OLYMPIA, Washington — The Washington State Building Code Council's adoption of an exception allowing certain equipment using A3 refrigerants marks a significant development in the state's refrigerant transition, despite opposition from HVACR industry associations and fire safety organizations.

The decision follows appeals from the HARDI and other industry groups urging state officials to reject the proposed code change over concerns about safety standards, product approvals, and installation requirements.

The amendment was considered as part of Washington's adoption of the 2024 International Mechanical Code. The council approved the change during its Oct. 30 meeting after revising portions of the proposed language. The vote was unanimous, and the revised provision is expected to take effect in May 2027.

The change addresses the use of A3 refrigerants, including R-290 (propane), which are classified as highly flammable under the refrigerant safety classification system. The amendment creates exceptions to existing restrictions on A3 refrigerants, establishing a pathway for certain equipment and applications to be approved under alternative standards and requirements.

HARDI raised concerns about the proposal before the council's decision. In an Oct. 15 statement, the association said it had joined the Washington Air Conditioning Contractors Association (WA ACCA), the Air-Conditioning, Heating, and Refrigeration Institute (AHRI), the Plumbing-Heating-Cooling Contractors—National Association (PHCC) and the Plumbing-Heating-Cooling Contractors Association of Washington (PHCC WA) in asking state leaders to reject the change.

The organizations argued that the proposal relied on international standards that do not fully align with the existing U.S. safety framework. They warned that allowing equipment using highly flammable A3 refrigerants in applications not addressed by established North American standards could create uncertainty for manufacturers, distributors, contractors, and code officials.

HARDI also questioned whether the industry has sufficient product approvals, installation requirements, and safety guidance in place to support the expanded use of A3 refrigerants. The association said Washington should allow its Refrigerant Transition Task Force to continue evaluating low- and ultra-low-global-warming-potential (GWP) refrigerants before adopting additional code exceptions. The task force includes representatives from HARDI and AHRI and is examining product availability, workforce training, safety considerations, and implementation timelines.

Fire safety organizations also raised objections during the code review. Written comments submitted to the State Building Code Council included feedback from the Washington State Association of Fire Marshals, the Snohomish County Fire Marshal, and other fire service representatives. During the Oct. 30 meeting, Karen Grove of the Washington State Association of Fire Marshals raised concerns about the lack of odorization in the refrigerants under consideration, noting that occupants and first responders may not be able to detect a leak by smell.

Other public comments addressed the potential safety implications of allowing A3 refrigerants in applications where existing U.S. standards do not provide clear installation guidance. The concerns centered on refrigerant charge limits, equipment applications, leak detection, and the ability of local authorities to evaluate installations.

Proponents of the amendment, meanwhile, argued that allowing limited installations could help generate field data needed to evaluate A3 refrigerants. Supporters Scott Spielman, P.E., and Andy Baker, P.E., cited the potential for the Northwest Energy Efficiency Alliance (NEEA) to conduct field research that could inform the state's transition to ultra-low-GWP refrigerants.

Spielman and Baker also argued that Washington should make independent decisions based on the state's economic interests, building codes and safety practices. They noted that national organizations headquartered outside Washington have members who have invested in HFO and A2L product lines and the existing UL certification framework. They suggested those investments could create a vested interest in delaying the adoption of natural refrigerants, a position they said does not reflect the views of Washington building owners, engineers and utilities.

In response to the concerns, the council revised portions of the amendment to limit certain installations to experimental applications and require approval from safety officials. However, the changes did not prevent the council from approving the exception.

The decision places Washington among the states addressing how A3 refrigerants may be used as the HVACR industry continues its transition toward lower-GWP refrigerants. The revised code language and its implementation will be important considerations for contractors, distributors, and manufacturers working in the state.