely skin cancer, cataracts, and weakened immune systems.

The targeted chemicals are hydrochlorofluorocarbons primarily used as refrigerants. They include HCFC-22 — better known as R-22 — as well as other specific HCFCs: HCFC-142b; HCFC-123; HCFC-124; HCFC-225ca; and HCFC-225cb. These chemicals deplete the stratospheric ozone layer, and are being phased out under the Montreal Protocol, an international treaty. By cutting the production and import of these chemicals and limiting how they can be used, the rules will help the ozone layer heal faster. They also provide significant climate benefits. Over the period from 2010 to 2014, the rules provide about the same climate benefit as eliminating the annual CO2 emissions from the electricity use of more than 102 million homes. While many people in the industry have heard about upcoming changes, they and others still may have specific questions about how the rules will affect their businesses.

(Ed. note: To read ContractingBusiness.com's exclusive R-22 refrigerant roundtable article, visit http://contractingbusiness.com/refrigeration/r22-phaseout-ready-1109/)

Here are answers to some expected questions, provided by the rules’ authors in the Stratospheric Protection Division of the U.S. Environmental Protection Agency. Division staffers are eager to provide answers to any additional questions people may have. Please write to: [email protected] with other questions.

What do the rules do?
The first rule, titled “Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export,” 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 second, complementary rule, titled “Ban on Sale or Distribution of Pre-Charged Appliances,” 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. This rulemaking further protects stratospheric ozone by decreasing demand for newly-produced HCFC equipment in the United States.

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. This follows our stepwise reductions for phasing out ozone-depleting substances. 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 January 1, 2010, and December 31, 2011, if the components have been specified for use at that project under a building permit or contract dated before January 1, 2010. Also, under the allocation rule, HCFC-22 produced prior to January 1, 2010, may be used until January 1, 2015, for the manufacture of thermostatic expansion valves (TXVs) and medical equipment.

What alternatives to R-22 are acceptable and available?
EPA has found acceptable a number of alternatives to R-22 that do not deplete the ozone layer. Most are hydrofluorocarbons and include R-134a, R-404A, R-407C and R-410A. In the U.S., 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. (See: www.epa.gov/ozone/snap/lists.)

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, technicians have a few options when using recovered refrigerants. First, 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 also 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. Lastly, the technician 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 PCBs. (See: www.epa.gov/ozone/partnerships/rad.)

Should technicians discuss the HCFC phase-out with customers?
Yes, technicians are an important source of information for consumers. Technicians should explain to their customers 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. (See: www.epa.gov/ozone/title6/phaseout/hcfcfaqs.html.)

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. A list of acceptable refrigerant substitutes is available at: www.epa.gov/ozone/snap/refrigerants. 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?
Depletion of the ozone layer results in more UV radiation reaching the Earth's surface. Overexposure to UV radiation can lead to serious health effects, such as skin cancer, cataracts, and immune suppression. While the ozone layer is under repair, it is even more essential to practice sun-safe behavior, follow the action steps in EPA’s SunWise program, and check the UV Index to better plan outdoor activities. Children are most susceptible to the health impacts of UV radiation. With more than 1 million people diagnosed with skin cancer in the U.S. each year, teaching children to be safe in the sun is an important step toward decreasing the incidence of this preventable disease. Since sun damage is cumulative and protection is best if started early, EPA’s SunWise Program works to improve children’s knowledge, attitudes, and behavior.

To learn more about sun safety, visit www.epa.gov/sunwise. To learn more about ozone depletion, visit: http://www.epa.gov/Ozone/strathome.html. 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 U.S. 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.


Staci Gatica, is rule co-author at EPA’s Stratospheric Protection Division. She can be reached by email at: [email protected]
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