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The US EPA SNAP and the Courts
International treaties like the Kigali amendment, even if
approved by the US representatives, are not US law.
Treaties need to rst be ratied by the Senate and then
codied into laws before they can be enforced. The original
portion of the Montreal Protocol was incorporated into the
Clean Air Act (CAA) and enforced by the EPA. However, the
Kigali Amendment has not been ratied or made into a law,
therefore, regardless of whether the treaty has gone into
force or not, it is not binding in the US.
The EPA has a program in place called the Signicant
New Alternatives Policy (SNAP) created under the CAA
and used to regulate the use of refrigerants from a safety
perspective (not performance). SNAP allows the use of
specic refrigerants only in specic types of equipment.
Only matched pairs are legal to use. For example, the use
of R-410A in residential A/C is a SNAP approved match;
however, R-410A in residential refrigeration is not and it
would be illegal to use it that way. For a refrigerant to be
used in a specic application, a petition has to be made to
the EPA, including required supporting information, and the
EPA rules whether the match is approved.
In 2014, the EPA began unilaterally delisting refrigerant/
equipment applications. The agency was trying to take a
proactive role in the regulation of HFCs to reduce their use
in the US. A summary of the changes to the program is
contained in SNAP Rules 20 and 21. One particular case of
the many changes was the delisting of R-134a and R-410A
in chiller applications after 2024, but it did not affect the use
of R-410A in residential A/C at all.
Two large refrigerant manufacturers, Mexichem and Arkema,
sued the EPA in federal court, claiming that it had exceeded
its authority granted by the CAA. The claim was that the CAA
could only be used to regulate ozone depleting substances
but its mandate did not extend to regulation due to global
warming concerns. The EPA lost the original ruling and a
subsequent appeal. The end result is that Rule 20 has been
vacated and Rule 21 is on hold in the Washington DC circuit
courts pending a nal ruling.
The California Air Resources Board (CARB) supported the
EPA during its court battles and pledged to follow the Kigali
Amendment reductions and to adopt SNAP Rules 20 and
21 regardless of the federal court rulings. The California
legislature has passed bill SB1013 called the California
Cooling Act. It adopts all of the provisions of the SNAP rules
and sets additional limits for stationary refrigeration and
A/C equipment based on charge size and refrigerant global
warming potential (GWP) values. Other states such as New
York, Maryland and Connecticut have made similar supporting
statements, but have not issued any specic rules yet.
A New Generation of Refrigerants: HFOs
In order to cover the gap that a reduction in the availability
of HFCs would create, the HVAC industry has developed a
new generation of refrigerants called Hydro-Fluoro-Olens
(HFO), such as R-1233zd(E) and R-1234ze(E) for example.
They are very similar to HFC refrigerants in their molecular
make-up and share the fact that they also have no Chlorine
atoms that could cause ozone depletion. However, they have
a big difference with HFCs: HFOs have a double bond that
makes the molecule more unstable and drastically reduces
its atmospheric lifetime. It may seem counterintuitive to
use refrigerants that are more unstable; however, that is
not an issue when they are in containment in storage tanks
or in the system itself. The instability occurs only when
the refrigerant is exposed to sunlight if it leaks. Having a
lifetime that is measured in days instead of years means
that the potential effects of these refrigerants as greenhouse
gases is drastically reduced by orders of magnitude. Some
of the GWP values of these new refrigerants are referred to
as “ultra-low” and their GWP in many cases is in the single
digits. However, other HFO refrigerant GWP values may be
much higher.
Many new low GWP refrigerants now coming into the
market are either pure HFOs or blends of HFOs and HFCs.
By mixing selective refrigerants in a blend, it is possible to
achieve certain properties that a single refrigerant could not
achieve on its own. It is also important to note that by having
HFCs as components of these long term refrigerant solutions
shows HFCs are NOT being eliminated and are part of the
global future solution to global warming.
Refrigerant Safety Classications
In order to discuss some of the more notable low GWP
refrigerants in the market, we will review safety classications
as set by ASHRAE’s Standard 34. (See Figure 5.)
The standard evaluates each refrigerant’s ammability
and toxicity and gives it a class referenced as a letter and
number combination. For toxicity it has two classes A: lower
toxicity and B: higher toxicity. The toxicity class is based on
the refrigerant’s Occupational Exposure Limit (OEL) and it
assigns refrigerants with an OEL of 400 ppm or greater
an A and for less than 400 ppm a B. For ammability, the
standard uses data based on the burning velocity (BV),
heat of combustion (HOC) and lower ammability limits
(LFL) of each refrigerant. A class of 1 would be the lowest
ammability and a 3 would be the highest. In recent years,
the second class was broken into 2L and 2. A rating of
2L indicates that while the refrigerant is still considered
ammable, its ammability is much lower than that of a
class 2 or 3.