Ms. Drusilla Hufford

Director, Stratospheric Protection Division

Office of Atmospheric Protection

USEPA Headquarters

William Jefferson Clinton Building 

1200 Pennsylvania Avenue, N. W. 

Mail Code: 6205T 

Washington, DC 20460

February 8, 2016

BY EMAIL AND LETTER

Dear Ms. Hufford:

The Association of Home Appliance Manufacturers (AHAM) would like to offer the following input to 

the Environmental Protection Agency (EPA) as it develops the next round of listing and change of status 

updates under the Significant New Alternatives Policy (SNAP) program. In particular, we are pleased to 

inform EPA that the U.S. domestic refrigeration industry has established a goal of phasing down the use 

of hydrofluorocarbon (HFC) refrigerants in refrigerators and freezers, and we call on EPA, the Consumer 

Product Safety Commission (CPSC), Underwriters Laboratories (UL) and other key players to work with 

us to eliminate barriers to this goal. For the reasons outlined below, we urge EPA not to propose a 

transition date for these products any earlier than 2024. 

Separately, we urge EPA to refrain from imposing transition dates in the next SNAP rule for ending the 

use of HFC refrigerants in room air conditioners (RACs), portable air conditioners (PACs) and 

dehumidifiers (DHs) (collectively, air conditioning home appliances)—or commercial ice makers, since 

this end use includes stand-alone icemakers designed for household use—given the absence of proven, 

viable alternatives and/or safety standards that permit the use of flammable refrigerants in sufficient 

quantities for these products. Even more time is needed for transition of these products than for 

refrigerators and freezers. No rational SNAP date can be set at this time for these products. If EPA 

commits to work with us, however, it not only could possibly accelerate the transition but would result in 

a deeper real-time understanding of the—in this case global—issues that are barriers to transition.

AHAM represents manufacturers of major, portable and floor care home appliances, and suppliers to the 

industry. AHAM’s more than 150 members employ tens of thousands of people in the U.S. and produce 

more than 95% of the household appliances shipped for sale within the U.S. The factory shipment value 

of these products is more than $30 billion annually. The home appliance industry, through its products 

and innovation, is essential to U.S. consumer lifestyle, health, safety and convenience. Through its 

technology, employees and productivity, the industry contributes significantly to U.S. jobs and economic 

security. Home appliances also are a success story in terms of energy efficiency and environmental 

protection. New appliances often represent the most effective choice a consumer can make to reduce 
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home energy use and costs, and no SNAP date can be rationally set at this time. If EPA will commit to 

work with us, however, it not only could possibly accelerate the transition but will result in a deeper realtime understanding of the—in this case global—issues that are barriers to transition.

In the following pages, we highlight the challenges to transitioning away from HFC refrigerants, which 

include the charge size limits for flammable alternatives in existing safety standards, product design and 

feasibility challenges, market dynamics and the need for direct engagement by third parties from 

government and the private sector. We believe these challenges underscore the need for a reasonable 

timeline for achieving the changeover in refrigerants in our products and justify the timeline we are 

proposing for refrigerators and freezers. We urge EPA to work with us in a non-regulatory posture to 

evaluate and facilitate the removal of barriers to transition.1

The History of Refrigerants in Home Appliances

As EPA is well aware, the home appliance industry has a long history of transitioning to refrigerants that 

maintain energy efficiency, cost effectiveness and safety while reducing impacts on the environment. In 

recent history, the industry has transitioned from CFCs, which were ozone depleting substances (ODS) 

with high global warming potential (GWP), to HCFCs (also ODS) and then to HFCs, which are nonozone depleting but still higher GWP than certain new alternatives. Each of these transitions required 

millions of dollars of R&D and capital investment by industry. Balancing performance and other product 

issues along with cost and energy efficiency parameters is a complicated and ever-evolving challenge. 

Above all, product safety is paramount.

In 2011, EPA approved the use of isobutane, which is not an ODS and has a very low GWP, as a 

refrigerant for use in residential refrigerators and freezers. In 2013, the Canadian Standards Association 

(CSA) also approved its use. Since that time, the industry has worked to remove technical barriers to 

transitioning to isobutane, including evaluating appropriate changes to the applicable safety standards that 

protect consumers while allowing a transition from HFCs. We have been urging the CPSC to participate 

in the development of safety standards for a number of years. Within the last year, the CPSC has been 

participating in the CANENA2 committee on Safety Requirements for Household Refrigerators and 

Freezers, a consensus safety standards process for refrigeration appliances.

In addition, the industry is currently transitioning out of high-GWP HFCs in foam insulation by 2020, per 

EPA’s most recent SNAP rule. This is achievable, but it is requiring significant expenditures and the 

diversion of a variety of important industry resources.

Moving beyond this history of voluntary transitions by the appliance industry, we now intend to eliminate 

HFC refrigerants in refrigerators and freezers after 2024. Such products, of course, already exist around 

the world, but unique North American design and safety challenge must be overcome. Factories must be 

reengineered, and education, logistics and disposal systems must be established to manage the safe 

transportation, servicing and disposal of flammable refrigerants. Nevertheless, this transition decision has 

been made without any existing regulatory mandate. 

For air conditioning home appliances and commercial ice-makers, on the other hand, we urge EPA not to 

mandate a transition to non-HFC refrigerants at this time. The industry needs adequate time to responsibly 

 1 As AHAM has noted in previous communications to EPA, we do not believe the agency has the authority under 

the Clean Air Act to “de-list” non- ozone-depleting substances (ODS) that had previously been approved as 

alternatives to ODS under the SNAP program. Nonetheless, this letter is offered in a spirit of cooperation. 2 CANENA is a tri-national body setting standards for the US, Canada and Mexico
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address the benefits and limitations of viable alternatives for these products. These products are 

manufactured outside the U.S., and this development work is still in a nascent stage globally.

Current Refrigerant Use, Alternatives and Existing Charge Size Limits

Refrigerators and Freezers

Refrigerators and freezers today mainly use the HFC refrigerant 134a. It is a highly effective chemical 

with a very low flammability index and a GWP of 1430, much lower than many other refrigerants 

currently used in other products. Only a few ounces of refrigerant are used in refrigerators and freezers, 

typically less than the amount of butane in a cigarette lighter. In addition, these refrigerants are in sealed 

systems, so leaks are exceedingly rare. 

The primary alternative for higher-GWP HFC refrigerants is isobutane (R600) in refrigerators and 

freezers. Isobutane is a hydrocarbon, so while it has a very low GWP, it is flammable and requires that 

appropriate precautions be taken against the associated risks. For refrigerator/freezers, air conditioning 

home appliances and commercial ice-makers, specific safety standards are in place that govern the use of 

HC refrigerants, which are flammable and require careful controls on use conditions. The current 

refrigerator/freezer standards from UL, the Canadian Standards Association (CSA) and CANENA limit 

the charge size in any refrigerant loop used in these products to 57 grams. Europe follows the 

International Electrotechnical Commission (IEC) standard, which sets the limit for HC for refrigerants at 

150 grams. 

Air Conditioning Home Appliances – RACs, PACs and DHs

Most air conditioning home appliances currently use R134a or R410A (GWP=2088). Others use R32, a 

mildly flammable HFC with a GWP of 675. For RACs and PACs, the total amount of refrigerant used 

ranges from less than a pound in smaller products to more than four pounds in larger RACs. DHs tend to 

be smaller and thus have smaller charge sizes, closer to half a pound.

The safety, design and energy issues of alternative refrigerants for these products—unlike refrigerators 

and freezers—are relatively unexplored, particularly in the North American context. For example, a 

possible alternative for higher-GWP HFC refrigerants in air conditioning home appliances is R32. 

Notably, R32 has equipment patent-related and possibly supply issues that need to be fully understood 

and resolved. AHAM members are understandably concerned about situations in which there may be 

limited chemical suppliers or patent issues, and it would be inadvisable and inappropriate for EPA to push 

industry into potentially costly, restrictive agreements. In addition, the transportation of even mildly 

flammable refrigerants and the warehousing and recycling of air conditioning home appliances containing 

them all need further evaluation. 

The UL and CSA limits and the proposed CANENA limit for RACs and PACs are 114 grams (~4 oz.) for 

propane and 918 grams (~2 lbs.) for R32. Although there are currently no specified limits for HC 

refrigerants in dehumidifiers in the UL and CSA standards, a proposal is moving forward to use the same 

formula as in room air conditioners. A formula used in the IEC 60335-2-40 standard caps propane use in 

air conditioning home appliances at almost 1kg, but many large RACs will need a refrigerant charge of 

more than 2kg.

Other Alternatives

Other potential alternatives to HFCs must be explored or are not yet vetted for the North American 

market. Propane and R441A were recently approved for use as refrigerants in the last SNAP rule, and 

manufacturers are now evaluating these new options. As noted above, the safety standards for AHAM 

products are very restrictive on the charge size for a unit using flammable refrigerants, so it is 
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questionable whether and to what extent manufacturers will opt to make this switch. Other potential 

alternatives that have been considered and rejected as unworkable include carbon dioxide and ammonia. 

Blends with HFOs that reduce flammability levels have been suggested recently, but evaluation of these 

options is just beginning. All that remains that is SNAP-approved are isobutane and propane, both 

flammable refrigerants. As with transitioning from HFC-based foam blowing agents, there are no drop-in 

alternatives. We seek a dialogue with EPA to discuss these issues.

Changes to Charge Size Limits

To determine the safest and most accurate charge limits and any other requirements for the CANENA 

standards for refrigerators and freezers, AHAM will need the support and participation of EPA and 

CPSC. The industry already has initiated an internal discussion to ascertain what research is needed to 

demonstrate where the proper safety limit is. This research will need to have broader input, engagement 

and support, however, to be widely and more rapidly accepted if it indicates the need for a change in the 

existing charge limits. Adding further complexity is the need to coordinate with safety standard 

organizations and regulators in Canada and Mexico. Updating a safety standard is a multi-year process. 

AHAM has committed to this review and has already begun internal efforts to this end. We call on EPA, 

CPSC and the three national standard development organizations to work with us on this analysis of the 

appropriate charge size limit.

Product Design and Feasibility Challenges

There are significant functional design challenges for standard-sized refrigerators to switch to HC 

refrigerants under current charge size limits. Redesign options include installing a second compressor 

and refrigerant loop or microtubes, each of which is expensive and adds considerable cost even to base 

model units. The U.S. refrigerator market is different from that in Europe, where the products (and the 

kitchens) tend to be smaller and are able to cool the internal compartments effectively with a single 

compressor, many of which are protected systems with no exposed evaporator tubing. Adding technical 

features could drive up the cost of products and put unnecessary financial strain on consumers. While 

many smaller products like mini-fridges and wine cabinets are already transitioning to hydrocarbons, the 

vast majority of refrigerators currently on the market would be affected. These impacts could be 

particularly hard on low-income and fixed-income consumers, who could face either more expensive 

products or a loss of key features.

Further complicating the dynamics of this transition for refrigerators are pending changes manufacturers 

must make to meet new EPA and Department of Energy regulatory requirements. The last iteration of 

EPA’s SNAP rule requires manufacturers to end the use of HFCs as foam blowing agents by 2020, a 

thoughtful decision which AHAM had recommended as it coincides with the anticipated publication of 

the next DOE refrigerator efficiency standard. Each of these new obligations will occupy research and 

development resources and require considerable capital investment. Adding a refrigerant phase-out at or 

around that time would further complicate the transition by adding a third major variable (and related 

investments) without achieving any efficiencies of scale.

Market Dynamics

The home appliance industry takes its responsibility for the environment seriously and has decided to 

spend the additional resources needed to expedite its transition to low GWP refrigerants. The percentage 

of total HFC use represented by home appliances is exceedingly small, and the environmental benefits 

that will be achieved by eliminating the use of HFC refrigerants in these products are marginal. EPA 

regulations already require recovery of HFCs at end of product life, meaning that the small amounts used 
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in our products must be captured and either disposed of properly or reclaimed. There is no evidence to 

suggest that leakage or improper disposal of home appliances are substantial sources of greenhouse gas 

emissions. We also note that EPA is taking actions to shore up refrigerant management rules under CAA 

Section 608; this action will further improve refrigerant management in the field.

On the other side of the scale, however, the costs to manufacturers—and ultimately to consumers—are 

significant. There are the obvious unit cost impacts from adding additional technological components or 

capabilities to achieve the transition to HCs. Other significant costs come from converting manufacturing 

operations to the use of alternative refrigerants and taking the necessary steps to address the risks inherent 

in working with flammable materials. This includes making operations explosion-proof and adopting 

worker safety practices and procedures that are consistent with OSHA regulations governing hazardous 

materials. In addition, there will be costs associated with the servicing of products containing flammable 

refrigerants and the related training and other burdens imposed on certified service technicians. 

History shows that chemical changes never go as quickly or as smoothly as anticipated. For example, the 

industry is still battling serious material compatibility issues with HFO use in foam, despite assurances 

from suppliers that there would be no such problems. All of these costs are additive to the obvious 

burdens on manufacturers: accelerated R&D, process retooling, supply chain disruption, etc. The 

environmental benefits of a prematurely accelerated phasedown are slight when compared to a more 

deliberate, less disruptive schedule that includes continuous progress toward transition

Next Steps

Despite these challenges and concerns, the appliance industry is moving forward with this transition. The 

single most challenging aspect is evaluating the restrictions in the existing safety standards for flammable 

refrigerants and determining a safe and appropriate charge size limit and any associated restrictions. As 

indicated above, AHAM has initiated internal discussions about a proposal on appropriate safety testing 

on which an updated standard could be based. This will be followed by outreach to relevant stakeholders 

such as the National Fire Protection Association, CPSC and others who should oversee the necessary 

technical study. We hope EPA will be involved in this process as well, and we clearly need to engage the 

three national standard development organizations. This process could take three to five years to 

complete, however.

While the necessary path forward is difficult but clear for refrigerators and freezers, the same cannot be 

said for air conditioning home appliances or commercial ice makers. As noted, no alternatives to HFCs 

currently exist other than propane, R441A and possibly R32, and the charge sizes required for these 

products to function correctly with flammable refrigerants are well beyond what is allowed by the 

existing safety standards. The transition dates for RAC, PAC and DH products and for commercial ice 

makers should necessarily be later than for refrigerators because of the uncertainty regarding alternatives 

to currently used refrigerants and because more information is needed about the particular challenges they 

face in making the switch to alternatives.

For these reasons, we urge EPA to support our voluntary efforts, to avoid a mandated transition date for 

household refrigerators and freezers that is no sooner than 2024 and to not set a date for air conditioning 

home appliances or commercial ice makers until the available alternatives and related technical and safety 

issues are better understood. We appreciate EPA’s willingness to work with the appliance industry over 

the years, and we hope EPA will assist us in this phasedown of HFCs as a refrigerant in residential 

refrigerators and freezers. 
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Thank you for considering our recommendations. We would be glad to provide any additional detail you 

may need about our concerns or our intended transition.

Sincerely,

Robert D. McArver

Vice President, Policy & Government Relations