# Presentation: 062472

## Last Remaining Barriers

- Kristen Taddonio
- Chair, Global Barrier Removal Team
- 9 December 2008

## 2008 Choices

- Refrigerants:
- R744
- R1234yf
- Barriers based on:
- Flammability
- Acute toxicity
- Pressure

## We’ve Come a Long Way

- 2006: Global barrier removal team formed to remove global barriers to alternative refrigerants’ adoption
- 2006: US barriers identified at national level and in 18 states
- 2006: U.S. Department of Transportation waives pressure requirement for MAC accumulators, enabling R744 solution
- 2007: HFC152a Tiger Team releases report confirming secondary loop safety
- 2007: Many state barriers removed
- 2007: US National Highway Traffic and Safety Administration (NHTSA) confirms EPA SNAP listed alternative refrigerants acceptable under existing rules
- 2008: R744 safety tiger team formed
- 2008: US EPA SNAP lists HFC-152a as acceptable with use conditions

## Remaining Resolvable Regulatory Challenges

- Remaining Resolvable Regulatory Challenges

- R744:
- US venting prohibition
- EPA SNAP revision proposed and suspended
- EU limits on refrigerant in passenger cabin
- US State acceptance conditional on safety standards
- R1234yf:
- Resolve REACH for 1234yf
- EPA SNAP review in progress
- EU limits on refrigerant in passenger cabin
- Legislative vote pending in 7 states that would allow EPA SNAP listed flammable refrigerants

## CO2

- CO2

## Refrigerant Venting

- The Clean Air Act prohibits venting of all refrigerants, including R744.
- As of yet, no company has requested an exemption.
- US EPA Stratospheric Protection Division responsible authority.

## Significant New Alternatives Program (SNAP)

- US EPA Stratospheric Protection Division responsible authority (Drusilla Hufford and Karen Thundiyil)
- EPA initiated review of R152a and CO2, and proposed use requirements
- R152a final rule issued 2008
- Final rule did not include CO2

## EU Limits on Refrigerant in Occupied Space

- EU limits refrigerant that can be discharged into occupied space of passenger cabin
- Current systems do not meet requirements
- 134a
- R744
- Several European companies lobbying to change EN 378 to exempt MACS

## States Where CO2 Contingent on Safety

| Connecticut | Department of Motor Vehicles | CO2 would not be considered toxic within the framework of its use as a refrigerant in an automotive air conditioning systems.  In addition, CO2 would be allowed as a refrigerant provided that it is compatible with the components and substances within that system in accordance with SAE International standards and recommended practices. |
| --- | --- | --- |
| Idaho | State Police | CO2 and all other non-flammable refrigerant gases in SAE International J639 standard are and will continue to be authorized for use in Idaho. Idaho is in the process of updating its rules to the most current SAE J639 standard. |
| Indiana | Bureau of Motor Vehicles | Letter referred to the Department of Environment, which responded that CO2 would not be prohibited in MACs. |
| Kansas | Department of Transportation | So long as systems meet federal requirements, no barriers are foreseen. |
| Louisiana | Department of Public Safety | Referred to the Louisiana Department of Environmental Quality, which would not regulate CO2 as toxic.   |
| Maryland | Department of Transportation | Legislative change proposed to allow alternative refrigerants listed as acceptable by the EPA Significant New Alternatives Program, including CO2 |
| North Dakota | Department of Transportation | Letter was passed to the State Department of Health, which indicated it has no restrictions regarding the use of CO2 in motor vehicle air conditioners. |
| Oklahoma | Department of Public Safety | CO2 would not be prohibited for use in vehicle air conditioning systems. |
| Texas | Department of Public Safety | CO2 is not considered a toxic chemical under Texas Health and Safety Code, however, permission to use CO2 as a refrigerant is conditional on compliance with SAE International recommended practices and standards and demonstration of safety. |
| Utah | Department of Public Safety | Federal standards have been incorporated by reference as of March 2008; no barrier to CO2 so long as federal standards are met. |
| Virginia | Department of State Police | They defer to the Federal Health Hazard Definitions, 29 CFR 1910:1200, Appendix A (2005).  CO2 does not meet this definition of toxic.  However, the Code of Virginia requires that equipment meet or exceed the standards and specifications of SAE International, the American National Standards Institute (ANSI), or the Federal Department of Transportation.   |
| Washington | State Patrol & 
Department of Ecology | Washington State would not define carbon dioxide as toxic to humans. |

## R1234yf

## EPA Significant New Alternatives Program (SNAP)

- SNAP application submitted 2008
- Requires review in EPA office of Toxics
- R152a final rule issued 2008
- US EPA Stratospheric Protection Division responsible authority

## REACH & EU Limits on Refrigerant in Occupied Space

- REACH & EU Limits on Refrigerant in Occupied Space

- Does R1234yf met REACH acceptability?
- EU limits refrigerant that can be discharged into occupied space of passenger cabin – same challenge as for R744
- Several European companies lobbying to change EN 378 to exempt MACS

## States Where Flammability is an Issue

| Indiana | Indiana Code 9-19-2-1 | "[Motor vehicle] air conditioning equipment shall...not contain a refrigerant that is toxic or flammable...." |
| --- | --- | --- |
| Louisiana | Louisiana Statute 40:1846(f) | "Mechanical vapor compression refrigeration equipment which is used to cool the driver or passenger compartment of any motor vehicle...shall not contain any refrigerant which is toxic or flammable " |
| North Dakota | North Dakota Code 39-21-45 | "[Motor vehicle] air-conditioning equipment...may not contain any refrigerant which is toxic or flammable." |
| Oklahoma | 47 Oklahoma Statute 12-410 | "[Motor vehicle air conditioning equipment] shall not contain any refrigerant which is toxic or flammable ..." |
| Utah | Administrative Code 41-6-154.10 | "[Motor vehicle air conditioning equipment] shall not contain any refrigerant which is toxic or flammable ..." |
| Washington | Revised Code of Washington 46.37.470 | "[Motor vehicle air conditioning equipment] shall not contain any refrigerant which is toxic or flammable ..."
 |

## R-1234yf and HFC-152a: Other States

| Connecticut | Connecticut Statute § 14-106 | New Law!  Allows refrigerants listed by SNAP. |
| --- | --- | --- |
| Arizona | Revised Statutes § 41 2169  | Arizona law allows any refrigerant approved by U.S. EPA and permits non-hydrocarbon flammable refrigerants like HFC-152a and R-1234yf. |
| Iowa | Administrative Code 661—51.102(101)  | Barrier only exists for hydrocarbons. |
| Idaho | Idaho Statute 49-959 | Recently decided to use SAE J639  |
| Kansas | Kansas Statute  8-1747 | Department of Transportation to recommend new law |
| Montana | Montana Code Annotated § 61-9-426  | Alternatives automatically approved if approved by U.S. EPA |
| Maryland | Maryland Statute § 22-410 | Department of Environmental Quality proposing new law to allow refrigerants listed by SNAP. |
| Wisconsin | Administrative Code ATCP 139.04(11) | Barrier only exists for hydrocarbons. |
| Arkansas | Arkansas Statue 28.05.011 | Statute no longer exists |
| Texas | Transportation Code 547.610 | Department of Transportation to recommend new law |
| DC | R33 Change 51 738.1 | Law can no longer be found. |
| Virginia | Virginia Code 46.2-1088 | New Law! Allows refrigerants listed by SNAP.  Effective July 1, 2008. |
| Florida | Florida Statutes 325.222 & 325.223 | Does not apply to HFC-152a or HFC 1234yf. |

## EPA Contacts

- Barrier Removal Chair
- Kristen Taddonio
- taddonio.kristen@epa.gov +1-202-343-9234
- Mobile A/C Climate Protection Partnership
- Stephen O. Andersen, Director
- Andersen.Stephen@epa.gov + 1-202-343-9069
- SNAP Approval Or Refrigerant Venting
- Karen Thundiyil, Manager
- Thundiyil.Karen@epa.gov +1-202-343-9464
- Drusilla Hufford, Division Director
- Hufford.Drusilla@epa.gov + 1-202-343-9101

## Back – Up Slides

## U.S. Department of Transportation Waives Pressure Requirement

- “[Air conditioning systems] are an integral component of a motor vehicle and necessary for the operation of the vehicle”... “Based on the information you provided, the air conditioning system...is not subject to the Hazardous Materials Regulation.”
- –John A. Gale, Chief of Standards Development
- US Department of Transportation (DoT) Pipeline and Hazardous Materials Safety Administration
- 11 July 2006

## OSHA, EPA, & SAE Cooperation will Satisfy US Health and Safety Requirements

- SAE J-Standards in progress: “Recommended practice for servicing CO2, HFC-152a and R-1234yf mobile air conditioning systems”
- The SAE Standards will meet Occupational Safety and Health Administration (OSHA) requirements for training, personal protective equipment, safe handling, pressure relief devices, equipment inspection, worker exposure, ventilation, and refrigerant storage
***SAE standard are critical to compliance with OSHA Health & Safety Requirements***

## States that ban toxic refrigerants

| Connecticut | Connecticut Statute § 14-106 | "[Motor vehicle air conditioning equipment]...shall not contain any refrigerant which is toxic..." |
| --- | --- | --- |
| Idaho | Idaho Statute 49-959 | "[Motor vehicle] air-conditioning equipment...shall not contain any refrigerant which is toxic...." |
| Indiana | Indiana Code 9-19-2-1 | "[Motor vehicle] air conditioning equipment shall...not contain a refrigerant that is toxic...." |
| Kansas | Kansas Statute  8-1747 | "[Motor vehicle] air-conditioning equipment...shall not contain any refrigerant which is toxic..." |
| Louisiana | Louisiana Statute 40:1846(f) | "Mechanical vapor compression refrigeration equipment which is used to cool the driver or passenger compartment of any motor vehicle...shall not contain any refrigerant which is toxic..." |
| Maryland | Maryland Statute § 22-410 | "[Motor vehicle] air conditioning equipment...may not contain any refrigerant that is toxic..." |
| North Dakota | North Dakota Code 39-21-45 | "[Motor vehicle] air-conditioning equipment...may not contain any refrigerant which is toxic..." |
| Oklahoma | 47 Oklahoma Statute 12-410 | "[Motor vehicle air conditioning equipment] shall not contain any refrigerant which is toxic..." |
| Texas | Transportation Code 547.610 | "Vehicle air conditioning equipment may not contain refrigerant that is toxic..." |
| Utah | Administrative Code 41-6-154.10 | "[Motor vehicle air conditioning equipment] shall not contain any refrigerant which is toxic..." |
| Virginia | Virginia Code 46.2-1088 | "...No refrigerant used in [motor vehicle air conditioning units] shall be explosive, flammable, or toxic." |
| Washington | Revised Code of Washington 46.37.470 | "[Motor vehicle air conditioning equipment] shall not contain any refrigerant which is toxic..." |

## CO2 State Barrier Removal

- Investigate definitions of toxic in State
- When no definition exists, identify state authority responsible for implementing the statute
- Inform state authorities of situation, ask if CO2 would be allowed in that state
- Provide information on system safety strategies and pending SAE standards