• EPA's Top 10 Questions Related to Alternative Refrigerants

    Dec. 15, 2010
    Whether you're a nationwide distribution chain or a one-man service shop, you should take the time to determine how well an alternative will work and whether it may pose any problems for your customers or liability for you.

    Many new alternative refrigerants marketed for use in the motor vehicle and stationary/commercial sectors are being touted by their manufacturers and distributors. Whether you're a nationwide distribution chain or a one-man service shop, you should take the time to determine how well an alternative will work and whether it may pose any problems for your customers or liability for you. Consider asking your supplier, whether it is the refrigerant manufacturer or a distributor, the following questions.

    Is the refrigerant on the EPA's SNAP (Significant New Alternatives Policy) Program list of acceptable substitutes, and therefore legal to use as a substitute for a CFC of HCFC refrigerant? If so, are there any restrictions on how the refrigerant can be used? EPA's SNAP program determines what risks alternatives to CFC or HCFC refrigerants pose to human health and the environment. EPA evaluates the alternative refrigerant's ozone-depleting potential, global warming potential, flammability, and toxicity. The SNAP evaluation, however, does not determine whether the alternative will provide adequate performance or will be compatible with the components of an A/C or refrigeration system. Download a version of the current list of refrigerants accepted under SNAP. See also the list of approved refrigerants by sector. EPA may place conditions or restrictions on how an alternative can be used. For example, using a motor vehicle A/C refrigerant accepted under SNAP as a CFC-12 substitute requires, among other things, the use of a new label and new fittings unique to the alternative, and the CFC-12 must first be removed from the system. Note that there is no do-it-yourself (DIY) exemption from SNAP requirements. Both service technicians and DIYers who use alternatives found unacceptable under SNAP or ignore use conditions have violated the Clean Air Act. A list of all refrigerants reviewed so far for motor vehicle air conditioning is available here. Some refrigerants that SNAP has found acceptable as substitutes for CFCs are not acceptable as substitutes for HCFCs.

    How much will the alternative refrigerant cost? Many manufacturers and distributors of alternative refrigerants may point out how much less expensive their product is than the refrigerant it is substituting for. Potential purchasers, however, should compare the cost of the product with the cost of other substitutes. For example, if you are considering purchasing a blend refrigerant that substitutes for CFC-12, consider its cost relative to the cost of HFC-134a, which is generally considerably less expensive than blend refrigerants.

    What does the system manufacturer have to say about this refrigerant and whether it is compatible with system components? Will using a particular refrigerant void any warranties on the system the refrigerant is used in? Because of the wide range in equipment types and designs, EPA does not issue retrofit procedures. The best source of information on how a given substitute will perform in a system is the manufacturer of the system and its components. Note that lab data have indicated that HCFC-22 refrigerant is not compatible with XH-5 or XH-7 desiccant, and that HCFC-22 can also damage NBR nitrile and HNBR rubber hoses and O-rings. If you are considering using a blend refrigerant that includes HCFC-22 as a major component, then you should ask about these issues before you purchase the refrigerant. In addition to questions about the alternative's performance in a particular end use, you should determine whether charging a system with a new refrigerant will void any warranty. For example, many manufacturers of components for motor vehicle air conditioners have stated that their warranties will be voided if any refrigerant other than R-12 or R-134a is charged into the system.

    What recycling and/or reclamation standards apply to the refrigerant? Can the refrigerant be recycled or reclaimed to those standards? The Clean Air Act requires that EPA establish standards for the recovery, on-site recycling and off-site reclamation of refrigerants, including alternatives accepted under SNAP. The Agency's standards for recovering and recycling refrigerants in motor vehicles are generally based on Society of Automotive Engineers (SAE) standards. EPA's standards for recovering and recycling refrigerants from stationary/commercial A/C and refrigeration systems are generally based on AHRI (Air-Conditioning, Heating and Refrigeration Institute) standards. If these standards have not been published by EPA for a particular alternative, then they may be under development by EPA, SAE, or AHRI. Check to make sure that the refrigerant manufacturer intends to work with these organizations to develop uniform methods for extraction, recycling and reclamation.

    What equipment must be used with the alternative refrigerant? Equipment that is used by a facility to service R-12 or R-134a A/C systems may not be used to charge, recover, or recharge a blend refrigerant. Technicians must make certain that the equipment has been certified for use with the alternative refrigerant.

    Has the alternative refrigerant been evaluated by AHRI (the Air-Conditioning, Heating, and Refrigeration Institute)? If an alternative is to be reclaimed, will it be reclaimed to AHRI's 700 standard? If not, then how will the purity of the reclaimed alternative refrigerant be assured? AHRI, an A/C and refrigeration manufacturers' trade association, develops standards for the industry. AHRI's 700 standard specifies acceptable levels of refrigerant purity for fluorocarbon refrigerants including R-12, R-22, R-134a, R-500, and R-502 and for certain refrigerant blends (e.g. R-410A, R-407C, and R-404A). The purpose of the AHRI 700 standard is to enable users to evaluate and accept or reject refrigerants, whether virgin, reclaimed, or repackaged.

    Is the alternative refrigerant flammable? Both ASHRAE (the American Society of Heating, Refrigerating and Air-Conditioning Engineers) and EPA evaluate refrigerant flammability. As part of its SNAP review, EPA requires that a new refrigerant be tested according to the American Society of Testing Materials (ASTM) E-681 testing method. E-681 is used to determine the concentrations in air at which a substance is flammable, at normal atmospheric pressure. In addition to testing the refrigerant itself, if a blend contains a flammable component, EPA requires fractionation testing to ensure that the composition does not change and become flammable. EPA currently prohibits the use of flammable CFC-12 substitutes in motor vehicle A/Cs, except for HFC-152a. If a substitute is flammable, EPA requires the manufacturer to send us a comprehensive risk assessment for each proposed end-use. This risk assessment estimates the likelihood of fire and the potential results if a fire were to occur, in addition to suggesting measures to mitigate this risk. State governments, fire marshals, building code organizations, and other local authorities may have issued prohibitions or other regulations related to flammable refrigerants. Check with them before buying, selling, or using a flammable refrigerant.

    Is the refrigerant readily and widely available? If a service technician charges a system with an alternative refrigerant that later becomes unavailable, or that is not available nationwide, then at the next servicing, the system may have to be retrofitted to another appropriate substitute.

    What is my liability if I sell an alternative not yet listed as acceptable by EPA or if I put it in a customer's system? Under EPA regulations, a refrigerant manufacturer must submit information on a new refrigerant for SNAP review at least 90 days before marketing the product. This 90-day period is required by Section 612 of the Clean Air Act, but the Act did not prohibit sale and use of that refrigerant after the 90-day period. Thus, if the Agency is still engaged in its review when the 90 days elapses, the product can be sold and used, even though it is not “EPA acceptable.” However, EPA may later determine that the product is unacceptable under SNAP. It makes sense, then, to determine whether SNAP review is complete -- if not, it may be only temporarily legal to use the alternative refrigerant. If you purchased the refrigerant during the SNAP review, and EPA later determines that it is unacceptable, you may be stuck with a large inventory of refrigerant no one can legally use.

    Are any alternative refrigerants more environmentally beneficial than others? HFC-134a does not contain chlorine and therefore does not contribute to ozone depletion, although like other HFCs, it contributes to global warming. HCFC-22 and all other HCFCs contribute to both ozone depletion and global warming.

    EPA has recently reviewed a number of alternative refrigerants that are ozone safe and have a low global warming potential (e.g. HFC-1234yf in motor vehicle air-conditioning, CO2 in cold storage warehouses and retail food refrigeration, and hydrocarbons in household and commercial refrigerators and freezers. VISIT http://www.epa.gov/ozone/strathome.html