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6560-50-P

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 82

[EPA-HQ-OAR-2015-0663; FRL-9941-84-OAR]

[RIN 2060-AS80]

Protection of Stratospheric Ozone: Proposed New Listings of Substitutes; Changes of

Listing Status; and Reinterpretation of Unacceptability for Closed Cell Foam Products

under the Significant New Alternatives Policy Program; and Revision of Clean Air Act 

Section 608’s Venting Prohibition for Propane

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice of proposed rulemaking.

SUMMARY: Pursuant to the U.S. Environmental Protection Agency’s (EPA) Significant New 

Alternatives Policy program, this action proposes to list a number of substances as acceptable, 

subject to use conditions; to list several substances as unacceptable; and to modify the listing 

status for certain substances from acceptable to acceptable, subject to narrowed use limits, or to 

unacceptable. Specifically, this action proposes to list as acceptable, subject to use restrictions,

propane and HFO-1234yf in the refrigeration and air conditioning, and 2-bromo-3,3,3-

trifluoroprop-1-ene in the fire suppression and explosion protection sectors; to list as 

unacceptable certain hydrocarbons and hydrocarbon blends in specific end-uses in the 

refrigeration and air conditioning sector; and to modify the listing status for certain high-global 

warming potential alternatives for certain end-uses in the refrigeration and air conditioning, foam 

blowing, and fire suppression and explosion protection sectors. This action also proposes to 
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exempt propane in certain refrigeration end-uses from the Clean Air Act section 608 prohibition 

on venting, release, or disposal on the basis of current evidence that its venting, release, or 

disposal does not pose a threat to the environment. In addition, this action proposes to apply 

unacceptability determinations for foam-blowing agents to closed cell foam products and 

products containing closed cell foam that are manufactured or imported using these foamblowing agents. This action also proposes to clarify the listing for Powdered Aerosol D (StatX

®), which is currently listed as both acceptable and acceptable subject to use conditions, by 

removing the listing as acceptable subject to use conditions.

DATES: Comments must be received on or before [INSERT DATE 45 DAYS AFTER 

PUBLICATION IN THE FEDERAL REGISTER]. Any party requesting a public hearing 

must notify the contact listed below under FOR FURTHER INFORMATION CONTACT by 

5 p.m. Eastern Daylight Time on [INSERT DATE 15 DAYS AFTER PUBLICATION IN 

THE FEDERAL REGISTER]. If a hearing is held, it will take place on or about [INSERT 

DATE 30 DAYS AFTER PUBLICATION IN THE FEDERAL REGISTER] in Washington, 

DC and further information will be provided on EPA’s Stratospheric Ozone Website at 

www.epa.gov/ozone/snap.

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-OAR-2015-0663,

to the Federal eRulemaking Portal: http://www.regulations.gov. Follow the online instructions 

for submitting comments. Once submitted, comments cannot be edited or withdrawn. EPA may 

publish any comment received to its public docket. Do not submit electronically any information 

you consider to be Confidential Business Information (CBI) or other information whose 

disclosure is restricted by statute. Multimedia submissions (audio, video, etc.) must be 

accompanied by a written comment. The written comment is considered the official comment 
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and should include discussion of all points you wish to make. EPA will generally not consider 

comments or comment contents located outside of the primary submission (i.e., on the web, 

cloud, or other file sharing system). For additional submission methods, the full EPA public 

comment policy, information about CBI or multimedia submissions, and general guidance on 

making effective comments, please visit http://www2.epa.gov/dockets/commenting-epa-dockets.

FOR FURTHER INFORMATION CONTACT: Chenise Farquharson, Stratospheric 

Protection Division, Office of Atmospheric Programs (Mail Code 6205 T), Environmental 

Protection Agency, 1200 Pennsylvania Ave. NW., Washington, DC 20460; telephone number: 

202-564-7768; email address: Farquharson.chenise@epa.gov. Notices and rulemakings under 

EPA’s Significant New Alternatives Policy program are available on EPA’s Stratospheric Ozone 

website at www.epa.gov/snap/snap-regulations.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. General information

A. Executive summary 

B. Does this action apply to me?

C. What acronyms and abbreviations are used in the preamble?

II. How does the SNAP program work?

A. What are the statutory requirements and authority for the SNAP program?

B. What are EPA’s regulations implementing CAA section 612?

C. How do the regulations for the SNAP program work?

D. What are the guiding principles of the SNAP program?

E. What are EPA’s criteria for evaluating substitutes under the SNAP program?

F. How are SNAP determinations updated?

G. What does EPA consider in deciding whether to modify the listing status of an

alternative?

H. Where can I get additional information about the SNAP program?

III. What actions and information related to greenhouse gases have bearing on this proposed

action?

IV. What petitions has EPA received requesting a change in listing status for HFCs?

A. Summary of petitions

B. How this action relates to the Climate Action Plan and petitions

V. How does EPA regulate substitute refrigerants under CAA section 608?
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A. What are the statutory requirements concerning venting, release, or disposal of 

refrigerants and refrigerant substitutes under CAA section 608?

B. What are EPA’s regulations concerning venting, release, or disposal of refrigerant 

substitutes?

C. What did EPA recently propose regarding management of refrigerant substitutes 

under CAA section 608? 

VI. What is EPA proposing in this action? 

A. Retail food refrigeration and stationary AC

1. Proposed listing of propane as acceptable, subject to use conditions, for 

commercial ice machines, water coolers, and very low temperature refrigeration

equipment

a. What are the affected end-uses?

b. How does propane compare to other refrigerants for these end-uses 

with respect to SNAP criteria?

c. What are the proposed use conditions?

d. What recommendations does EPA have for the safe use of propane?

e. When would the listing apply?

f. What is the relationship between this SNAP rule and other federal 

rules? 

g. On which topics is EPA specifically requesting comment? 

2. Proposed exemption for propane from the venting prohibition under CAA 

section 608 for the end-uses in the proposed new SNAP listing 

a. What is EPA’s proposal regarding whether venting of propane in the 

end-uses in this action would pose a threat to the environment?

b. What is EPA’s proposal regarding whether venting of propane in the 

end-uses in this action should be exempted from the venting prohibition 

under CAA section 608?

c. When would the exemption from the venting prohibition apply?

d. What is the relationship between this proposed exemption under CAA 

section 608 and other EPA rules?

e. On which topics is EPA specifically requesting comment?

3. Proposed listing of new refrigerants as unacceptable 

a. Proposed listing of certain flammable refrigerants as unacceptable for 

retrofits in unitary split AC systems and heat pumps

i. What is the affected end-use?

ii. Which refrigerants is EPA proposing to list as unacceptable? 

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for these end-uses with respect to SNAP criteria?

iv. When would the listings apply?

v. What is the relationship between this SNAP rule and other federal 

rules? 

vi. On which topics is EPA specifically requesting comment? 

b. Proposed listing of propylene and R-443A as unacceptable for new 

residential and light commercial AC and heat pumps, cold storage 

warehouses, and centrifugal and positive displacement chillers

i. What are the affected end-uses?
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ii. Which refrigerants is EPA proposing to list as unacceptable?

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for these end-uses with respect to SNAP criteria?

iv. When would the listings apply?

v. What is the relationship between this SNAP rule and other federal 

rules? 

vi. On which topics is EPA specifically requesting comment? 

4. Proposed changes in listing status

a. Proposed change of status for certain HFC refrigerants for new 

centrifugal chillers

i. What is the affected end-use?

ii. Which refrigerants is EPA proposing to list as unacceptable?

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for this end-use with respect to SNAP criteria?

iv. When would the status change?

v. What is the relationship between this SNAP rule and other federal 

rules? 

vi. On which topics is EPA specifically requesting comment? 

b. Proposed change of status for certain HFC refrigerants for new 

positive displacement chillers 

i. What is the affected end-use? 

ii. Which refrigerants is EPA proposing to list as unacceptable? 

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for this end-use with respect to SNAP criteria?

iv. When would the status change?

v. What is the relationship between this SNAP rule and other federal 

rules? 

vi. On which topics is EPA specifically requesting comment? 

c. Proposed change of status for certain HFC refrigerants for new cold 

storage warehouses

i. What is the affected end-use?

ii. Which refrigerants is EPA proposing to list as unacceptable?

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for this end-use with respect to SNAP criteria?

iv. When would the status change?

v. What is the relationship between this SNAP rule and other federal 

rules? 

vi. On which topics is EPA specifically requesting comment? 

d. Proposed change of status for certain HFC refrigerants for new retail 

food refrigeration (refrigerated food processing and dispensing equipment) 

i. What is the affected end-use? 

ii. Which refrigerants is EPA proposing to list as unacceptable? 

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for this end-use with respect to SNAP criteria?

iv. When would the status change?

v. What is the relationship between this SNAP rule and other federal 
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rules? 

vi. On which topics is EPA specifically requesting comment? 

e. Proposed change of status for certain HFC refrigerants for new 

household refrigerators and freezers

i. What is the affected end-use? 

ii. Which refrigerants is EPA proposing to list as unacceptable? 

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for this end-use with respect to SNAP criteria?

iv. When would the status change?

v. What is the relationship between this SNAP rule and other federal 

rules? 

vi. On which topics is EPA specifically requesting comment? 

B. Motor vehicle air conditioning 

1. Proposed listing of HFO-1234yf as acceptable, subject to use conditions, for 

newly manufactured MVAC systems

2. What is the affected end-use?

3. How does HFO-1234yf compare to other refrigerants for these MVAC 

applications with respect to SNAP criteria?

4. What are the proposed use conditions?

5. When would the listing apply?

6. What is the relationship between this SNAP rule and other federal rules? 

7. On which topics is EPA specifically requesting comment?

C. Foam blowing agents

1. Proposed change of status for certain HFC foam blowing agents for rigid PU

spray foam

a. What is the affected end-use? 

b. Which foam blowing agents is EPA proposing to list as unacceptable? 

c. How do the proposed unacceptable blowing agents compare to other 

blowing agents for these applications with respect to SNAP criteria?

d. What narrowed use limits for military or space- and aeronauticsrelated applications is EPA proposing?

e. When would the status change?

f. What is the relationship between this SNAP rule and other federal 

rules? 

g. On which topics is EPA specifically requesting comment? 

2. Proposed change of status for methylene chloride in flexible PU, integral skin 

PU, and polyolefin foams

a. What are the affected end-uses?

b. How does methylene chloride compare to other blowing agents for 

these end-uses with respect to SNAP criteria?

c. When would the status change?

d. What is the relationship between this SNAP rule and other federal

rules? 

e. On which topics is EPA specifically requesting comment? 

3. Proposed application of listings to foam products

a. What are the affected end-uses?
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b. How would this proposal change the treatment of foam products under 

SNAP?

c. How do other stratospheric ozone protection requirements apply to 

foam products? 

d. How is EPA reexamining treatment of foam products under SNAP?

e. When would use of closed cell foam products with unacceptable 

blowing agents be unacceptable?

f. On which topics is EPA specifically requesting comment? 

D. Fire suppression and explosion protection

1. Proposed listing of 2-bromo-3,3,3-trifluoropropene (2-BTP) as acceptable, 

subject to use conditions, for total flooding and streaming

a. What are the affected end-uses? 

b. How does 2-BTP compare to other fire suppressants for these end-uses

with respect to SNAP criteria?

c. What are the proposed use conditions? 

d. What further information is EPA providing in the acceptable, subject 

to use conditions, listing for 2-BTP? 

e. When would the listing apply?

f. What is the relationship between this SNAP rule and other federal 

rules? 

g. On which topics is EPA specifically requesting comment? 

2. Proposed change of status for certain perfluorocarbons 

a. What is the affected end-use? 

b. Which fire suppressants is EPA proposing to list as unacceptable?

c. How do the proposed unacceptable fire suppressants compare to other 

fire suppressants for this end-use with respect to SNAP criteria?

d. When would the status change?

e. What is the relationship between this SNAP rule and other federal 

rules? 

f. On which topics is EPA specifically requesting comment? 

3. Proposed removal of Powdered Aerosol D in total flooding from the list of 

substitutes acceptable for use subject to use conditions

VII. Statutory and executive order reviews

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 

13563: Improving Regulation and Regulatory Review

B. Paperwork Reduction Act

C. Regulatory Flexibility Act

D. Unfunded Mandates Reform Act

E. Executive Order 13132: Federalism

F. Executive Order 13175: Consultation and Coordination with Indian Tribal 

Governments

G. Executive Order 13045: Protection of Children from Environmental Health and 

Safety Risks

H. Executive Order 13211: Actions Concerning Regulations That Significantly Affect 

Energy Supply, Distribution, or Use 

I. National Technology Transfer and Advancement Act (NTTAA)
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J. Executive Order 12898: Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations

VIII. References

I. General Information 

A. Executive summary

Under section 612 of the Clean Air Act (CAA), EPA is required to evaluate substitutes1

to ozone-depleting substances (ODS) for their risks to human health and the environment. EPA 

reviews substitutes within a comparative risk framework. More specifically, section 612 provides 

that EPA must prohibit the use of a substitute where EPA has determined that there are other 

alternatives that pose less overall risk to human health and the environment. Thus, EPA’s 

Significant New Alternatives Policy (SNAP) program, which implements section 612, does not 

provide a static list of alternatives. Instead, the program evolves the list as EPA makes decisions 

informed by our overall understanding of the environmental and human health impacts as well as 

our current knowledge about other alternatives. In the more than twenty years since the initial 

SNAP rule was promulgated, EPA has modified the SNAP lists many times, most often by 

expanding the list of acceptable substitutes. However, in some cases, the SNAP list has been 

modified by listing a substitute as unacceptable for one or more end-uses or by restricting the use 

of a previously listed substitute by changing its status for a particular end-use to unacceptable, 

acceptable subject to use conditions, or acceptable subject to narrowed use.

In the decades since ODS were first invented in the 1920s, American consumers relied on 

products using ODS for diverse uses including aerosols, air conditioning, insulation, solvent 

cleaning, and fire protection. The agreement by governments to phase out production of ODS 

under the Montreal Protocol led to inevitable questions about whether suitable alternatives could 

 

1 The terms “alternatives” and “substitutes” are used interchangeably in this document.
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be found in all cases, and in the larger sense, about how to limit negative societal impacts from 

use of alternatives. 

Over the past twenty years, the SNAP program has played an important role in assisting

with a continuous smooth transition to safer alternatives, by addressing in concrete and highly 

technical terms, end-use by end-use, these myriad issues. From the first SNAP framework rule 

published in 1994, which provided confidence and certainty by identifying safer alternatives in 

key consumer and industrial uses, the SNAP program has continued to ensure that businesses 

and consumers have access to information about suitable alternatives. The SNAP program works 

with many stakeholders domestically and abroad, to continuously evaluate and provide updates 

on safer alternatives and new technologies. Thanks to these efforts and the work of individuals, 

businesses, and organizations, the transitions generally have been successful. Perhaps the best 

evidence of the program’s success has been the lack of fanfare with which so many important 

consumer and industrial uses have moved to adopt safer SNAP-listed alternatives. When

reviewing a substitute, EPA compares the risk posed by that substitute to the risks posed by other 

alternatives and determines whether that specific substitute under review poses significantly 

more risk than other alternatives for the same use. EPA recently has begun to review the lists in a 

broader manner to determine whether substitutes added to the lists early in the program pose 

significantly more risk than substitutes that have more recently been added. As with initial listing 

decisions, decisions to change the status of an already listed alternative are based on applying our 

comparative risk framework. 

Global warming potential (GWP) is one of several criteria EPA considers in the overall 

evaluation of the alternatives under the SNAP program. The President’s June 2013 Climate 

Action Plan (CAP) states that, “to reduce emissions of HFCs, the United States can and will lead 
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both through international diplomacy as well as domestic actions.” Furthermore, the CAP states 

that EPA will “use its authority through the Significant New Alternatives Policy Program to 

encourage private sector investment in low-emissions technology by identifying and approving 

climate-friendly chemicals while prohibiting certain uses of the most harmful chemical 

alternatives.” On July 20, 2015 (80 FR 42870), EPA issued a final regulation that was our first 

effort to take a broader look at the SNAP lists, where we focused on those listed substitutes that 

have a high GWP relative to other alternatives in specific end-uses, while otherwise posing 

comparable levels of risk. 

In this action, EPA is proposing to list a number of substances as acceptable, subject to 

use restrictions; to list several substances as unacceptable; and to modify the listing status for 

certain substances from acceptable to unacceptable. We performed a comparative risk analysis, 

based on our criteria for review, with other alternatives for the relevant end-uses. For particular 

substances, EPA found significant potential differences in risk with respect to one or more 

specific criteria, such as flammability, toxicity, or local air quality concerns, while otherwise 

posing comparable levels of risk to those of other alternatives in specific end-uses. EPA is also 

proposing that the existing listing decisions for foam blowing agents apply to closed cell foam 

products and products containing closed cell foam. See section VI.C.3 for the details of this 

proposal. Additionally, EPA is proposing to list propane (R-290) as acceptable, subject to use 

conditions, as a refrigerant in new self-contained commercial ice machines, in new water coolers, 

and in new very low temperature refrigeration equipment. EPA is proposing to exempt propane 

in these end-uses from the venting prohibition under CAA section 608(c)(2). See section 

VI.A.2.a, “What is EPA’s proposal regarding whether venting of propane in the end-uses in this 

action would pose a threat to the environment?” for the details of this proposal.

Commented [A1]: Does this cover lab-grade equipment? Will 

EPA describe how this category is defined so that the commenting 

agency can figure out if there are other regulations that may also be 

impacting the same sector.
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Per the guiding principles of the SNAP program, this action does not specify that any 

alternative is acceptable or unacceptable across all sectors and end-uses. Instead, in all cases, 

EPA considered the intersection between the specific alternative and the particular end-use and 

the availability of substitutes for those particular end-uses. In the case of refrigeration and air 

conditioning (AC), we consider new equipment to be a separate end-use from retrofitting 

existing equipment with a different refrigerant from that for which the equipment was originally 

designed. EPA is not setting a “risk threshold” for any specific SNAP criterion, such that the 

only acceptable substitutes pose risk below a specified level of risk. Because the substitutes 

available and the types of risk they may pose vary by sector and end-use and under the SNAP 

comparative risk framework, our review focuses on the specific end-use and the alternatives for 

that end-use, including the other risks alternatives might pose. Thus, there is no bright line that 

can be established. Also, EPA recognizes that there are a range of substitutes with various uses 

that include both fluorinated (e.g., hydrofluorocarbons (HFCs), hydrofluoroolefins (HFOs)) and 

non-fluorinated (e.g., hydrocarbons (HCs), carbon dioxide (CO2)) substitutes that may pose 

lower overall risk to human health and the environment. Consistent with CAA section 612 as we 

have historically interpreted it under the SNAP program, EPA is proposing both initial listings 

and certain modifications to the current lists based on our evaluation of the substitutes addressed 

in this action using the SNAP criteria for evaluation and considering the current suite of other 

alternatives for the specific end-use at issue. 

1. Proposed acceptable alternatives, with use conditions, by end-use (initial 

listings): 

1) For refrigeration, we are proposing to list as acceptable, subject to use 

conditions, as of 30 days after publication of a final rule
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 Propane in new commercial ice machines, new water coolers, and new 

very low temperature refrigeration equipment.

2) For motor vehicle air conditioning (MVAC) systems, we are proposing to list, 

as acceptable, subject to use conditions, as of 30 days after publication of a final 

rule

 HFO-1234yf in newly manufactured medium-duty passenger vehicles

(MDPVs), heavy-duty (HD) pickup trucks, and complete HD vans.

3) For fire suppression and explosion protection end-uses, we are proposing to list

as acceptable, subject to use conditions, as of 30 days after publication of a final 

rule

 2-BTP as a total flooding agent for use in engine nacelles and auxiliary 

power units (APUs) on aircraft; and 

 2-BTP as a streaming agent for use in aircraft.

2. Proposed unacceptable alternatives by end-use (initial listings):

1) For retrofit residential and light commercial AC and heat pumps—unitary split 

AC systems and heat pumps, we are proposing to list as unacceptable, as of 30 

days after publication of a final rule

 All refrigerants identified as flammability Class 3 in American 

National Standards Institute (ANSI)/American Society of Heating, 

Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 

34–2013; and 

 All refrigerants meeting the criteria for flammability Class 3 in 

ANSI/ASHRAE Standard 34–2013. These include, but are not limited 
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to, refrigerant products sold under the names R-22a, 22a, Blue Sky 22a 

refrigerant, Coolant Express 22a, DURACOOL-22a, EC-22, 

Ecofreeeze EF-22a, EF-22a, Envirosafe 22a, ES-22a, Frost 22a, HC22a, Maxi-Fridge, MX-22a, Oz-Chill 22a, Priority Cool, and RED 

TEK 22a.

2) For new residential and light commercial AC and heat pumps, cold storage 

warehouses, centrifugal chillers, and positive displacement chillers, we are 

proposing to list as unacceptable, as of 30 days after publication of a final rule

 Propylene and R-443A.

3. Proposed change of listing status by end-use:

1) For new centrifugal chillers, we are proposing to list as unacceptable, as of 

January 1, 2022

 FOR12A, FOR12B, HFC-134a, HFC-227ea, HFC-236fa, HFC-245fa, 

R-125/134a/600a (28.1/70/1.9), R-125/290/134a/600a

(55.0/1.0/42.5/1.5), R-404A, R-407C, R-410A, R-410B, R-417A, R421A, R-422B, R-422C, R-422D, R-423A, R-424A, R-434A, R-438A, 

R-507A, RS-44 (2003 composition), and THR-03.

2) For new positive displacement chillers, we are proposing to list as 

unacceptable, as of January 1, 2022

 FOR12A, FOR12B, HFC-134a, HFC-227ea, KDD6, R-125/134a/600a 

(28.1/70/1.9), R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R407C, R-410A, R-410B, R-417A, R-421A, R-422B, R-422C, R-422D, 

Commented [A2]: This is helpful internationally given some of 

the safety concerns raised recently with the use of hydrocarbons for 

retrofit. To be clear, the agency commenter stated that it is the 

retrofit aspect that is the concern, new equipment designed for these 

refrigerants can meet necessary standards. 

Are there any requirements for retrofits? If so, please explain. 

Commented [A3]: The commenting agency suggests that EPA

consider a listing for window air conditioning unit given prior EPA 

rulemakings that have allowed R-290 and R-32 in window units. 

There is considerable global capacity using these refrigerants in 

window units, especially R-290, and they could be introduced into 

the US market to meet the need here. Will EPA explain the current 

status of any recent changes or reasons why the agency has not 

recently made any changes for window air conditioning units?
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R-424A, R-434A, R-437A, R-438A, R-507A, RS-44 (2003 

composition), SP34E, and THR-03.

3) For new cold storage warehouses, we are proposing to list as unacceptable, as 

of January 1, 2023

 HFC-227ea, R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R407A, R-407B, R-410A, R-410B, R-417A, R-421A, R-421B, R-422A, 

R-422B, R-422C, R-422D, R-423A, R-424A, R-428A, R-434A, R438A, R-507A, and RS-44 (2003 composition).

4) For new retail food refrigeration (refrigerated food processing and dispensing 

equipment), we are proposing to list as unacceptable, as of January 1, 2021

 HFC-227ea, KDD6, R-125/290/134a/600a (55.0/1.0/42.5/1.5), R404A, R-407A, R-407B, R-407C, R-407F, R-410A, R-410B, R-417A, 

R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R428A, R-434A, R-437A, R-438A, R-507A, RS-44 (2003 formulation).

5) For new household refrigerators and freezers, we are proposing to list as 

unacceptable, as of January 1, 2021

 FOR12A, FOR12B, HFC-134a, KDD6, R-125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, R-407C, R-407F, R-410A, R-410B, R417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, 

R-426A, R-428A, R-434A, R-437A, R-438A, R-507A, RS-24 (2002 

formulation), RS-44 (2003 formulation), SP34E, and THR-03.

6) For rigid polyurethane (PU) high-pressure two-component spray foam, we are 

proposing to list as unacceptable for all uses, except military or space-and 

Commented [A4]: Given the recent agreement between NRDC 

and industry for 2025. 

Has EPA considered a broader scope for this chiller delisting? The 

commenting agency suggested a delisting that would apply to all 

other types of chillers on January 1, 2025.

If both industry and NRDC have agreed to 2025, suggest that the 

agency move all of the proposed dates to 2025.
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aeronautics–related applications, as of January 1, 2020; as acceptable, subject to 

narrowed use limits, for military or space-and aeronautics–related applications, as 

of January 1, 2020; and as unacceptable for military or space-and aeronautics–

related applications as of January 1, 2022

 HFC-134a, HFC-245fa, and blends thereof; blends of HFC-365mfc 

with at least four percent HFC-245fa, and commercial blends of HFC365mfc with seven to 13 percent HFC-227ea and the remainder HFC365mfc; and Formacel TI.

2

7) For rigid PU low-pressure two-component spray foam, we are proposing to list

as unacceptable for all uses, except military or space-and aeronautics–related 

applications, as of January 1, 2021; as acceptable, subject to narrowed use limits,

for military or space-and aeronautics–related applications, as of January 1, 2021;

and as unacceptable for military or space-and aeronautics–related applications as 

of January 1, 2022

 HFC-134a, HFC-245fa, and blends thereof; blends of HFC-365mfc 

with at least four percent HFC-245fa, and commercial blends of HFC365mfc with seven to 13 percent HFC-227ea and the remainder HFC365mfc; and Formacel TI.

3

8) For rigid PU one-component foam sealants, we are proposing to list as 

unacceptable, as of January 1, 2020

 

2 Closed cell foam products and products containing closed cell foams manufactured on or before January 1, 2020, 

may be used after that date.

3 Closed cell foam products and products containing closed cell foams manufactured on or before January 1, 2021, 

may be used after that date.
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 HFC-134a, HFC-245fa, and blends thereof; blends of HFC-365mfc 

with at least four percent HFC-245fa, and commercial blends of HFC365mfc with seven to 13 percent HFC-227ea and the remainder HFC365mfc; and Formacel TI.4

9) For flexible PU foam applications, we are proposing to list as unacceptable, as 

of 30 days after publication of a final rule

 Methylene chloride.

10) For integral skin PU foam applications, we are proposing to list as 

unacceptable, as of January 1, 2017

 Methylene chloride.5

11) For polyolefin foam applications, we are proposing to list as unacceptable, as 

of January 1, 2020

 Methylene chloride.6

12) For fire suppression total flooding uses, we are proposing to list as 

unacceptable, as of one year after publication of a final rule

 Perfluorocarbons (PFCs) (C3F8 and C4F10).

4. Other changes

1) For all foam blowing end-uses, we are proposing to prohibit 

 Use of closed cell foam products and products that contain closed cell 

 

4 Closed cell foam products and products containing closed cell foams manufactured on or before January 1, 2020, 

may be used after that date.

5 Closed cell foam products and products containing closed cell foams manufactured on or before January 1, 2017, 

may be used after that date.

6 Closed cell foam products and products containing closed cell foams manufactured on or before January 1, 2020, 

may be used after that date.
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foam manufactured with an unacceptable foam blowing agent on or after 

the later of 1) one year after publication of a final rule or 2) the date of the 

unacceptability listing.

2) For fire suppression and explosion protection total flooding end-use, we are 

proposing to clarify the listing for Powdered Aerosol D (Stat-X

®), which is 

currently listed as both “acceptable” and “acceptable subject to use conditions,”

by removing the listing as “acceptable subject to use conditions,” as of 30 days 

after publication of a final rule.

B. Does this action apply to me?

Potential entities that may be affected by this final rule include:

Table 1. Potentially Regulated Entities by North American Industrial Classification System (NAICS) 

Code

Category NAICS code Description of regulated entities

Construction 238210 Alarm System (E.G., Fire, Burglar), Electric, Installation Only

Industry 238220 Plumbing, Heating, And Air Conditioning Contractors

Industry 325199 All Other Basic Organic Chemical Manufacturing

Industry 325412 Pharmaceutical Preparation Manufacturing

Industry 325520 Adhesive Manufacturing

Industry 325998 All Other Miscellaneous Chemical Product and Preparation 

Manufacturing

Industry 326150 Urethane and Other Foam Product (Except Polystyrene) 

Manufacturing

Manufacturing 332919 Nozzles, Firefighting, Manufacturing

Industry 333415 Manufacturers of Refrigerators, Freezers, and Other Refrigerating or 

Freezing Equipment, Electric or Other (NESOI); Heat Pumps Not 

Elsewhere Specified or Included; and Parts Thereof

Commented [A5]: The commenting agency supports this to 

level the playing field for domestic manufacturers.
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Industry 333415 Air Conditioning and Warm Air Heating Equipment and Commercial 

and Industrial Refrigeration Equipment Manufacturing

Manufacturing 334290 Fire Detection and Alarm Systems Manufacturing

Industry 335222 Household Refrigerator and Home Freezer Manufacturing

Industry 336120 Heavy Duty Truck Manufacturing

Industry 336211 Motor Vehicle Body Manufacturing

Industry 3363 Motor Vehicle Parts Manufacturing

Industry 3364 Aerospace Product and Parts Manufacturing

Manufacturing 336411 Aircraft Manufacturing

Manufacturing 336413 Other Aircraft Parts and Auxiliary Equipment Manufacturing

Industry 336992 Military Armored Vehicle, Tank, and Tank Component 

Manufacturing

Industry 339113 Surgical Appliance and Supplies Manufacturing

Manufacturing 339999 Fire Extinguishers, Portable, Manufacturing

Retail 423620 Household Appliances, Electric Housewares, and Consumer 

Electronics Merchant Wholesalers

Retail 423740 Refrigeration Equipment and Supplies Merchant Wholesalers

Retail 423930 Recyclable Material Merchant Wholesalers

Retail 443111 Appliance Stores: Household-Type

Retail 44511 Supermarkets and Other Grocery (Except Convenience) Stores

Retail 445110 Supermarkets and Other Grocery (Except Convenience) Stores

Retail 445120 Convenience Stores

Retail 44521 Meat Markets

Retail 44522 Fish and Seafood Markets

Retail 44523 Fruit and Vegetable Markets

Retail 445291 Baked Goods Stores

Retail 445292 Confectionary and Nut Stores
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Retail 445299 All Other Specialty Food Stores

Retail 4453 Beer, Wine, and Liquor Stores

Retail 446110 Pharmacies and Drug Stores

Retail 44711 Gasoline Stations With Convenience Stores

Retail 452910 Warehouse Clubs and Supercenters 

Retail 452990 All Other General Merchandise Stores

Services 72111 Hotels (Except Casino Hotels) and Motels

Services 72112 Casino Hotels

Retail 72241 Drinking Places (Alcoholic Beverages)

Retail 722513 Limited-Service Restaurants

Retail 722514 Cafeterias, Grill Buffets, and Buffets

Retail 722515 Snack and Nonalcoholic Beverage Bars

Services 81119 Other Automotive Repair and Maintenance

Services 811412 Appliance Repair and Maintenance

Services 922160 Fire Protection

This table is not intended to be exhaustive, but rather provides a guide for readers 

regarding entities likely to be regulated by this action. This table lists the types of entities that 

EPA is now aware could potentially be regulated by this action. Other types of entities not listed 

in the table could also be regulated. To determine whether your entity is regulated by this action, 

you should carefully examine the applicability criteria found in 40 CFR Part 82. If you have 

questions regarding the applicability of this action to a particular entity, consult the person listed 

in the FOR FURTHER INFORMATION CONTACT section.

C. What acronyms and abbreviations are used in the preamble?

Below is a list of acronyms and abbreviations used in the preamble of this document:

AIHA—American Industrial Hygiene Association 
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AC—Air Conditioning

ACGIH—American Conference of Governmental Industrial Hygienists 

ACH—Changes Per Hour 

ASRAC—Appliance Standards and Rulemaking Federal Advisory Committee

AEGL— Acute Emergency Guideline Limits 

AHRI—Air Conditioning, Heating and Refrigeration Institute 

AIRAH—Australian Institute of Refrigeration, Air conditioning and Heating

ANSI—American National Standards Institute 

APU— Auxiliary Power Unit

ASHRAE—American Society of Heating, Refrigerating and Air-Conditioning Engineers 

BTU—British Thermal Units 

CAA—Clean Air Act 

CAP—Climate Action Plan 

CAS Reg. No.—Chemical Abstracts Service Registry Identification Number 

CBI—Confidential Business Information 

CFC—Chlorofluorocarbon 

CFR—Code of Federal Regulations 

CH4—Methane 

CMAQ—Community Multiscale Air Quality 

CO2—Carbon Dioxide 

CO2eq—Carbon Dioxide Equivalent

CUAC—Commercial Unitary Air Conditioner

CUHP—Commercial Unitary Heat Pump
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DOE—United States Department of Energy 

DX—Direct Expansion

EEAP—Environmental Effects Assessment Panel

EIA—Environmental Investigation Agency 

EO—Executive Order

EPA—United States Environmental Protection Agency 

EU—European Union 

FCA—Fiat Chrysler Automobiles 

FMEA— Failure Mode and Effects Analysis

FAA—Federal Aviation Administration

FR—Federal Register 

FTA—Fault Tree Analysis 

GHG—Greenhouse Gas 

GtCO2eq—Gigatonnes of Carbon Dioxide Equivalent

GWP—Global Warming Potential 

GVWR—Gross Vehicle Weight Rating 

HBFC—Hydrobromofluorocarbon 

HC—Hydrocarbon 

HCFC—Hydrochlorofluorocarbon 

HD—Heavy-Duty

HD GHG—Heavy-Duty Greenhouse Gas

HF—Hydrogen Fluoride

HFC—Hydrofluorocarbon 
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HFO—Hydrofluoroolefin 

HTOC—Halons Technical Options Committee

ICAO— International Civil Aviation Organization

ICF—ICF International, Inc. 

IGSD—Institute for Governance and Sustainable Development

IEC—International Electrochemical Commission

IPCC—Intergovernmental Panel on Climate Change 

IPR—Industrial Process Refrigeration

kPa—Kilopascal 

LD—Light-Duty

LD GHG—Light-Duty Greenhouse Gas 

LFL—Lower Flammability Limit 

LOAEL—Lowest Observed Adverse Effect Level

LPG—Liquified Petroleum Gas 

MAC Directive—Directive on Mobile Air Conditioning

MDPV—Medium-Duty Passenger Vehicle

MIR—Maximum Incremental Reactivity 

MMTCO2eq—Million Metric Tons of Carbon Dioxide Equivalent

MSDS—Material Safety Data Sheet

MVAC—Motor Vehicle Air Conditioning 

MY—Model Year 

N2O—Nitrous Oxide 

NAAQS—National Ambient Air Quality Standards
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NADA— National Automobile Dealers Association 

NAICS—North American Industrial Classification System 

NESHAP—National Emission Standards for Hazardous Air Pollutants

NFPA—National Fire Protection Association

NHTSA—National Highway Traffic Safety Administration 

NIK—Not-In-Kind

NIOSH—United States National Institute for Occupational Safety and Health 

NPRM—Notice of Proposed Rulemaking 

NRDC—Natural Resources Defense Council 

NSF—National Sanitation Foundation 

OEM—Original Equipment Manufacturer 

ODP—Ozone Depletion Potential 

ODS—Ozone-depleting Substance 

OMB—United States Office of Management and Budget 

OSHA—United States Occupational Safety and Health Administration 

PEL—Permissible Exposure Limit 

PFC—Perfluorocarbons

PMS—Pantone Matching System

ppb—Parts Per Billion 

PPE—Personal Protective Equipment 

ppm—Parts Per Million 

PSM—Process Safety Management 

PTAC—Packaged Terminal Air Conditioners 
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PTHP—Packaged Terminal Heat Pumps 

PU—Polyurethane 

RCRA—Resource Conservation and Recovery Act 

REL—Recommended Exposure Limit 

RfC—Reference Concentration 

RMP—Risk Management Plan 

RSES—Refrigeration Service Engineers Society

RTOC—Refrigeration, Air Conditioning and Heat Pumps Technical Options Committee

SARPS—Standards and Recommended Practices

SIP—State Implementation Plan 

SAE ICCC—SAE International’s Interior Climate Control Committee 

SAP—Scientific Assessment Panel

SF6—Sulfur Hexafluoride 

SNAP—Significant New Alternatives Policy 

SRES—Special Report on Emissions Scenarios 

STEL—Short-term Exposure Limit

SUV—Sport Utility Vehicles 

TEAP—Technical and Economic Assessment Panel 

TFA—Trifluoroacetic Acid

TLV—Threshold Limit Value 

TWA—Time Weighted Average 

UL—Underwriters Laboratories, Inc. 

UMRA—Unfunded Mandates Reform Act
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UNEP—United Nations Environmental Programme

VOC—Volatile Organic Compounds 

WEEL—Workplace Environmental Exposure Limit 

II. How does the SNAP program work?

A. What are the statutory requirements and authority for the SNAP program?

CAA section 612 requires EPA to develop a program for evaluating alternatives to ODS. 

This program is known as the SNAP program. The major provisions of section 612 are: 

1. Rulemaking

Section 612(c) requires EPA to promulgate rules making it unlawful to replace any class I 

(chlorofluorocarbon (CFC), halon, carbon tetrachloride, methyl chloroform, methyl bromide, 

hydrobromofluorocarbon (HBFC), and chlorobromomethane) or class II (HCFC) substance with 

any substitute that the Administrator determines may present adverse effects to human health or 

the environment where the Administrator has identified an alternative that (1) reduces the overall 

risk to human health and the environment and (2) is currently or potentially available.

2. Listing of Unacceptable/Acceptable Substitutes

Section 612(c) requires EPA to publish a list of the substitutes that it finds to be 

unacceptable for specific uses and to publish a corresponding list of acceptable substitutes for 

specific uses. The list of “acceptable” substitutes is found at www.epa.gov/ozone/snap/lists and 

the lists of “unacceptable,” “acceptable subject to use conditions,” and “acceptable subject to 

narrowed use limits” substitutes are found in the appendices to 40 CFR part 82 subpart G. 

3. Petition Process

Section 612(d) grants the right to any person to petition EPA to add a substance to, or 

delete a substance from, the lists published in accordance with section 612(c). The Agency has 
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90 days to grant or deny a petition. Where the Agency grants the petition, EPA must publish the 

revised lists within an additional six months.

4. 90-day Notification

Section 612(e) directs EPA to require any person who produces a chemical substitute for 

a class I substance to notify the Agency not less than 90 days before new or existing chemicals 

are introduced into interstate commerce for significant new uses as substitutes for a class I 

substance. The producer must also provide the Agency with the producer’s unpublished health 

and safety studies on such substitutes.

5. Outreach

Section 612(b)(1) states that the Administrator shall seek to maximize the use of federal 

research facilities and resources to assist users of class I and II substances in identifying and 

developing alternatives to the use of such substances in key commercial applications.

6. Clearinghouse

Section 612(b)(4) requires the Agency to set up a public clearinghouse of alternative 

chemicals, product substitutes, and alternative manufacturing processes that are available for 

products and manufacturing processes which use class I and II substances. 

B. What are EPA’s regulations implementing CAA section 612?

On March 18, 1994, EPA published the initial SNAP rule (59 FR 13044) which 

established the process for administering the SNAP program and issued EPA’s first lists 

identifying acceptable and unacceptable substitutes in major industrial use sectors (40 CFR part 

82 subpart G). These sectors are the following: refrigeration and AC; foam blowing; solvents 

cleaning; fire suppression and explosion protection; sterilants; aerosols; adhesives, coatings and 

inks; and tobacco expansion. These sectors comprise the principal industrial sectors that 
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historically consumed the largest volumes of ODS.

C. How do the regulations for the SNAP program work?

Under the SNAP regulations, anyone who produces a substitute to replace a class I or II 

ODS in one of the eight major industrial use sectors must provide the Agency with notice and the 

required health and safety information on the substitute at least 90 days before introducing it into 

interstate commerce for significant new use as an alternative. 40 CFR 82.176(a). While this 

requirement typically applies to chemical manufacturers as the person likely to be planning to 

introduce the substitute into interstate commerce,7it may also apply to importers, formulators, 

equipment manufacturers, or end users8 when they are responsible for introducing a substitute 

into commerce. The 90-day SNAP review process begins once EPA receives the submission and 

determines that the submission includes complete and adequate data. 40 CFR 82.180(a). The 

CAA and the SNAP regulations, 40 CFR 82.174(a), prohibit use of a substitute earlier than 90 

days after a complete submission has been provided to the Agency.

The Agency has identified four possible decision categories for substitute submissions: 

acceptable; acceptable, subject to use conditions; acceptable, subject to narrowed use limits; and 

unacceptable.940 CFR 82.180(b). Use conditions and narrowed use limits are both considered 

“use restrictions” and are explained below. Substitutes that are deemed acceptable without use 

 

7 As defined at 40 CFR 82.104, “interstate commerce” means the distribution or transportation of any product 

between one state, territory, possession or the District of Columbia, and another state, territory, possession or the 

District of Columbia, or the sale, use or manufacture of any product in more than one state, territory, possession or 

District of Columbia. The entry points for which a product is introduced into interstate commerce are the release of a 

product from the facility in which the product was manufactured, the entry into a warehouse from which the 

domestic manufacturer releases the product for sale or distribution, and at the site of United States Customs 

clearance.

8 As defined at 40 CFR 82.172, “end-use” means processes or classes of specific applications within major 

industrial sectors where a substitute is used to replace an ozone-depleting substance. 

9

The SNAP regulations also include “pending,” referring to submissions for which EPA has not reached a 

determination, under this provision.
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conditions can be used for all applications within the relevant sector end-uses and without limits 

under SNAP on how they may be used. Substitutes that are acceptable subject to use restrictions 

may be used only in accordance with those restrictions. Substitutes that are found to be 

unacceptable may not be used after the date specified in the rulemaking adding them to the list of 

unacceptable substitutes.10

After reviewing a substitute, the Agency may determine that a substitute is acceptable 

only if certain conditions in the way that the substitute is used are met to ensure risks to human 

health and the environment are not significantly greater than other substitutes. EPA describes 

such substitutes as “acceptable subject to use conditions.” Entities that use these substitutes 

without meeting the associated use conditions are in violation of CAA section 612 and EPA’s 

SNAP regulations. 40 CFR 82.174(c).

For some substitutes, the Agency may permit a narrow range of use within an end-use or 

sector. For example, the Agency may limit the use of a substitute to certain end-uses or specific 

applications within an industry sector. The Agency generally requires a user of a substitute 

subject to narrowed use limits to demonstrate that no other acceptable substitutes are available 

for their specific application.11 EPA describes these substitutes as “acceptable subject to 

narrowed use limits.” A person using a substitute that is acceptable subject to narrowed use 

 

10 As defined at 40 CFR 82.172, “use” means any use of a substitute for a class I or class II ozone-depleting 

compound, including but not limited to use in a manufacturing process or product, in consumption by the end-user, 

or in intermediate uses, such as formulation or packaging for other subsequent uses. This definition of use 

encompasses manufacturing process of products both for domestic use and for export. Substitutes manufactured 

within the United States exclusively for export are subject to SNAP requirements since the definition of use in the 

rule includes use in the manufacturing process, which occurs within the United States.

11 In the case of the July 20, 2015, final rule, EPA established narrowed use limits for certain substitutes over a 

limited period of time for specific MVAC and foam applications, on the basis that other acceptable alternatives 

would not be available for those specific applications within broader end-uses, but acceptable alternatives were 

expected to become available over time, e.g., after military qualification testing for foam blowing agents in military 

applications or after development of improved servicing infrastructure in a destination country for MVAC in 

vehicles destined for export.
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limits in applications and end-uses that are not consistent with the narrowed use limit is using 

these substitutes in violation of CAA section 612 and EPA’s SNAP regulations. 40 CFR 

82.174(c).

The section 612 mandate for EPA to prohibit the use of a substitute that may present risk 

to human health or the environment where a lower risk alternative is available or potentially 

available12 provides EPA with the authority to change the listing status of a particular substitute 

if such a change is justified by new information or changed circumstance. The Agency publishes 

its SNAP program decisions in the Federal Register. EPA uses notice-and-comment rulemaking 

to place any alternative on the list of prohibited substitutes, to list a substitute as acceptable only 

subject to use conditions or narrowed use limits, or to remove a substitute from either the list of 

prohibited or acceptable substitutes. 

In contrast, EPA publishes “notices of acceptability” to notify the public of substitutes 

that are deemed acceptable with no restrictions. As described in the preamble to the rule initially 

implementing the SNAP program (59 FR 13044; March 18, 1994), EPA does not believe that 

rulemaking procedures are necessary to list substitutes that are acceptable without restrictions 

because such listings neither impose any sanction nor prevent anyone from using a substitute

Many SNAP listings include “comments” or “further information” to provide additional 

information on substitutes. Since this additional information is not part of the regulatory 

decision, these statements are not binding for use of the substitute under the SNAP program. 

However, regulatory requirements so listed are binding under other regulatory programs (e.g., 

 

12 In addition to acceptable commercially available alternatives, the SNAP program may consider potentially 

available alternatives. The SNAP program’s definition of “potentially available” is “any alternative for which 

adequate health, safety, and environmental data, as required for the SNAP notification process, exist to make a 

determination of acceptability, and which the Agency reasonably believes to be technically feasible, even if not all 

testing has yet been completed and the alternative is not yet produced or sold.” (40 CFR 82.172)
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worker protection regulations promulgated by the U.S. Occupational Safety and Health 

Administration (OSHA)). The “further information” classification does not necessarily include 

all other legal obligations pertaining to the use of the substitute. While the items listed are not 

legally binding under the SNAP program, EPA encourages users of substitutes to apply all 

statements in the “further information” column in their use of these substitutes. In many 

instances, the information simply refers to sound operating practices that have already been 

identified in existing industry and/or building codes or standards. Thus, many of the statements, 

if adopted, would not require the affected user to make significant changes in existing operating

practices.

D. What are the guiding principles of the SNAP program?

The seven guiding principles of the SNAP program, elaborated in the preamble to the 

initial SNAP rule and consistent with section 612, are discussed below. 

 Evaluate substitutes within a comparative risk framework

The SNAP program evaluates the risk of alternative compounds compared to available or 

potentially available substitutes to the ozone depleting compounds which they are intended to 

replace. The risk factors that are considered include ozone depletion potential (ODP) as well as 

flammability, toxicity, occupational health and safety, and contributions to climate change and 

other environmental factors. 

 Do not require that substitutes be risk free to be found acceptable

Substitutes found to be acceptable must not pose significantly greater risk than other 

substitutes, but they do not have to be risk free. A key goal of the SNAP program is to promote 

the use of substitutes that minimize risks to human health and the environment relative to other 

alternatives. In some cases, this approach may involve designating a substitute acceptable even 
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though the compound may pose a risk of some type, provided its use does not pose significantly 

greater risk than other alternatives.

 Restrict those substitutes that are significantly worse

EPA does not intend to restrict a substitute if it has only marginally greater risk. Drawing 

fine distinctions would be extremely difficult. The Agency also does not want to intercede in the 

market’s choice of substitutes by listing as unacceptable all but one substitute for each end-use, 

and does not intend to restrict substitutes on the market unless a substitute has been proposed or 

is being used that is clearly more harmful to human health or the environment than other 

alternatives.

 Evaluate risks by use

Central to SNAP’s evaluations is the intersection between the characteristics of the 

substitute itself and its specific end-use application. Section 612 requires that substitutes be 

evaluated by use. Environmental and human health exposures can vary significantly depending 

on the particular application of a substitute. Thus, the risk characterizations must be designed to 

represent differences in the environmental and human health effects associated with diverse uses. 

This approach cannot, however, imply fundamental tradeoffs with respect to different types of 

risk to either the environment or to human health. 

 Provide the regulated community with information as soon as possible

The Agency recognizes the need to provide the regulated community with information on 

the acceptability of various substitutes as soon as possible. To do so, EPA issues notices or 

determinations of acceptability and rules identifying substitutes as unacceptable, acceptable to 

use conditions or acceptable subject to narrowed use limits in the Federal Register. In addition, 
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we maintain lists of acceptable and unacceptable alternatives on our website, 

www.epa.gov/ozone/snap.

 Do not endorse products manufactured by specific companies

The Agency does not issue company-specific product endorsements. In many cases, the 

Agency may base its analysis on data received on individual products, but the addition of a 

substitute to the acceptable list based on that analysis does not represent an endorsement of that 

company’s products. 

 Defer to other environmental regulations when warranted

In some cases, EPA and other federal agencies have developed extensive regulations 

under other sections of the CAA or other statutes that address potential environmental or human 

health effects that may result from the use of alternatives to class I and class II substances. For 

example, use of some substitutes may in some cases entail increased use of chemicals that 

contribute to tropospheric air pollution. The SNAP program takes existing regulations under 

other programs into account when reviewing substitutes. 

E. What are EPA’s criteria for evaluating substitutes under the SNAP 

program?

EPA applies the same criteria for determining whether a substitute is acceptable or 

unacceptable. These criteria, which can be found at §82.180(a)(7), include atmospheric effects 

and related health and environmental effects, ecosystem risks, consumer risks, flammability, and 

cost and availability of the substitute. To enable EPA to assess these criteria, we require 

submitters to include various information including ODP, GWP, toxicity, flammability, and the 

potential for human exposure. 

When evaluating potential substitutes, EPA evaluates these criteria in the following 
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groupings: 

 Atmospheric effects- The SNAP program evaluates the potential contributions to both 

ozone depletion and climate change. The SNAP program considers the ozone depletion potential 

and the 100-year integrated GWP of compounds to assess atmospheric effects. 

 Exposure assessments-The SNAP program uses exposure assessments to estimate 

concentration levels of substitutes to which workers, consumers, the general population, and the 

environment may be exposed over a determined period of time. These assessments are based on

personal monitoring data or area sampling data if available. Exposure assessments may be 

conducted for many types of releases including: 

1) Releases in the workplace and in homes; 

2) Releases to ambient air and surface water; 

3) Releases from the management of solid wastes. 

 Toxicity data- The SNAP program uses toxicity data to assess the possible health and 

environmental effects of exposure to substitutes. We use broad health-based criteria such as: 

1) Permissible Exposure Limits (PELs) for occupational exposure; 

2) Inhalation reference concentrations (RfCs) for non-carcinogenic effects on the 

general population; 

3) Cancer slope factors for carcinogenic risk to members of the general population. 

When considering risks in the workplace, if OSHA has not issued a PEL for a compound, 

EPA then considers Recommended Exposure Limits from the National Institute for Occupational 

Safety and Health (NIOSH), Workplace Environmental Exposure Limits (WEELs) set by the 

American Industrial Hygiene Association (AIHA), or threshold limit values (TLVs) set by the 

American Conference of Governmental Industrial Hygienists (ACGIH). If limits for 
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occupational exposure or exposure to the general population are not already established, then 

EPA derives these values following the Agency’s peer reviewed guidelines. Exposure 

information is combined with toxicity information to explore any basis for concern. Toxicity data 

are used with existing EPA guidelines to develop health-based limits for interim use in these risk 

characterizations.

 Flammability-The SNAP program examines flammability as a safety concern for 

workers and consumers. EPA assesses flammability risk using data on: 

1) Flash point and flammability limits (e.g., ASHRAE flammability/combustibility 

classifications); 

2) Data on testing of blends with flammable components; 

3) Test data on flammability in consumer applications conducted by independent 

laboratories; and 

4) Information on flammability risk mitigation techniques. 

 Other environmental impacts- The SNAP program also examines other potential 

environmental impacts like ecotoxicity and local air quality impacts. A compound that is likely 

to be discharged to water may be evaluated for impacts on aquatic life. Some substitutes are 

volatile organic compounds (VOC). EPA also notes whenever a potential substitute is considered 

a hazardous or toxic air pollutant (under CAA sections 112 (b) and 202 (l)) or hazardous waste 

under the Resource Conservation and Recovery Act (RCRA) subtitle C regulations. 

EPA’s consideration of cost in listing decisions is limited to evaluating the cost of the 

substitute under review pursuant to section 82.180(a)(7)(vii). This is distinct from consideration 

of costs associated with the use of other alternatives to which the substitute is being compared. 

See Honeywell v. EPA, 374 F.3d 1363 (D.C. Cir. 2004) at 1,378 (J. Rogers, concurring in part 
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and dissenting in part) (“While the SNAP regulations make the ‘cost and availability of the 

substitute’ an element of acceptability . . . that concern is limited to whether EPA ‘has . . . reason 

to prohibit its use,’ not to whether cleaner alternatives for the substance are already ‘currently or 

potentially available’. . . . Consideration of transition costs is thus precluded by the SNAP 

regulations as currently written, irrespective of whether it might be permitted under CAA § 

612(c) . . . .”).

Over the past twenty years, the menu of substitutes has become much broader and a great 

deal of new information has been developed on many substitutes. Because the overall goal of the 

SNAP program is to ensure that substitutes listed as acceptable do not pose significantly greater 

risk to human health and the environment than other substitutes, the SNAP criteria continue to be 

informed by our current overall understanding of environmental and human health impacts and 

our experience with and current knowledge about alternatives. Over time, the range of substitutes 

reviewed by SNAP has changed, and, at the same time, scientific approaches have evolved to 

more accurately assess the potential environmental and human health impacts of these chemicals 

and alternative technologies. 

F. How are SNAP determinations updated?

Three mechanisms exist for modifying the list of SNAP determinations. First, under 

section 612(d), the Agency must review and either grant or deny petitions to add or delete 

substances from the SNAP list of acceptable or unacceptable substitutes. That provision allows 

any person to petition the Administrator to add a substance to the list of acceptable or 

unacceptable substitutes or to remove a substance from either list. The second means is through

the notifications which must be submitted to EPA 90 days before introduction of a substitute into 

interstate commerce for significant new use as an alternative to a class I or class II substance. 
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These 90-day notifications are required by CAA section 612(e) for producers of substitutes to 

class I substances for new uses and, in all other cases, by EPA regulations issued under sections 

114 and 301 of the Act to implement section 612(c).

Finally, since the inception of the SNAP program, we have interpreted the section 612 

mandate to find substitutes acceptable or unacceptable to include the authority to act on our own 

to add or remove a substance from the SNAP lists (59 FR 13044, 13047; March 18, 1994). In 

determining whether to add or remove a substance from the SNAP lists, we consider whether 

there are other alternatives that pose lower overall risk to human health and the environment. In 

determining whether to modify a listing of a substitute we undertake the same consideration, but 

do so in the light of new data that may not have been available at the time of our original listing 

decision, including information on substitutes that were not included in our comparative review 

at the time of our initial listing decision and new information on substitutes previously reviewed.

G. What does EPA consider in deciding whether to modify the listing status of 

an alternative?

As described in this document and elsewhere, including in the initial SNAP rule 

published in the Federal Register on March 18, 1994 (59 FR 13044), CAA section 612 requires 

EPA to list as unacceptable any substitute substance where it finds that there are other 

alternatives that reduce overall risk to human health and the environment. The initial SNAP rule 

included submission requirements and presented the environmental and health risk factors that 

the SNAP program considers in the comparative risk framework it uses to determine whether 

there are other alternatives that pose significantly lower risk than the substitute under review. 

EPA makes decisions based on the particular end-use where a substitute is to be used. EPA has, 

in many cases, found certain substitutes acceptable only for limited end-uses or subject to use 
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restrictions. 

It has now been over twenty years since the initial SNAP rule was promulgated. When 

the SNAP program began, the number of substitutes available for consideration was, for many 

end-uses, somewhat limited. Thus, while the SNAP program’s initial comparative assessments of 

overall risk to human health and the environment were rigorous, often there were few substitutes 

upon which to apply the comparative assessment. The immediacy of the class I phaseout often 

meant that EPA listed class II ODS (i.e., HCFCs) as acceptable, recognizing that they too would 

be phased out and, at best, could offer an interim solution. Other Title VI provisions such as the 

section 610 Nonessential Products Ban and the section 605 Use Restriction made clear that a 

listing under the SNAP program could not convey permanence. 

Since EPA issued the initial SNAP rule in 1994, the Agency has issued 20 rules and 30 

notices that generally expand the menu of options for the various SNAP sectors and end-uses. 

Thus, comparisons today apply to a broader range of alternatives – both chemical and nonchemical – than at the inception of the SNAP program. Industry experience with these substitutes 

has also grown during the history of the program. 

In addition to an expanding menu of substitutes, developments over the past 20 years 

have improved our understanding of global environmental issues. With regard to that 

information, our review of substitutes in this rule includes comparative assessments that consider 

our evolving understanding of a variety of factors. For example, GWPs and climate effects are

not new elements in our evaluation framework, but as is the case with all of our review criteria, 

the amount of information has expanded and the quality has improved. 

To the extent possible, EPA’s ongoing management of the SNAP program considers new 

information, including new substitutes, and improved understanding of the risk to the 
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environment and human health. EPA previously has taken several actions revising listing 

determinations from acceptable or acceptable with use conditions to unacceptable. On January 

26, 1999, EPA listed the refrigerant blend known by the trade name MT-31 as unacceptable for 

all refrigeration and AC end-uses for which EPA had previously listed this blend as an 

acceptable substitute (62 FR 30275; June 3, 1997). EPA based this decision on new information 

about the toxicity of one of the chemicals in the blend. 

Another example of EPA revising a listing determination occurred in 2007, when EPA 

listed HCFC–22 and HCFC–142b as unacceptable for use in the foam sector (72 FR 14432; 

March 28, 2007). These HCFCs, which are ozone depleting and subject to a global production 

phaseout, were initially listed as acceptable substitutes since they had a lower ODP than the 

substances they were replacing and there were no other alternatives that posed lower overall risk 

at the time of EPA’s listing decision. HCFCs offered a path forward for some sectors and enduses at a time when the number of substitutes was far more limited. In light of the expanded 

availability of other alternatives with lower overall risk to human health and the environment in 

specific foam end-uses, and taking into account the 2010 class II ODS phase-down step, EPA 

changed the listing for these HCFCs in relevant end-uses from acceptable to unacceptable. In 

that rule, EPA noted that continued use of these HCFCs would contribute to unnecessary 

depletion of the ozone layer and delay the transition to substitutes that pose lower overall risk to 

human health and the environment. EPA established a change of status date that recognized that 

existing users needed time to adjust their manufacturing processes to safely accommodate the 

use of other substitutes. 

In a final rule published on July 20, 2015 (80 FR 42870), various HFCs and HFCcontaining blends that were previously listed as acceptable under the SNAP program were listed 
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as unacceptable in various end-uses in the aerosols, foam blowing, and refrigeration and AC 

sectors where there are other alternatives that pose lower overall risk to human health and the 

environment for specific uses. The July 2015 rule also changed the status from acceptable to 

unacceptable for certain HCFCs being phased out of production under the Montreal Protocol on 

Substances that Deplete the Ozone Layer and CAA section 605(a). Per the guiding principles of 

the SNAP program, the July 2015 rule did not specify that any HFCs or HCFCs are unacceptable 

across all sectors and end-uses. Instead, in all cases, EPA considered the intersection between the 

specific substitute and the particular end-use and the availability of substitutes for those 

particular end-uses when making its determinations.

H. Where can I get additional information about the SNAP program?

For copies of the comprehensive SNAP lists of substitutes or additional information on 

SNAP, refer to EPA’s website at www.epa.gov/ozone/snap. For more information on the 

Agency’s process for administering the SNAP program or criteria for evaluation of substitutes, 

refer to the initial SNAP rule published March 18, 1994 (59 FR 13044), codified at 40 CFR part 

82 subpart G. A complete chronology of SNAP decisions and the appropriate citations are found 

at www.epa.gov/ozone/snap/chron.html.

III. What actions and information related to greenhouse gases have bearing on this 

proposed action?

GWP is one of several criteria EPA considers in the overall evaluation of alternatives 

under the SNAP program. During the past two decades, the general science on climate change 

and the potential contributions of greenhouse gases (GHGs) such as HFCs to climate change 

have become better understood. 

On December 7, 2009, at 74 FR 66496, the Administrator issued an endangerment 
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finding determining that, for purposes of CAA section 202(a), the current and projected 

concentrations of the six key well-mixed greenhouse gases in the atmosphere — CO2, methane 

(CH4), nitrous oxide (N2O), HFCs, PFCs, and sulfur hexafluoride (SF6) — threaten the public 

health and welfare of current and future generations.13

Like the ODS they replace, HFCs are potent GHGs (IPCC/TEAP, 2005). Although they 

represent a small fraction of the current total volume of GHG emissions, their warming impact is 

very strong. While GHGs such as CO2 and CH4 are unintentional byproducts from industrial 

activities and mobile source emissions, HFCs are intentionally produced chemicals. The most 

commonly used HFC is HFC-134a. HFC-134a is 1,430 times more damaging to the climate 

system than CO2. Because of their role in replacing ODS, both in the United States and globally, 

and because of the increasing use of refrigeration and AC, HFC emissions are projected to 

increase substantially and at an increasing rate over the next several decades if left unregulated. 

In the United States, emissions of HFCs are increasing more quickly than those of any other 

GHGs, and globally they are increasing 10-15 percent annually (UNEP, 2011). At that rate, 

emissions are projected to double by 2020 and triple by 2030 (Akerman, 2013). HFCs are rapidly 

accumulating in the atmosphere. The atmospheric concentration of HFC-134a, the most 

abundant HFC, has increased by about 10 percent per year from 2006 to 2012, and the 

concentrations of HFC-143a and HFC-125 have risen over 13 percent and 16 percent per year 

from 2007-2011, respectively (Montzka, 2012).

14

Annual global emissions of HFCs are projected to rise to about 6.4 to 9.9 gigatons of CO2

equivalent (GtCO2eq) in 2050 (Velders et al., 2009), which is comparable to the drop in annual 

 

13 The relevant scientific and technical information summarized to support the Endangerment Finding and the Cause 

or Contribute Finding can be found at: 

www.epa.gov/climatechange/Downloads/endangerment/Endangerment_TSD.pdf.

14 NOAA data at ftp://ftp.cmdl.noaa.gov/hats/hfcs/.
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GHG emissions from ODS of 8.0 GtCO2eq between 1988 and 2010 (UNEP, 2011). By 2050, the 

buildup of HFCs in the atmosphere is projected to increase radiative forcing by up to 0.4 W m‐2. 

This increase may be as much as one-fifth to one-quarter of the expected increase in radiative 

forcing due to the buildup of CO2 since 2000, according to the Intergovernmental Panel on 

Climate Change’s (IPCC’s) Special Report on Emissions Scenarios (SRES) (UNEP, 2011). To 

appreciate the significance of the effect of projected HFC emissions within the context of all 

GHGs, HFCs would be equivalent to five to 12 percent of the CO2 emissions in 2050 based on 

the IPCC’s highest CO2 emissions scenario and equivalent to 27 to 69 percent of CO2 emissions 

based on the IPCC’s lowest CO2 emissions pathway (UNEP, 2011; IPCC, 2013). Additional 

information concerning the peer-reviewed scientific literature and emission scenarios is available 

in the docket for this rulemaking (EPA-HQ-OAR-2015-0663). Today’s notice of proposed 

rulemaking (NPRM) includes status change proposals for certain HFCs or HFC blends in 

specific refrigeration and AC end-uses and in rigid polyurethane spray foam.

PFCs are potent GHGs and have very long atmospheric lifetimes. PFCs are produced as a 

byproduct of various industrial processes associated with aluminum production and the 

manufacturing of semiconductors, then captured for intentional use or manufactured for use in 

various industrial applications. PFCs have had limited use in the eight sectors regulated under 

SNAP. This action includes status change proposals for certain PFCs in fire suppression total 

flooding and streaming uses. 

IV. What petitions has EPA received requesting a change in listing status for HFCs?

A. Summary of petitions

EPA recently received two petitions requesting EPA to modify certain acceptability 

listings of high-GWP substances in various end-uses. The petitions were both submitted on 
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October 6, 2015. The first was submitted by the Natural Resource Defense Council (NRDC) and 

the Institute for Governance and Sustainable Development (IGSD) and the second by the 

Environmental Investigation Agency (EIA) (NRDC/IGSD, 2015; EIA, 2015). Today’s proposal 

is relevant to certain aspects of these petitions. 

The NRDC and IGSD petition requests that EPA change the listing status of certain highGWP chemicals they believe are used most frequently in the United States in various end-uses in 

the refrigeration and AC, foam blowing, and fire suppression and explosion protection sectors. 

The EIA petition requests that EPA list additional high-GWP HFCs as unacceptable or 

acceptable, subject to use restrictions, in a number of end-uses in the refrigeration and AC, and 

fire suppression and explosion protection sectors. EIA requests that the schedule for changing the 

status of the substances listed in their petition be based on a three tiered approach: 1) January 1, 

2017, or one year following the passage of a final rule for SF6, HFC-23, and HFC-23 blends R508A and R-508B; 2) January 1, 2019, for all chemicals with a GWP greater than 3,000 (e.g., 

includes HFC-236fa, HFC-227ea, HFC-507A, and HFC-404A) in all remaining stationary 

refrigeration end-uses; and 3) January 1, 2022, for all remaining substitutes with GWPs higher 

than 1,000, including HFC-134a, R-410A. In support of their petitions, the petitioners identified 

other alternatives they claimed are available for use in the specified end-uses. NRDC and IGSD 

stated that these other alternatives “possess similar thermodynamic characteristics” and “can 

achieve equal or greater energy efficiency in hardware design” compared to the substances they 

request the Agency list as unacceptable. The petitions are available in the docket for this 

rulemaking. While EPA has not found these petitions complete at this time, today’s proposal 

addresses certain aspects of the petitions as described in section I.A and further discussed below. 
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Parts of two other previously submitted SNAP petitions that EPA found to be incomplete

are also relevant to this rulemaking. In a petition EIA submitted to EPA on April 26, 2012, EIA 

stated that, “in light of the comparative nature of the SNAP program’s evaluation of substitutes

and given that other acceptable substitutes are on the market or soon to be available,” EPA 

should “remove HFC-134a and HFC-134a blends from the list of acceptable substitutes for any 

ozone depleting substance in any non-essential uses under EPA’s SNAP program.” Additionally, 

NRDC, EIA, and IGSD filed a petition on April 27, 2012, requesting that EPA remove HFC134a from the list of acceptable substitutes in household refrigerators and freezers, and standalone retail food refrigerators and freezers, among other things. On August 7, 2013, EPA found 

both petitions to be incomplete. 

B. How this action relates to the Climate Action Plan and petitions

This action is consistent with a provision in the President’s CAP announced June 2013:

“Moving forward, the Environmental Protection Agency will use 

its authority through the Significant New Alternatives Policy 

Program to encourage private sector investment in low-emissions 

technology by identifying and approving climate-friendly 

chemicals while prohibiting certain uses of the most harmful 

chemical alternatives.”

The CAP further states: “to reduce emissions of HFCs, the United States can and will 

lead both through international diplomacy as well as domestic actions.” This rule is also 

consistent with that call for leadership through domestic actions. As regards international 

leadership, for the past six years, the United States, Canada, and Mexico have proposed an 

amendment to the Montreal Protocol to phase down the production and consumption of HFCs. 
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Global benefits of the amendment proposal would yield significant reductions in emissions of 

over 90 GtCO2eq through 2050. 

This action also addresses certain aspects of the various petitions referred to above in 

section IV.A. While the two recent petitions have not been found complete and earlier petitions 

have been found incomplete, EPA possesses sufficient information to propose action on some of 

the end-uses covered by the petitions. EPA’s action is responsive to certain aspects of the 

petitions that relate to the refrigeration and AC, foam blowing, and fire suppression and 

explosion protection sectors; EPA is proposing to change the listing from acceptable to 

unacceptable for: 

 HFC-134a in new centrifugal chillers, new household refrigerators and freezers, and 

rigid PU spray foam; 

 R-404A, R-410A, and R-410B in new centrifugal chillers, new household 

refrigerators and freezers, and new cold storage warehouses; 

 R-407A in new cold storage warehouses; 

 R-421A, R-422B, R-422C, R-422D, R-424A, and R-434A in new centrifugal chillers; 

R-507A in new centrifugal chillers and new cold storage warehouses; 

 HFC-227ea in new cold storage warehouses; 

 HFC-245fa, HFC-365mfc, and HFC-227ea in new centrifugal chillers and rigid PU 

spray foam; 

 PFCs (i.e., C3F8 and C4F10,) for total flooding applications; and a number of 

refrigerant blends with higher GWPs in certain new refrigeration and AC equipment. 

EPA is also requesting comment and updated information on total flooding uses of SF6

and HFC-23 as fire suppressants.

Commented [A6]: The commenting agency is not aware of any 

products for household refrigerators and freezers that are using R404A, R410A, and R-410B refrigerants. Is EPA aware of any 

products or manufacturers that are still using these products? 

If in fact there are no household refrigerators and freezers using 

these refrigerants, EPA should not be claiming any benefits (tons or 

monetized). Please confirm.
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Throughout the process of our discussions with the regulated community, we have sought 

to convey our continued understanding of the role that certainty plays in enabling the robust 

development and uptake of alternatives. As noted above, some of the key strengths of the SNAP 

program, such as its substance and end-use specific consideration, its multi-criteria basis for 

action, and its petition process, tend to militate against measures some have advocated could 

provide more certainty, such as setting specific numerical criteria for environmental evaluations 

(e.g., all compounds with GWP greater than 150). That said, we believe that the action we are 

taking today does provide additional certainty in the specific cases addressed. In addition, we 

remain committed to continuing to actively seek stakeholder views and to share our thinking at 

the earliest moment practicable on any future actions, as part of our commitment to provide 

greater certainty to producers and consumers in SNAP-regulated industrial sectors.

V. How does EPA regulate substitute refrigerants under CAA section 608?

A. What are the statutory requirements concerning venting, release, or 

disposal of refrigerants and refrigerant substitutes under CAA section 608? 

The statutory requirements concerning venting, release, or disposal of refrigerants and 

refrigerant substitutes are under CAA section 608, and EPA's authority to promulgate the 

regulatory revisions in this action is based in part on CAA section 608. Section 608 of the Act as 

amended, titled National Recycling and Emission Reduction Program, requires, among other 

things, that EPA establish regulations governing the use and disposal of ODS used as 

refrigerants, such as certain CFCs and HCFCs, during the service, repair, or disposal of 

appliances and industrial process refrigeration (IPR). Section 608(c)(1) provides that it is 

unlawful for any person, in the course of maintaining, servicing, repairing, or disposing of an 

appliance (or IPR), to knowingly vent, or otherwise knowingly release or dispose of, any class I 
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or class II substance used as a refrigerant in that appliance (or IPR) in a manner which permits 

the ODS to enter the environment. 

Section 608(c)(1) further exempts from this self-effectuating prohibition de minimis

releases associated with good faith attempts to recapture and recycle or safely dispose of such a 

substance. EPA, as set forth in its regulations, interprets releases to meet the criteria for 

exempted de minimis releases if they occur when the recycling and recovery requirements of 

specified regulations promulgated under sections 608 and 609 are followed. 40 CFR 

82.154(a)(2).

Section 608(c)(2) extends the prohibition in section 608(c)(1) to knowingly venting or 

otherwise knowingly releasing or disposing of any refrigerant substitute for class I or class II 

substances by any person maintaining, servicing, repairing, or disposing of appliances or IPR. 

This prohibition applies to any substitute unless the Administrator determines that such venting, 

releasing, or disposing does not pose a threat to the environment. Thus, section 608(c) provides 

EPA authority to promulgate regulations to interpret, implement, and enforce this prohibition on 

venting, releasing, or disposing of class I or class II substances and their refrigerant substitutes, 

which we refer to as the “venting prohibition” in this action. EPA’s authority under section 

608(c) includes authority to implement section 608(c)(2) by exempting certain substitutes for 

class I or class II substances from the venting prohibition when the Administrator determines that 

such venting, release, or disposal does not pose a threat to the environment.

B. What are EPA’s regulations concerning venting, releasing, or disposal of 

refrigerant substitutes?

Regulations promulgated under CAA section 608, published on May 14, 1993 (58 FR 

28660), established a recycling program for ozone-depleting refrigerants recovered during the 
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servicing and maintenance of refrigeration and AC appliances. In the same 1993 rule, EPA also 

promulgated regulations implementing the section 608(c) prohibition on knowingly venting, 

releasing, or disposing of class I or class II controlled substances. These regulations were 

designed to substantially reduce the use and emissions of ozone-depleting refrigerants.

EPA issued a final rule on March 12, 2004 (69 FR 11946) and a second rule on April 13, 

2005 (70 FR 19273) clarifying how the venting prohibition in section 608(c) applies to 

substitutes for CFC and HCFC refrigerants (e.g., HFCs and PFCs) during the maintenance, 

service, repair, or disposal of appliances. These regulations are codified at 40 CFR part 82, 

subpart F. In relevant part, they provide that no person maintaining, servicing, repairing, or 

disposing of appliances may knowingly vent or otherwise release into the environment any 

refrigerant or substitute from such appliances, with the exception of the certain specified 

substitutes in the specified end-uses, as provided in 40 CFR 82.154(a).

As explained in an earlier EPA rulemaking concerning refrigerant substitutes, EPA has 

not promulgated regulations requiring certification of refrigerant recycling/recovery equipment 

intended for use with substitutes to date (70 FR 19275; April 13, 2005). The Agency has recently 

proposed, but not yet finalized, regulations to address certification of such equipment used to 

recover and/or recycle refrigerants that are not exempt from the venting prohibition (80 FR 

69458; November 9, 2015). However, as EPA has noted, the lack of a current regulatory 

provision should not be considered as an exemption from the venting prohibition for substitutes 

that are not expressly exempted in section 82.154(a) (80 FR 69466, 69478). EPA has also noted 

that, in accordance with section 608(c) of the Act, the regulatory prohibition at section 82.154(a) 

reflects the statutory references to de minimis releases of substitutes as they pertain to good faith 

attempts to recover and recycle or safely dispose of non-exempted substitutes but does not 
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provide clear guidance about what constitutes such a “good faith attempt” for substitutes. (80 FR 

69470).

On May 23, 2014 (79 FR 29682), EPA exempted from the venting prohibition three HC

refrigerant substitutes listed as acceptable, subject to use conditions, in the specified end-uses: 

isobutane and R–441A, as refrigerant substitutes in household refrigerators, freezers, and 

combination refrigerators and freezers; and propane as a refrigerant substitute in retail food 

refrigerators and freezers (stand-alone units only). Similarly, on April 10, 2015 (80 FR 19453), 

EPA exempted from the venting prohibition four HC refrigerant substitutes listed as acceptable, 

subject to use conditions, in the specified end-uses: isobutane and R–441A, in retail food 

refrigerators and freezers (stand-alone units only); propane in household refrigerators, freezers, 

and combination refrigerators and freezers; ethane in very low temperature refrigeration 

equipment and equipment for non-mechanical heat transfer; R-441A, propane, and isobutane in 

vending machines; and propane and R-441A in self-contained room air conditioners for 

residential and light commercial AC and heat pumps. Those regulatory exemptions do not apply 

to blends of HCs with other refrigerants or containing any amount of any CFC, HCFC, HFC, or 

PFC.

In those actions, EPA determined that for the purposes of CAA section 608(c)(2), the 

venting, release, or disposal of such HC refrigerant substitutes in the specified end-uses does not 

pose a threat to the environment, considering both the inherent characteristics of these substances 

and the limited quantities used in the relevant applications. EPA further concluded that other 

authorities, controls, or practices that apply to such refrigerant substitutes help to mitigate 

environmental risk from the release of those HC refrigerant substitutes. 

C. What did EPA recently propose regarding management of refrigerant
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substitutes under CAA section 608?

In addition to the prohibition on knowingly releasing ozone-depleting and substitute 

refrigerants during the maintenance, service, repair, and disposal of appliances, the existing 

regulations established under CAA section 608 require that persons servicing or disposing of airconditioning and refrigeration equipment observe certain service practices that reduce emissions 

of ozone-depleting refrigerant. The current regulatory provisions only apply to ozone-depleting 

refrigerants and appliances containing ozone-depleting refrigerants. The current requirements 

include: requiring that technicians be certified to work on appliances; restricting the sale of 

refrigerant to certified technicians; specifying the proper evacuation levels before opening up an 

appliance; requiring the use of certified refrigerant recovery and/or recycling equipment; 

requiring the maintenance and repair of appliances that meet certain size and leak rate thresholds; 

requiring that refrigerants be removed from appliances prior to disposal; requiring that airconditioning and refrigeration equipment be provided with a servicing aperture or process stub to 

facilitate refrigerant recovery; requiring that refrigerant reclaimers be certified in order to reclaim 

and sell used refrigerant; and establishing standards for technician certification programs, 

recovery equipment, and quality of reclaimed refrigerant. 

On November 9, 2015 (80 FR 69457), EPA proposed to update these existing 

requirements found in 40 CFR part 82, subpart F that currently apply to ozone-depleting 

refrigerants and then to generally extend those requirements, as appropriate, to non-ozonedepleting substitute refrigerants, including but not limited to HFCs and PFCs. However, as 

proposed, the rule requirements would not extend to substitute refrigerants that are exempt from 

the venting prohibition. This proposed rule would also streamline the regulations at 40 CFR part 
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82, subpart F to improve clarity. For more information on this proposed rule, see docket EPAHQ-OAR-2015-0453.

VI. What is EPA proposing in this action?

EPA is proposing to list certain newly submitted alternatives as acceptable, subject to use

conditions, and other newly submitted alternatives as unacceptable. EPA is also proposing to 

modify the listings from acceptable to acceptable, subject to narrowed use limits, or to 

unacceptable for certain alternatives in various end-uses in the refrigeration and AC, foam 

blowing, and fire suppression and explosion protection sectors. In each instance where EPA is 

proposing to list a newly submitted substitute as unacceptable or is changing the status of a 

substitute from acceptable to unacceptable, EPA has determined that there are other alternatives 

that pose lower overall risk to human health and the environment. EPA is also proposing that the 

existing listing decisions for foam blowing agents apply to closed cell foam products and 

products containing closed cell foam. See section VI.C.3 for the details of this proposal.

Additionally, EPA is proposing The emissions that would be avoided from the proposed changes 

of status in this action are estimated to be approximately 5.7 to 6.9 MMTCO2eq in 2025 and

approximately 10.1 to 11.6 MMTCO2eq in 2030 (EPA, 2016a).

In each listing decision, EPA is considering the intersection between the specific 

alternative and the particular end-use, per the guiding principles stated above. This action does 

not propose that any specific alternative is acceptable or unacceptable across all sectors and enduses. EPA is also not proposing that, for any specific sector, the only acceptable substitutes are 

non-fluorinated. EPA recognizes that both fluorinated (e.g., HFCs, HFOs) and non-fluorinated 

(e.g., HCs, CO2) substitutes may pose lower overall risk to human health and the environment, 

depending on the particular use.

Commented [A7]: Please complete sentence.
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Change of listing status

In determining whether to modify the previous listing decisions for substitutes based on 

whether other alternatives are available that pose lower risk to human health and the 

environment, we considered, among other things: scientific findings, information provided by the 

Technology and Economic Assessment Panel (TEAP) that supports the Montreal Protocol, 

journal articles, submissions to the SNAP program, the regulations and supporting dockets for 

other EPA rulemakings, presentations and reports presented at domestic and international 

conferences, and materials from trade associations and professional organizations. The materials 

on which we have relied may be found in the docket for this rulemaking (EPA-HQ-OAR-2015-

0663). Key references are highlighted in section VIII of today’s notice.

Change of status dates

Here, as in the July 20, 2015, final rule, the proposed change of status dates are based 

upon EPA’s understanding of the availability of alternatives, considering factors such as 

commercial availability and supply of alternatives, time required to work through technical 

challenges with using alternatives, and time required to meet other federal regulatory 

requirements with redesigned equipment or formulations.

Consideration of costs

Under the SNAP criteria for review in 40 CFR 82.180(a)(7), consideration of cost is 

limited to cost of the substitute under review, and that consideration does not include the cost of 

transition when a substitute is found unacceptable. EPA requires information on cost and 

availability of substitutes as part of SNAP submissions in order to judge how widely a substitute 

might be used, and therefore, what its potential environmental and health effects might be. The 

SNAP criteria do not identify other cost considerations and thus we have not historically used 
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cost information independent of environmental and health effects to determine the acceptability 

of substitutes under review—that is, we have never determined a substitute under review to be 

unacceptable or acceptable on the basis of its cost. When considering a change of status for 

substitutes already listed as acceptable, the SNAP program has not considered the costs of 

transition as part of determining the status of the substitute or the availability of other 

alternatives for the same uses. 

We are not addressing in this rulemaking whether to revise the regulatory criteria to 

include an expanded role for the consideration of costs in SNAP listing decisions. We have 

simply applied the existing regulatory criteria in determining whether to change the listing status 

of the substitutes addressed in this action. 

Nevertheless, EPA has estimated the costs of the proposed changes of status in this action 

in order to provide information to the public and to meet various statutory and executive order 

requirements. We have estimated costs for applicable NAICS codes in a document titled, 

“Preliminary Cost Analysis for Regulatory Changes to the Listing Status of High-GWP 

Alternatives used in Refrigeration and Air Conditioning, Foams, and Fire Suppression” (ICF, 

2015a).” In addition, we have analyzed costs and impacts on small businesses in a document 

titled, “Draft Economic Impact Screening Analysis for Regulatory Changes to the Listing Status 

of High-GWP Alternatives used in Refrigeration and Air Conditioning, Foams, and Fire 

Suppression (ICF, 2015b). Based upon these analyses, EPA does not expect this rule to have 

major economic impacts (greater than $100 million per year) or to have a significant impact on a 

substantial number of small entities, if it is finalized as proposed. 

Narrowed use limits

EPA notes that it may be reasonable for several of the end-uses to be broken down 
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further. Consistent with previous practice and as EPA is proposing in certain instances in this 

proposal, EPA could consider adopting temporary narrowed use limits for a specific application

within an end-use if the Agency determined that substitutes would be available for all but that 

specific application as of a particular date. In that case, for applications in that end-use not 

covered by the narrowed use limit, the rule would list the substitute as unacceptable as of that 

date. For the specific application at issue, the rule could contain both a temporary narrowed use 

limit with an expiration date and a listing as unacceptable upon the expiration of the narrowed 

use limit. Any end user within the covered application would need to comply with the 

requirement to analyze and document that there are no other alternatives that are technically 

feasible for their specific end-use in order to use the substitute identified in the narrowed use 

limit. 

Requests for comment

EPA requests comment on all aspects of this proposal, including proposed decisions to 

list additional substitutes as acceptable in certain end uses, to list new substitutes as unacceptable 

in certain end uses and to change the listing status of certain substitutes from acceptable to

unacceptable, subject to narrowed use limits or unacceptable, and the dates when the change of 

status would apply to users of these substitutes. EPA is particularly interested in information 

concerning whether the supply of substitutes is sufficient to meet the dates proposed in this 

action or whether there are technical challenges in meeting a proposed change of status date.

EPA is also interested in whether EPA should adopt a temporary narrowed use limit for a 

specific application of an end-use in the final rule. In such a case, the commenter should explain 

why other alternatives would not be available for the specific application of that end-use and for 

what period of time. EPA is also requesting comments on the determination that the SNAP 
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listing decisions for foam blowing agents would apply to closed cell foam products and products 

containing closed cell foam that are manufactured or imported after one year after publication of 

a final rule. In addition, EPA is requesting comments on its proposed decision regarding the 

venting prohibition under section 608. More specific requests for comment are included with the 

discussion of each of the proposed decisions. 

A. Retail food refrigeration and stationary AC

1. Proposed listing of propane as acceptable, subject to use conditions, for 

commercial ice machines, water coolers, and very low temperature refrigeration 

equipment

EPA is proposing to list propane (R-290) as acceptable, subject to use conditions, as a 

refrigerant in new self-contained commercial ice machines, in new water coolers, and in new 

very low temperature refrigeration equipment. The proposed use conditions include conditions 

requiring conformity with industry standards, limits on charge size, and requirements for 

warnings and markings on equipment. The use conditions are detailed below in section VI.A.1.c, 

“What are the proposed use conditions?”

a. What are the affected end–uses?

Commercial ice machines are used in commercial establishments to produce ice for 

consumer use, such as in hotels, restaurants, and convenience stores. Many commercial ice 

machines are self-contained units, while some have the condenser separated from the portion of 

the machine making the ice and have refrigerant lines running between the two. The proposed 

listing applies only to self-contained commercial ice machines. 

Water coolers are self-contained units providing chilled water for drinking. They may or 

may not feature detachable containers of water. 
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Very low temperature refrigeration equipment is intended to maintain temperatures 

considerably lower than for refrigeration of food—generally, -80 °C (-170 °F) or lower. In some 

cases, very low temperature refrigeration equipment may use a refrigeration system with two 

refrigerant loops containing different refrigerants or with a direct expansion (DX) refrigeration 

loop coupled with an alternative refrigeration technology (e.g., Stirling cycle).

b. How does propane compare to other refrigerants for these end–uses 

with respect to SNAP criteria?

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks (e.g., 

flammability, exposure, and toxicity) are discussed below. In addition, a technical support 

document that provides the Federal Register citations concerning data on the SNAP criteria (e.g., 

ODP, GWP, VOC, toxicity, flammability) for acceptable alternatives in the relevant end-uses 

may be found in the docket for this rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015a).

i. Environmental impacts

The ODP is the ratio of the impact on stratospheric ozone of a substance compared to the 

impact of an identical mass of CFC–11. Thus, the ODP of CFC–11 is defined to be one. Other 

ODS have ODPs that range from 0.01 to 10.0. 

Propane has an ODP of zero. 15 The most commonly used substitutes in the commercial 

ice machine, water cooler, and very low temperature refrigeration end-uses also have an ODP of 

zero (e.g., R–404A and R–134a). Some less common alternatives for these end-uses, such as R-

 

15 We assume that substitutes containing no chlorine, bromine, or iodine have an ODP of zero.
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401A, R-403B, R-414A and other blends containing HCFC-22 or HCFC-142b,

16 have ODPs 

ranging from 0.01 to 0.047. Thus, propane has an ODP lower than or identical to the ODPs of 

other alternatives in these end-uses.17

The GWP is a means of quantifying the potential integrated climate forcing of various 

greenhouse gases relative to a value of one for CO2. Propane has a relatively low integrated 

GWP of three. 18 For comparison, some other commonly used acceptable refrigerants in these 

end-uses are R–134a and R–404A, with GWPs of about 1,430 and 3,920, respectively. As shown 

in Table 2, the GWPs for acceptable refrigerants in commercial ice machines ranges from zero 

for ammonia vapor compression, ammonia absorption, and the not-in-kind Stirling cycle 

technology to approximately 3,990 for R-507A, while for water coolers, acceptable substitutes 

have GWPs ranging from 31 for THR-02 to approximately 3,990 for R-507A.19 In very low 

temperature refrigeration, a common refrigerant is R-508B, with a GWP of 13,400, while the 

recently listed refrigerant ethane has a GWP of approximately six and CO2 has a GWP of one; 

the GWPs for substitutes in this end-use range from one for CO2 to 14,800 for HFC-23. 

Propane’s GWP is comparable to or significantly lower than those of other alternatives in these 

end-uses.

Table 2: GWP, ODP, and VOC Status of Propane Compared to Other Refrigerants in New Commercial 

Ice Machines, Water Coolers, and Very Low Temperature Refrigeration Equipment1,2,3

Refrigerants GWP ODP VOC Proposal

Propane 3 0 Yes Acceptable, 

subject to use 

conditions

 

16 Under EPA’s phaseout regulations, virgin HCFC-22, HCFC-142b, and blends containing HCFC-22 or HCFC142b may only be used to service existing appliances. Consequently, virgin HCFC-22, HCFC-142b and blends 

containing HCFC-22 or HCFC-142b may not be used to manufacture new pre-charged appliances or appliance 

components or to charge new appliances assembled onsite.

17 Propane’s ODP is also lower than the ODP of the ozone depleting substances historically used in these end-uses: 

CFC–12 (ODP = 1.0); HCFC–22 (ODP = 0.055); R-13B1 (ODP = 10) and R–502 (ODP = 0.334).

18 Unless otherwise stated, GWPs stated in this document are 100-year integrated time horizon values taken from 

IPCC, 2007. Climate Change 2007: The Physical Science Basis. 

19 The GWPs of the ozone-depleting substances historically used in these end-uses are: CFC–12 (GWP = 10,900); 

HCFC–22 (GWP = 1,810); R-13B1/halon 1301 (GWP = 7,140) and R–502 (GWP = 4,660) (IPCC, 2007).
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Commercial Ice Machines

Ammonia, HFC-134a, R-404A, R-407A, R-407B, R407C, R-407F, R-410A, R-410B, R-421A, R-421B, 

R-424A, R-426A, R-437A, R-448A, R-449A, R450A, R-507A, R-513A

0-3,990 0 No No change

FOR12A, FOR12B, FRIGC FR-12 (HCFC Blend 

Beta), IKON A, IKON B, R-125/R-290/R-134a/R600a (55.0/1.0/42.5/1.5), 417A, R-422A, R-422B, R422C, R-422D, 428A, R-434A, R-438A, RS-24 

(2002 formulation), RS-44 (2003 formulation), 

THR-02, THR-03

30-3,610 0-0.009 Yes3 No change

Water Coolers

HFC-134a, R-404A, R-407A, R-407C, R-410A, R410B, R-417A, R-421A, R-426A, R-437A, R-450A, 

R-507A, R-513A,

0-3,990 0 No No change

FOR12A, FOR-12B, FRIGC FR-12 (HCFC Blend 

Beta), IKON B, R-125/R-290/R-134a/R-600a 

(55.0/1.0/42.5/1.5), R-422B, R-422C, R-422D, R438A, RS-24 (2002 formulation), SP34E, THR-02, 

THR-04

30-3,090 0-0.009 Yes3 No change

Very Low Temperature Refrigeration Equipment

CO2, HFC-23, HFC-245fa, HFE-7000, HFE-7100, 

HFE-7200, R-170 (ethane), R-404A, R-407C, R410A, R-410B, R-507A, R-508A, R-508B

1-14,800 0 No No change

ISCEON 89, R-125/R-290/R-134a/R-600a 

(55.0/1.0/42.5/1.5), R-422B, R-422C, PFC-1102HC, 

PFC-662HC, PFC-552HC, and FLC-15

2,530-8,500 0 Yes3 No change

1The table does not include not-in-kind technologies listed as acceptable for the stated end-use.

2HCFC-22 and several blends containing HCFCs are also listed as acceptable but their use is severely restricted by 

the phasedown in HCFC production and consumption.

3 One or more constituents of the blend are VOC.

The overall GHG effects of these refrigerants in various end-uses depend upon the design 

of the appliances, since the “indirect” GHG emissions associated with electricity consumption 

typically exceed the GHG emissions from the refrigerants over the full lifecycle of refrigerantcontaining products (RTOC, 2014). These indirect emissions occur from combustion of fossil 

fuel at power plants in order to supply electric power for operation of the refrigeration 

equipment. We do not have a practice in the SNAP program of including energy efficiency in the 

overall risk analysis. We do, however, consider issues such as technical needs for energy 

efficiency (e.g., to meet Department of Energy (DOE) conservation standards) in determining 

whether alternatives are “available.” We recognize that the energy efficiency of any given piece 
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of equipment is in part affected by the choice of refrigerant and the particular thermodynamic 

and thermophysical properties that refrigerant possesses, as well as other factors. For example, 

appliances that are optimized for a specific refrigerant will operate more efficiently. While 

theoretical efficiency of any given Rankine cycle is not dependent on the refrigerant used, the 

refrigerant, the design of the equipment, and other factors will affect the actual energy efficiency 

achieved in operation. Although we cannot know what energy efficiency will be achieved in 

future products using propane, or any other specific acceptable refrigerant, we can point to both 

actual equipment and testing results that suggest that equipment optimized for propane may 

improve energy efficiency, and is unlikely to negatively impact it. (Eppendorf, 2015; 

Manitowoc, 2015; Blupura, 2015). Further, testing data, peer-reviewed journal articles and other 

information provided by the submitters for propane in the proposed end-uses indicate that 

equipment using propane is likely to require a smaller refrigerant charge, to have a higher 

coefficient of performance, and to use less energy than equipment currently being manufactured 

that uses other refrigerants that currently are listed as acceptable under SNAP in these end-uses. 

Also see section VI.A.1.f below concerning the role of the DOE energy conservation standards 

in ensuring that overall energy efficiency of equipment will be maintained or improved over 

time.

In addition to global impacts on the atmosphere, EPA evaluated potential impacts of 

propane and other HC refrigerants on local air quality. Propane is a VOC under CAA regulations 

(see 40 CFR 51.100(s)) addressing the development of State Implementation Plans (SIPs) to 

attain and maintain the National Ambient Air Quality Standards (NAAQS). Potential emissions 

of VOC from all substitutes for all end-uses in the refrigeration and AC sector are addressed by 

the venting prohibition under CAA section 608. Under that prohibition, refrigerant substitutes 
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(and thus the VOC they contain) may only be emitted where EPA issues a final determination 

exempting a refrigerant substitute from the venting prohibition on the basis that venting, 

releasing or disposing of such substance does not pose a threat to the environment, as proposed 

elsewhere in this action (see section VI.A.2.a, “What is EPA’s proposal regarding whether 

venting of propane in the end-uses in this action would pose a threat to the environment?”

below). EPA estimates that potential emissions of HCs, including propane, when used as 

refrigerant substitutes in all end-uses in the refrigeration and AC sector, have little impact on 

local air quality, with the exception of unsaturated HCs such as propylene (ICF, 2014a).

EPA analyzed a number of scenarios to consider the potential impacts on local air quality 

if HC refrigerants were used widely (ICF, 2014a). The analysis considered both worst-case and 

more realistic scenarios. The worst-case scenario assumed that the most reactive HC listed as 

acceptable (isobutane) was used in all refrigeration and AC uses even though isobutane has not 

been listed acceptable for use in all refrigeration and AC uses, and that all refrigerant used was 

emitted to the atmosphere. In that extreme scenario, the model predicted that the maximum 

increase in any single 8-hour average ground-level ozone concentration would be 0.72 ppb in 

Los Angeles, which is the area with the highest level of ozone pollution in the United States. 

Given the potential sources of uncertainty in the modeling, the conservativeness of the 

assumptions, and the finding that the incremental VOC emissions from refrigerant emissions 

would not cause any area that otherwise would meet the 2008 ozone NAAQS to exceed it,20 we 

believe that the use of isobutane consistent with the use conditions required in EPA’s regulations 

will not result in significantly greater risk to the environment than other alternatives. Further, 

propane is less reactive than isobutane and thus we reach a similar conclusion for propane. 

 

20 The analysis described here was conducted prior to finalization of the 2015 ozone NAAQS. EPA has not yet 

made ozone attainment area designations for the 2015 ozone NAAQS.
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In a less conservative analysis potential impacts on ambient ozone levels, EPA looked at 

a set of end-uses that would be more likely to use HC refrigerants between now and 2030, 

including end-uses where they previously have been listed as acceptable and where they are 

proposed to be acceptable under this rule. For example, we assumed use of propane in water 

coolers and commercial ice machines and in end-uses where it is listed as acceptable, including 

room air conditioners and household and retail food refrigeration equipment and we assumed the 

use of other HCs such as isobutane in household and retail food refrigeration equipment and R441A in room air conditioners and household and retail food refrigeration equipment. For further 

information on the specific assumptions, see ICF, 2014a, in the docket for this rulemaking (EPAHQ-OAR-2015-0663). Based on this still conservative but more probable assessment of 

refrigerant use, we found that even if all the refrigerant in appliances in end-uses addressed in 

this proposed rule and in appliances in end-uses for which HCs are listed as acceptable were to 

be emitted, there would be a worst-case impact of a 0.15 ppb increase in ozone for a single 8-

hour average concentration in the Los Angeles area, which is the area with the highest level of 

ozone pollution in the United States.21 In the other cities examined in the analysis, Houston and 

Atlanta, impacts were smaller (no more than 0.03 and 0.01 ppb for a single 8-hour average 

concentration, respectively) (ICF, 2014a). For areas in the analysis that were not violating the 

2008 ozone NAAQS, the impacts did not cause an exceedance of the 2008 ozone NAAQS.

Because of the relatively low air quality impacts of propane if it is released to the 

atmosphere from the proposed end-uses even in a worst-case scenario, we propose that propane 

 

21 This less conservative analysis included some use of R-443A in room AC units because that substitute was under 

evaluation for that end-use. Elsewhere in this proposal, we propose to find R-443A and propylene unacceptable in 

residential and light-commercial AC and heat pumps, including room AC units. The propylene in R-443A, 

representing 12 percent of refrigerant emitted, was responsible for about 75 percent of the 0.15 ppb increase in 

ozone in this scenario, while all uses of propane, representing 83 percent of refrigerant emitted, was responsible for 

about 21 percent of the increase of ozone in this scenario. Thus, only 0.03 ppb of the o.15 ppb observed in Los 

Angeles would be due to propane and other acceptable HCs. 
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does not have a significantly greater overall impact on human health and the environment based 

on its effects on local air quality than other refrigerants listed as acceptable in commercial ice 

machines, water coolers, and very low temperature refrigeration equipment.

Propane is highly volatile and typically evaporates or partitions to air, rather than 

contaminating surface waters. Propane’s effects on aquatic life are expected to be small and pose 

no greater risk of aquatic or ecosystem effects than those of other alternatives for these uses.

ii. Flammability 

Propane’s flammability risks are of potential concern because commercial ice machines, 

water coolers, and very low temperature refrigeration equipment have traditionally used 

refrigerants that are not flammable. Without appropriate use conditions, the flammability risk 

posed by propane would be higher than non-flammable refrigerants because individuals may not 

be aware that their actions could potentially cause a fire. In this section, we discuss the 

flammability risks posed by propane and identify proposed use conditions that would mitigate 

those risks such that propane would not pose significantly greater risk due to flammability than 

other substitutes in these end-uses.

Because of its flammability, propane could pose a significant safety concern for workers 

and consumers in the end-uses addressed in this proposal if it is not handled correctly. In the 

presence of an ignition source (e.g., static electricity spark resulting from closing a door, use of a 

torch during service, or a short circuit in wiring that controls the motor of a compressor), an 

explosion or a fire could occur when the concentration of refrigerant exceeds its lower 

flammability limit (LFL). Propane’s LFL is 21,000 ppm (2.1%). Therefore, to use propane 

safely, it is important to minimize the presence of potential ignition sources and to reduce the 

likelihood that the concentration of propane will exceed the LFL. Under the proposed listing 
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decision, propane would be acceptable for use only in new equipment (self-contained 

commercial ice machines, water coolers, and very low temperature refrigeration equipment) 

specifically designed for this refrigerant. OSHA and building code requirements generally 

address flammability risks in the workplace and we presume that the original equipment 

manufacturers (OEMs), who would be storing large quantities of the refrigerant, are familiar 

with and use proper safety precautions to minimize the risk of explosion, consistent with those 

requirements. Therefore, we are not proposing use conditions to address workplace risk, which 

would be redundant of already existing requirements. We are proposing, however, to include 

recommendations in the “Further Information” section of the SNAP listings that these facilities 

be equipped with proper ventilation systems and be properly designed to reduce possible ignition 

sources.

To determine whether flammability would be a concern for service personnel or for 

consumers, EPA analyzed a plausible worst-case scenario to model a catastrophic release of 

propane. The worst-case scenario analysis for water coolers and for very low temperature 

refrigeration equipment revealed that even if the unit’s full charge is emitted within one minute, 

the leaked refrigerant concentration did not reach propane’s LFL of 2.1%, provided that the 

charge sizes were no greater than those specified in the relevant standard from UL (ICF, 

2015c,d). We are proposing the maximum charge size specified in the standard as a use 

condition; thus, there would not be an unacceptable risk of fire or explosion, even under those 

worst-case assumptions, so long as the charge does not exceed the use conditions in this 

proposed rule. In the case of commercial ice machines, the worst-case scenario with use of a 

charge size of 150 g resulted in attaining 102 percent of the LFL; less conservative, but 

reasonable, assumptions (e.g., larger room size, greater mixing of the refrigerant in the entire 
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room, same charge size of 150 g) resulted in concentrations at 18 percent or less of the LFL 

(ICF, 2015e). Thus, we expect there would not be an unacceptable risk of fire or explosion 

provided that the charge size is limited to 150 g. EPA also reviewed the submitters’ detailed 

assessments of the probability of events that might create a fire and approaches to avoid sparking 

from the refrigeration equipment. Further information on these analyses and EPA’s risk 

assessments are available in the docket for this rulemaking (EPA-HQ-OAR-2015-0663). Further, 

service personnel or consumers may not be familiar with refrigeration or AC equipment 

containing a flammable refrigerant. Therefore, use conditions are necessary to ensure people 

handling such equipment are aware that equipment contains a flammable refrigerant and to 

ensure safe handling.

iii. Toxicity

In evaluating potential toxicity impacts of propane on human health in these end-uses, 

EPA considered both occupational and consumer risks. In general when evaluating non-cancer 

toxicity risks of a substitute, we use measured exposure concentrations if available, or modeled 

exposure concentrations using conservative assumptions appropriate to an end-use, and compare 

these exposure levels to recommended or required exposure limits for a compound that are 

intended to protect against adverse health effects. Where measured or modeled exposure levels 

are below relevant exposure limits for a chemical, we consider toxicity risks to be acceptable. 

Other acceptable substitutes listed for these end-uses have been evaluated for toxicity in this 

manner, including ethane for very low temperature refrigeration, ammonia for commercial ice 

machines, and a number of HFC blends for all three end-uses. 

EPA investigated the risk of asphyxiation and of exposure to toxic levels of refrigerant 

for a worst-case scenario and a typical use. In the worst-case scenario of a catastrophic leak, we 
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modeled release of the unit’s full charge within one minute into a confined space to estimate 

concentrations that might result. We considered a conservatively small space appropriate to each 

end-use, such as a small galley kitchen of 18 m3for a water cooler, a kitchen of a fast food 

restaurant of 22 m3for a commercial ice machine or in a laboratory module of 28 m3for very 

low temperature refrigeration equipment. 

To evaluate the toxicity of propane, EPA estimated the maximum time weighted average 

(TWA) exposure both for a short-term exposure scenario, with a 30-minute TWA exposure, and 

for an 8-hour TWA that would be more typical of occupational exposure for a technician 

servicing the equipment or a worker disposing of appliances. We compared these short-term and 

long-term exposure values to relevant industry and government workplace exposure limits for 

propane. The modeling results indicate that both the short-term (30-minute) and long-term (8-

hour) worker exposure concentrations would be below the relevant workplace exposure limits, 

such as the OSHA PEL of 1000 ppm (8-hr TWA), and the National Research Council’s Acute 

Emergency Guideline Limit Level 1 (AEGL-1)22 of 6,900 ppm over 30 minutes. 

A similar analysis of asphyxiation risks considered whether a worst-case release of 

refrigerant in the same room sizes would result in oxygen concentrations of 12 percent or less. 

This analysis found that impacts on oxygen concentrations were minimal, with oxygen 

 

22 The AEGL limit is an emergency guideline for exposures to the general population (including

susceptible populations) and is not time-weighted. It also considers the chemical’s flammability in

addition to its toxicity. EPA develops a set of AEGL values for a substance for five exposure periods

(10 and 30 minutes, 1 hour, 4 hours and 8 hours). For each exposure period, three different AEGL values

are developed to address different levels of toxicological impacts. Of relevance for the modeled

scenario is the AEGL–1, which is defined as: “the airborne concentration, expressed as parts per

million or milligrams per cubic meter (ppm or mg/m3) of a substance above which it is predicted that 

the general population, including susceptible individuals, could experience notable discomfort, 

irritation, or certain asymptomatic nonsensory effects. However, the effects are not disabling and are

transient and reversible upon cessation of exposure.” While permanent toxicological effects are not

expected up to the AEGL–2 value, this limit is not relevant for this analysis because at that level, 

flammability would be a greater concern.
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concentrations remaining at approximately 21 percent.

For equipment with which consumers might come into contact, such as water coolers and 

commercial ice machines, EPA performed a consumer exposure analysis. In this analysis, we 

examined potential catastrophic release of the entire charge of the substitute in one minute under 

a worst-case scenario. We did not examine exposure to consumers in very low temperature 

refrigeration, as equipment for this end-use would typically be used in the workplace, such as in 

laboratories, and not in a home or public space. The analysis was undertaken to determine the 

30-minute TWA exposure levels for the substitute, which were then compared to the toxicity 

limit to assess the risk to consumers.

EPA considered toxicity limits for consumer exposure that reflect a short-term exposure 

such as might occur at home or in a store or other public setting where a member of the general 

public could be exposed and could then escape. The toxicity limit that we used in our analysis of 

consumer exposure was an AEGL-1 of 6,900 ppm over 30 minutes. The analysis of consumer 

exposure assumed that 100 percent of the unit’s charge would be released over one minute, at 

which time the concentration of refrigerant would peak in an enclosed space, and then steadily 

decline. Refrigerant concentrations were modeled under two air change scenarios, believed to 

represent the baseline of potential flow rates for a home or public space, assuming flow rates of 

2.3 air changes per hour (ACH) in a household kitchen and 20 ACH in a restaurant kitchen (ICF, 

2015c,e). The highest concentrations of the refrigerant occur in the lower stratum of the room 

when assuming the lower ventilation level of 2.3 ACH. Calculating the TWA exposure using 2.3 

ACH results in a higher concentration than calculating the TWA exposure using 20 ACH. Even 

under the very conservative assumptions used in the consumer exposure modeling, the estimated 

30-minute consumer exposures to propane are lower than the relevant toxicity limits.
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Based upon our analysis, workplace and consumer exposure to propane when used in 

these end-uses according to the proposed use conditions is not expected to exceed relevant 

exposure limits. Thus, propane does not pose significantly greater toxicity risks to other 

acceptable refrigerants in these end-uses. For further information, including EPA’s risk screens 

and risk assessments as well as information from the submitters of propane as a substitute 

refrigerant, see docket EPA–HQ–OAR–2015-0663.

c. What are the proposed use conditions? 

In order to ensure that use of propane in these three end-uses would not cause greater risk 

to human health or the environment than use of other alternatives, we have identified and are 

proposing use conditions to address flammability and toxicity concerns. The proposed use 

conditions include conditions consistent with industry standards, limits on charge size, and 

requirements for warnings and markings on equipment.

i. New equipment only; not intended for use as a retrofit alternative

EPA is proposing that, in the specified end-uses, propane be limited to use only in new 

equipment23 that has been designed and manufactured specifically for use with propane. Propane 

was not submitted under the SNAP program to be used in retrofitted equipment, and no 

information was provided on how to mitigate hazards of flammable refrigerants when used in 

equipment that was not designed for flammable refrigerants. If this use condition is finalized as 

proposed, use of propane in equipment not designed for its use, including existing equipment

designed for another refrigerant, would be in violation of CAA section 612(c) and the 

corresponding SNAP regulations at 40 CFR part 82, subpart G. 

ii. Standards

 

23 This is intended to mean a completely new refrigeration circuit containing a new evaporator, condenser 

and refrigerant tubing.
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EPA is proposing that propane be used only in equipment that meets all requirements in 

the relevant supplements for flammable refrigerants in certain applicable UL standards for 

refrigeration and AC equipment. Specifically, Supplement SA to the 8th edition of UL 563 

standard, dated July 31, 2009, applies to self-contained commercial ice machines using 

flammable refrigerants; the UL standard for water coolers using flammable refrigerants is 

Supplement SB to the 7th edition of UL 399, dated August 22, 2008; and very low temperature 

refrigeration equipment is sufficiently similar to stand-alone commercial refrigerators that an 

appropriate standard is Supplement SB to the 10th edition of UL 471, dated November 24, 2010.

UL has tested equipment for flammability risk in household and retail food refrigeration 

and for commercial freezers for very low temperature refrigeration. Further, UL has developed 

acceptable safety standards including requirements for construction, for markings, and for 

performance tests concerning refrigerant leakage, ignition of switching components, surface 

temperature of parts, and component strength after being scratched. These standards were 

developed in an open and consensus-based approach, with the assistance of experts in the AC 

and refrigeration industry as well as experts involved in assessing the safety of products. While 

similar standards exist from other bodies such as the International Electrotechnical Commission 

(IEC), we are proposing to rely on UL standards as those that are most applicable to and 

recognized by the U.S. market. This proposed approach is the same as that adopted in our 

previous rules on flammable refrigerants (76 FR 78832, December 20, 2011; 80 FR 19453, April 

10, 2015).

iii. Charge size

EPA is proposing use conditions that limit the amount of propane allowed in each 
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refrigerant circuit to 150 g.24 It is necessary to set limits on charge size in order for propane not 

to pose a risk to human health or the environment that is greater than the risk posed by other 

substitutes. These limits will reduce the risk to workers and consumers since under scenarios we 

analyzed, a leak of the proposed charge sizes did not result in concentrations of the refrigerant 

that met or exceeded the LFL.

EPA is proposing limitations on refrigerant charge size for self-contained commercial ice 

machines, water coolers, and very low temperature refrigeration equipment that reflect the UL 

563, UL 399, and UL 471 standards. As discussed above in paragraph ii of this section, we 

believe UL standards are appropriate because they are the most applicable to and recognized by 

the U.S. market and offer requirements developed by a consensus of experts. 

UL Standards 563 (ice machines), 399 (water coolers), and 471 (commercial stand-alone 

refrigeration equipment) limit the amount of refrigerant leaked to 150 grams (5.29 ounces). We 

note that the charge size limit for propane in the UL standards is in line with the IEC 60335–2–

89 standard addressing these end-uses, which also has a charge size limit of 150 grams.

iv. Color-coded hoses and piping

EPA proposes that equipment designed for use with propane must have distinguishing 

color-coded hoses and piping to indicate use of a flammable refrigerant. This will help 

technicians immediately identify the use of a flammable refrigerant, thereby reducing the risk of 

using sparking equipment or otherwise having an ignition source nearby. The AC and 

refrigeration industry currently uses distinguishing colors as means to identify different 

refrigerants. Likewise, distinguishing coloring has been used elsewhere to indicate an unusual 

and potentially dangerous situation, for example in the use of orange-insulated wires in hybrid 

 

24 To place this in context, a 150 g charge is about five times the charge in a disposable lighter (30 g).
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electric vehicles. Currently, no industry standard exists for color-coded hoses or pipes for 

propane. EPA is proposing that all such refrigerator tubing be colored red PMS #185 to match 

the red band displayed on the container of flammable refrigerants under the Air Conditioning, 

Heating and Refrigeration Institute (AHRI) Guideline “N” 2012, “2012 Guideline for 

Assignment of Refrigerant Container Colors.” This proposal mirrors the existing use condition 

for HCs in residential and commercial refrigerator-freezers, vending machines, very low 

temperature refrigeration equipment, non-mechanical heat transfer equipment and room air 

conditioners (76 FR 78832, December 20, 2011; 80 FR 19453, April 10, 2015). EPA wants to 

ensure that there is adequate notice that a flammable refrigerant is being used within a particular 

piece of equipment or appliance. One mechanism to distinguish hoses and pipes is to add a 

colored plastic sleeve or cap to the service tube. The colored plastic sleeve or cap would have to 

be forcibly removed in order to access the service tube. This would signal to the technician that 

the refrigeration circuit that she/he was about to access contained a flammable refrigerant, even 

if all warning labels were somehow removed. This sleeve would be of the same red color (PMS 

#185) and could also be boldly marked with a graphic to indicate the refrigerant was flammable. 

This could be a cost-effective alternative to painting or dying the hose or pipe. 

EPA is particularly concerned with ensuring adequate and proper notification for 

servicing and disposal of appliances containing flammable refrigerants. The use of color-coded 

hoses, as well as the use of warning labels discussed below, is necessary to ensure flammable 

refrigerants can be used without presenting significantly more risk than other alternatives and 

would be consistent with other general industry practices. This proposed approach is consistent 

with the approach adopted in our previous rules on flammable refrigerants (76 FR 78832, 

December 20, 2011; 80 FR 19453, April 10, 2015). 
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v. Labeling

As a use condition, EPA is proposing to require labeling of self-contained commercial ice 

machines, water coolers, and, very low temperature refrigeration equipment. EPA is proposing 

the warning labels on the equipment contain letters at least 1⁄4 inch high and that they be 

permanently affixed to the equipment. Warning label language requirements are as follows:

(a) “DANGER—Risk of Fire or Explosion. Flammable Refrigerant Used. Do 

Not Use Mechanical Devices To Defrost Refrigerator. Do Not Puncture Refrigerant 

Tubing.” This marking must be provided on or near any evaporators that can be contacted 

by the consumer.

(b) “DANGER—Risk of Fire or Explosion. Flammable Refrigerant Used. To 

Be Repaired Only By Trained Service Personnel. Do Not Puncture Refrigerant Tubing.” 

This marking must be located near the machine compartment.

(c) “CAUTION—Risk of Fire or Explosion. Flammable Refrigerant Used. 

Consult Repair Manual/Owner’s Guide Before Attempting To Service This Product. All 

Safety Precautions Must be Followed.” This marking must be located near the machine 

compartment.

(d) “CAUTION—Risk of Fire or Explosion. Dispose of Properly In 

Accordance With Federal Or Local Regulations. Flammable Refrigerant Used.” This 

marking must be provided on the exterior of the refrigeration equipment.

(e) CAUTION—Risk of Fire or Explosion Due To Puncture Of Refrigerant 

Tubing; Follow Handling Instructions Carefully. Flammable Refrigerant Used.” This 

marking must be provided near all exposed refrigerant tubing.

The warning label language is similar to or exactly the same as that required in UL 
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standards: for commercial ice machines in UL 563 in section SB6.1, for water coolers in UL 399 

in section SA6.1, and for commercial refrigerators and freezers, including very low temperature 

freezers, in UL 471 in section SB6.1.

It would be difficult to see warning labels with the minimum lettering height requirement 

of 1⁄8 inch in these UL standards. Therefore, as in the requirements in our previous HC 

refrigerants rules for residential and commercial refrigerator-freezers, vending machines, very 

low temperature refrigeration equipment, non-mechanical heat transfer equipment, and room air 

conditioners (76 FR 78832, December 20, 2011; 80 FR 19453, April 10, 2015), EPA is 

proposing the minimum height for lettering must be 1⁄4 inch as opposed to 1⁄8 inch, which will 

make it easier for technicians, consumers, retail storeowners, and first responders to view the 

warning labels. 

d. What recommendations does EPA have for the safe use of propane?

In addition to establishing regulatory use conditions, which are binding on end users, 

EPA may also make recommendations for use of a substitute. EPA is proposing to recommend 

that only technicians specifically trained in handling flammable refrigerant substitutes dispose of 

or service refrigeration and AC equipment containing these substances. Trained technicians 

should know how to minimize the risk of fire and the procedures for using flammable refrigerant 

substitutes safely. Releases of large quantities of flammable refrigerants during servicing and 

manufacturing, especially in enclosed, poorly ventilated spaces or in areas where large amounts 

of refrigerant are stored, could cause an explosion if an ignition source exists nearby. For these 

reasons, technicians should be properly trained to handle flammable refrigerant substitutes when 

maintaining, servicing, repairing, or disposing of water coolers, commercial ice machines, and 

very low temperature freezers. In addition, EPA recommends that if propane would be vented, 
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released, or disposed of (rather than recovered), as is proposed for the specified end-uses in this 

rule, the release should be in a well-ventilated area, such as outside of a building. Ensuring 

proper ventilation and avoiding ignition sources are recommended practices, whether venting or 

recovering a flammable refrigerant.

The Australian Institute of Refrigeration, Air Conditioning and Heating (AIRAH) 

provides useful guidance on safety precautions technicians can follow when servicing equipment 

containing flammable refrigerants or when venting refrigerant. One of those practices is to 

connect a hose to the appliance to allow for venting the refrigerant outside. This document is 

included in the docket for this rule (EPA-HQ-OAR-2015-0663) (AIRAH, 2013). 

We are aware that at least two organizations in the United States, Refrigeration Service 

Engineers Society (RSES) and the ESCO Institute, have developed technician training programs 

in collaboration with refrigeration equipment manufacturers and users that address safe use of 

flammable refrigerant substitutes. In addition, EPA has reviewed several training programs 

provided as part of SNAP submissions from persons interested in flammable refrigerant 

substitutes. The agency intends to update the test bank for technician certification under CAA 

section 608 as we have done previously, and will consider including additional questions on 

flammable refrigerants. By adding such questions to the test bank, EPA would supplement but 

would not replace technician training programs currently provided by non-government entities. 

EPA will seek additional information and guidance on how best to incorporate this content 

through a separate process outside the scope of this final rule.

e. When would the listing apply?

EPA proposes that this listing would apply 30 days after the date of publication of a final 

rule. This date, the same as the proposed effective date of this regulation, allows for the safe use 
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of this substitute at the earliest opportunity.

f. What is the relationship between this SNAP rule and other federal

rules? 

i. How would this proposed listing relate to federal energy conservation 

standards?

For some of the types of equipment covered in this proposal, DOE has established energy 

conservation standards. For example, DOE energy conservation standards apply to automatic 

commercial ice machines.25 Thus, total energy use with propane can be expected to be no higher 

than that required by the standards for those classes of equipment.26 DOE does not have an 

energy conservation standard that would apply to water coolers or to very low temperature 

refrigeration equipment. EPA considers technical needs for energy efficiency (e.g., to meet DOE 

energy conservation standards) in determining whether alternatives are “available.” Based on 

available information, we found no evidence that propane would reduce energy efficiency or that 

equipment using propane would be unable to meet DOE energy efficiency standards in the enduses proposed in this rule, and we found some evidence that propane may improve energy 

efficiency (Manitowoc, 2015; Eppendorf, 2015; Blupura, 2015). 

ii. How would this proposed listing relate to regulations implementing 

the venting prohibition under CAA section 608?

 

25 See https://www1.eere.energy.gov/buildings/appliance_standards/standards_test_procedures.html.

26 Refrigeration or AC equipment in the applicable covered equipment class would still be subject to DOE’s 

standards, regardless of the refrigerant that the equipment uses. If a manufacturer believes that its design is subjected 

to undue hardship by DOE’s regulations, the manufacturer may petition DOE’s Office of Hearing and Appeals 

(OHA) for exception relief or exemption from the standard pursuant to OHA’s authority under section 504 of the 

DOE Organization Act (42 U.S.C. 7194), as implemented at subpart B of 10 CFR part 1003. OHA has the authority 

to grant such relief on a case-by-case basis if it determines that a manufacturer has demonstrated that meeting the 

standard would cause hardship, inequity, or unfair distribution of burdens.
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Below in section VI.A.2 of this document, EPA is proposing to exempt propane from the 

venting prohibition under CAA section 608 when propane is used as a refrigerant in selfcontained commercial ice machines, water coolers, or very low temperature refrigeration 

equipment.

g. On which topics is EPA specifically requesting comment? 

EPA requests comment on all aspects of the proposed listing of propane as an acceptable 

refrigerant in self-contained commercial ice machines, water coolers, and very low temperature 

refrigeration equipment, including the proposed use conditions discussed in section VI.A.1.c. We 

are particularly interested in comment of two of the proposed use conditions: (1) the use of red 

marking for pipes, hoses and other devices including direct color application on the applicable 

parts of the system, such as a red plastic sleeve (see section VI.A.1.c.iv, “Color-coded hoses and 

piping”); and (2) the UL standards that EPA proposes to incorporate by reference (i.e., 

Supplement SA to the 8th edition of UL 563, dated July 31, 2009, for self-contained commercial 

ice machines, Supplement SB to the 7th edition of UL 399, dated August 22, 2008, for water 

coolers; and Supplement SB to the 10th edition of UL 471, dated November 24, 2010, for very 

low temperature refrigeration equipment).

2. Proposed exemption for propane from the venting prohibition under CAA 

section 608 for the end-uses in the proposed new SNAP listing 

a. What is EPA’s proposal regarding whether venting of propane

in the end-uses in this action would pose a threat to the environment?

EPA is proposing to list the refrigerant substitute propane under the SNAP program as 

acceptable, subject to use conditions, in newly manufactured water coolers, self-contained 

commercial ice machines, and very low temperature refrigeration equipment. EPA is also 
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proposing to exempt propane in these end-uses from the venting prohibition under CAA section 

608(c)(2). For purposes of CAA section 608(c)(2), EPA considers two factors in determining 

whether or not venting, release, or disposal of a refrigerant substitute during the maintenance, 

servicing, repairing, or disposing of appliances poses a threat to the environment. See 69 FR 

11948, March 12, 2004; 79 FR 29682, May 23, 2014; and 80 FR 19453, April 10, 2015. First, 

EPA analyzes the threat to the environment due to inherent characteristics of the refrigerant 

substitute, such as GWP. Second, EPA determines whether and to what extent venting, release, 

or disposal actually takes place during the maintenance, servicing, repairing, or disposing of 

appliances, and to what extent such actions are controlled by other authorities, regulations, or 

practices. To the extent that such releases are adequately controlled by other authorities, EPA 

defers to those authorities. 

i. Potential environmental impacts

EPA has evaluated the potential environmental impacts of releasing into the environment 

propane, the substitute that we are proposing to list under the SNAP program as acceptable, 

subject to use conditions, in water coolers, self-contained commercial ice machines, and very 

low temperature refrigeration equipment. In particular, we assessed the potential impact of the 

release of propane on local air quality and its ability to decompose in the atmosphere, its ODP, 

its GWP, and its potential impacts on ecosystems. 

As explained above in section VI.A.1.b.i, “Environmental impacts,” propane’s ODP is 

zero, its GWP is approximately three, and its effects on aquatic life are expected to be small. As 

to potential effects on local air quality, based on the analysis and modeling results described in 

section VI.A.1.b.i of this preamble, EPA proposes to conclude that release of propane from the 

end-uses proposed in this action, in addition to the HCs previously listed as acceptable, subject to 
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use conditions, for their specific end-uses, is expected to have little impact on local air quality. In 

this regard, EPA finds particularly noteworthy that even assuming 100 percent market 

penetration of propane and the other acceptable HCs in the proposed and acceptable end-uses, 

which is a conservative assumption, the highest impact for a single 8-hour average concentration 

based on this analysis would be 0.03 ppb in Los Angeles.

In addition, when examining all HC substitute refrigerants in those uses for which UL 

currently has standards in place, for which the SNAP program has already listed the uses as 

acceptable, subject to use conditions, or for which the SNAP program is reviewing a submission, 

including those in this rule, we found that even if all the refrigerant in appliances in end-uses 

proposed as acceptable, subject to use conditions in this rule and listed as acceptable in previous 

rules were to be emitted, there would be a worst-case impact of less than 0.15 ppb for groundlevel ozone in the Los Angeles area (ICF, 2014a). The use conditions established in the SNAP 

listings limit the total amount of refrigerant in each refrigerant circuit to 150 g or less, depending 

on the end-use. Because propane is not proposed to be used in all refrigerant uses, the total 

amount of propane that could be emitted in the end-uses evaluated is estimated at roughly ten 

percent of total refrigerant emissions, or less than 16,000 metric tons annually (ICF, 2014a). 

Further, there are other substitute refrigerants that are not VOC that may also be used in these 

end-uses, so our analysis assuming complete market penetration of HCs is conservative. In light 

of its evaluation of potential environmental impacts, EPA proposes that propane in the end-uses 

for which it is proposed to be listed under SNAP as acceptable, subject to use conditions, in this 

notice is not expected to pose a threat to the environment on the basis of the inherent 

characteristics of this substance and the limited quantities used in the relevant end-uses. In this 

regard, EPA finds particularly noteworthy that even assuming 100% market penetration of 
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propane and the other acceptable HCs in the proposed and acceptable end-uses, which is a 

conservative assumption, the highest impact for a single 8-hour average concentration based on 

this analysis would be 0.03 ppb in Los Angeles.

ii. Flammability and toxicity

As discussed above in sections VI.A.1.b.ii, “Flammability” and VI.A.1.b.iii, “Toxicity,” 

EPA’s SNAP program evaluated the flammability and toxicity risks from propane in the 

proposed end-uses in this rule. EPA is providing some of that information in this section as well. 

Propane is classified as an A3 refrigerant by ASHRAE Standard 34–2010 and subsequent 

addenda, indicating that it has low toxicity and high flammability. Propane has an LFL of 2.1%. 

To address flammability risks, this proposal provides recommendations for its safe use (see 

section VI.A.1.d, “What recommendations does EPA have for the safe use of propane?” above). 

The SNAP program’s analysis suggests that the proposed use conditions in this rule will mitigate 

flammability risks.

Like most refrigerants, at high concentrations HCs can displace oxygen and cause 

asphyxiation. Various industry and regulatory standards exist to address asphyxiation and 

toxicity risks. The SNAP program’s analysis of asphyxiation and toxicity risks suggests that the 

proposed use conditions in this rule would mitigate asphyxiation and toxicity risks. Furthermore, 

it is the Agency’s understanding that flammability risks and occupational exposures to HCs are

adequately regulated by OSHA and building and fire codes at a local and national level.

iii. Authorities, controls, or practices

EPA expects that existing authorities, controls, and/or practices will mitigate

environmental risk from the release of propane. Analyses performed for both this rule and the 

SNAP rules issued in 1994, 2011, and 2015 (59 FR 13044, March 17, 1994; 76 FR 38832, 
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December 20, 2011; and 80 FR 19453, April 10, 2015, respectively) ) indicate that existing 

regulatory requirements and industry practices limit and control the emission of propane. As 

explained below, EPA proposes that the limits and controls under other authorities, regulations, 

or practices adequately control the release of and exposure to propane and mitigate risks from 

any possible release.

As mentioned above, the determination of whether venting, release, or disposal of a 

substitute refrigerant poses a threat to the environment includes considering whether such 

venting, release, or disposal is adequately controlled by other authorities, regulations, or 

practices. This information is another part of EPA’s proposal that the venting, release, or 

disposal of propane, in the specified end-uses and subject to the use conditions in this proposed 

action, does not pose a threat to the environment.

Industry service practices and OSHA standards and guidelines that address HC

refrigeration equipment include monitoring efforts, engineering controls, and operating 

procedures. OSHA requirements that apply during servicing include continuous monitoring of 

explosive gas concentrations and oxygen levels. In general, HC emissions from refrigeration 

systems are likely to be significantly smaller than those emanating from the industrial process 

and storage systems, which are controlled for safety reasons. In the SNAP listings in section 

VI.A.1.c, “What are the proposed use conditions?” we note that the amount of refrigerant 

substitute from a refrigerant loop is limited to 150 g in the end-uses proposed in this rule. This 

indicates that HC emissions from such uses are likely to be relatively small. 

The release and/or disposal of many refrigerant substitutes, including propane, are 

controlled by other authorities including various standards, and state and local building codes. To 

the extent that release during maintaining, repairing, servicing, or disposing of appliances is 
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controlled by regulations and standards of other authorities, these practices and controls for the 

use of propane are sufficiently protective. These practices and controls mitigate the risk to the 

environment that may be posed by the venting, release, or disposal of propane during the 

maintaining, servicing, repairing, or disposing of appliances.

EPA is aware of equipment that can be used to recover HC refrigerants. While there are 

no relevant U.S. standards for such recovery equipment currently, to the extent that propane is 

recovered rather than vented in specific end-uses and equipment, EPA recommends the use of 

recovery equipment designed specifically for flammable refrigerants in accordance with 

applicable safe handling practices. See section VI.A.1.d above, “What recommendations does 

EPA have for the safe use of propane?”

b. What is EPA’s proposal regarding whether venting of propane in the

end-uses in this action should be exempted from the venting prohibition 

under CAA section 608?

Consistent with the proposed listing under SNAP in this action, EPA proposes that 

venting, releasing or disposing of propane in water coolers, self-contained commercial ice 

machines, and very low temperature refrigeration equipment is not expected to pose a threat to 

the environment. As discussed more fully above, we propose this on the basis of the inherent 

characteristics of this substance, the limited quantities used in the relevant end-uses, and the 

limits and controls under other authorities, regulations, or practices that adequately control the 

release of and exposure to propane and mitigate risks from any possible release. Accordingly, 

EPA is proposing to revise the regulations at 82.154(a)(1) to add propane in these end-uses to the 

list of substitute refrigerants that are exempt from the venting prohibition. We also note that EPA 

has recently proposed to revise the format of the text of this section to include separate 
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paragraphs for each substitute refrigerant, rather than grouping refrigerants in an end-use (80 FR 

69457; November 9, 2015). Thus, the final text of section 82.154(a)(1) may reflect revised 

language related to both the November 2015 proposal and to this proposal.

c. When would the exemption from the venting prohibition apply?

We are proposing that propane would be exempt from the venting prohibition as of 30 

days after the publication of a final rule in the Federal Register. This would be the same as the 

date of the SNAP listing of propane in commercial ice machines, water coolers, and very low 

temperature refrigeration equipment.

d. What is the relationship between this proposed exemption under CAA

section 608 and other EPA rules? 

If this proposed exemption were to become final as proposed, it would not mean that 

propane could be vented in all situations. Propane and other HCs being recovered, vented, 

released, or otherwise disposed of from commercial and industrial appliances are likely to be 

hazardous waste under RCRA (see 40 CFR Parts 261-270). As discussed in the final rules 

addressing the venting of ethane, isobutane, propane, and R–441A as refrigerant substitutes in 

certain end-uses, incidental releases may occur during the maintenance, service, and repair of 

appliances subject to CAA section 608 (79 FR 29682, May 23, 2014; 80 FR 19454, April 10, 

2015). Such incidental releases would not be subject to RCRA requirements for the disposal of 

hazardous waste, as such releases would not constitute disposal of the refrigerant charge as a 

solid waste, per se. Disposal or venting of propane from household appliances used in the home, 

such as a water cooler, is also generally not considered disposal of a hazardous waste under the 

existing RCRA regulations and could be vented under the household hazardous waste 

exemption, assuming other state or local requirements do not prohibit venting. See 40 CFR 
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261.4(b)(1). However, for commercial and industrial appliances such as self-contained 

commercial ice machines, very low temperature refrigeration equipment, or water coolers used in 

an industrial or office setting, it is likely that propane and other flammable HC refrigerant 

substitutes would be classified as hazardous waste and disposal of propane from such appliances

would need to be managed as hazardous waste under the RCRA regulations (40 CFR Parts 261-

270), unless it is subject to a limited exception in those regulations if the ignitable refrigerant is 

to be recycled.

e. On which topics is EPA specifically requesting comment? 

EPA requests comment on all aspects of our proposal to exempt from CAA section 608’s 

venting prohibition the venting or release of propane used as a refrigerant substitute in water 

coolers, self-contained commercial ice machines, and very low temperature refrigeration 

equipment, as well as seeking comment on the proposed exemption language at 40 CFR 

82.154(a)(1). 

3. Proposed listing of new refrigerants as unacceptable 

a. Proposed listing of certain flammable refrigerants as unacceptable 

for retrofits in unitary split AC systems and heat pumps

EPA is proposing to list the following flammable refrigerants as unacceptable for use in

existing unitary split AC and heat pumps for residential and light commercial AC and heat 

pumps because they pose significantly more risk to human health or the environment than other 

available alternatives: 

 All refrigerants identified as flammability Class 3 in ANSI/ASHRAE .Standard 

34–2013.
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 All refrigerants meeting the criteria for flammability Class 3 in ANSI/ASHRAE 

Standard 34–2013. These include, but are not limited to, refrigerant products sold 

under the names R-22a, 22a, Blue Sky 22a refrigerant, Coolant Express 22a, 

DURACOOL-22a, EC-22, Ecofreeeze 22a, EF-22a, Envirosafe 22a, ES-22a, 

Frost 22a, HC-22a, Maxi-Fridge, MX-22a, Oz-Chill 22a, Priority Cool, and RED 

TEK 22a.

Existing unitary split AC systems and heat pumps were not designed to use a flammable 

refrigerant. We are aware of instances in which people or property have been harmed by retrofit 

or so-called ‘drop-in’ use of certain of the specified flammable refrigerants in equipment

designed to use HCFC-22. For new equipment, we have listed certain flammable refrigerants as 

acceptable on the basis that flammability risks can be addressed in designing the equipment and 

mitigated through use conditions. In contrast, existing equipment has not been designed for 

flammable refrigerants and we have not identified appropriate use conditions that can manage 

the flammability risk for retrofits such that these flammable refrigerants would pose similar or 

lower risk than other available refrigerants in this end-use.

i. What is the affected end-use?

The residential and light commercial AC and heat pumps end-use includes equipment for 

cooling air in individual rooms, in single-family homes, and sometimes in small commercial 

buildings. This end-use differs from commercial comfort AC, which uses chillers that cool water 

that is then used to cool air throughout a large commercial building, such as an office building or 

hotel. This proposal specifically concerns unitary split systems and heat pumps, commonly 

called central AC. These systems include an outdoor unit with a condenser and a compressor, 

refrigerant lines, an indoor unit with an evaporator, and ducts to carry cooled air throughout a 
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building. Central heat pumps are similar but offer the choice to either heat or cool the indoor 

space. We are proposing that certain flammable refrigerants would be listed as unacceptable for 

retrofit use in this type of equipment.

We are not currently proposing that the unacceptability determination for certain 

flammable refrigerants applies to other types of residential AC and heat pump equipment, but we 

may do so in the future. The presence of a proposal for a single type of equipment within this 

end-use or listings finding certain substitutes acceptable, subject to use conditions, in a specific 

type of equipment does not imply that other uses are acceptable (e.g., listing as acceptable, 

subject to use conditions in new equipment does not mean retrofit use is acceptable). Other types 

of residential AC and heat pump equipment not included in this proposed unacceptability 

determination include:

 Multi-split air conditioners and heat pumps. These systems include one or more 

outdoor unit(s) with a condenser and a compressor and multiple indoor units, each of 

which is connected to the outdoor unit by refrigerant lines. For ductless multi-split 

systems, the cooled air exits directly from the indoor unit rather than being carried 

through ducts. 

 Mini-split air conditioners and heat pumps. These systems include an outdoor unit 

with a condenser and a compressor and a single indoor unit that is connected to the 

outdoor unit by refrigerant lines. Cooled air exits directly from the indoor unit rather 

than being carried through ducts. 

 Packaged outdoor air conditioners and heat pumps. These systems include an outdoor 

unit with a condenser and a compressor and a heating assembly, often used on top of 

the roof of a building such as a commercial office building or apartment building. 
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These units carry cool air to the inside of the building through ducts, so they are not 

completely self-contained units; however, the refrigerant remains within the packaged 

unit, thus reducing the chance of leaks from refrigerant lines. 

 Window air conditioners and heat pumps. These are self-contained units that fit in a 

window with the condenser extending outside the window. 

 Packaged terminal air conditioners (PTACs) and packaged terminal heat pumps 

(PTHP). These are self-contained units that consist of a separate, un-encased 

combination of heating and cooling assemblies mounted through a wall.

 Portable room air conditioners and heat pumps. These are self-contained, factorysealed, single package units that are designed to be moved easily from room to room 

and are intended to provide supplemental cooling within a room. These units typically 

have wheels or casters for portability and have a fan which operates continuously 

when the unit is on. Portable room air conditioners and heat pumps may contain an 

exhaust hose that can be placed through a window or door to eject heat to the outside. 

Compared to self-contained AC equipment such as window air conditioners, PTAC, 

PTHP, and portable room air conditioners, unitary split AC systems and heat pumps are much 

more likely to have a refrigerant release due to having a larger charge sizes, more locations that 

are prone to leak, and because they are more likely to require servicing by a technician . A higher 

risk of refrigerant releases and a potential for larger releases and higher concentration releases 

results in higher risk that flammable refrigerant could be ignited from unitary split AC systems 

and heat pumps compared to self-contained equipment. 

EPA is aware of a number of situations where companies have sold highly flammable 

refrigerants for use in residential AC that have not been submitted to SNAP for review. EPA has 
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conducted enforcement actions against companies that have sold such substitutes in violation of 

EPA’s regulations (EPA, 2013). EPA is aware of multiple cases, people and property using the 

“22a” refrigerant in a residential AC system were harmed in explosions and fires, in part because 

the person servicing the AC system was not aware that the system contained a highly flammable 

refrigerant. Considering this demonstration of the flammability risks of retrofitting residential 

AC systems as well as the lack of risk mitigation available for existing equipment (e.g., charge 

limits, design for reduced leakage), EPA is proposing to list R-22a, 22a, and other similar 

liquified petroleum gases as unacceptable, as well as refrigerants with a flammability 

classification of 3 in ASHRAE 34-2013.

ii. Which refrigerants is EPA proposing to list as unacceptable?

EPA is proposing that the following flammable refrigerants be listed as unacceptable for 

retrofits in unitary split AC systems and heat pumps:

 All refrigerants identified as flammability Class 3 in ANSI/ ASHRAE Standard 34–

2013.

 All refrigerants meeting the criteria for flammability Class 3 in ANSI/ASHRAE 

Standard 34–2013. These include, but are not limited to, refrigerant products sold 

under the names R-22a, 22a, Blue Sky 22a refrigerant, Coolant Express 22a, 

DURACOOL-22a, EC-22, Ecofreeeze 22a, EF-22a, Envirosafe 22a, ES-22a, Frost 

22a, HC-22a, Maxi-Fridge, MX-22a, Oz-Chill 22a, Priority Cool, and RED TEK 22a.

ANSI/ASHRAE Standard 34–2013 assigns a safety group classification for each 

refrigerant which consists of two alphanumeric characters (e.g., A2 or B1). The capital letter 

indicates the toxicity and the numeral denotes the flammability. ASHRAE classifies Class A 

refrigerants as refrigerants for which toxicity has not been identified at concentrations less than 
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or equal to 400 parts per million (ppm) by volume, based on data used to determine TLV–TWA

or consistent indices. Class B signifies refrigerants for which there is evidence of toxicity at 

concentrations below 400 ppm by volume, based on data used to determine TLV–TWA or 

consistent indices. The refrigerants are also assigned a flammability classification of 1, 2, or 3. 

Tests are conducted in accordance with ASTM E681 using a spark ignition source at 60 °C and 

101.3 kPa (ASHRAE, 2013). Figure 1 in ANSI/ASHRAE Standard 15–2013 uses the same 

safety group but limits its concentration to 3,400 ppm.

The flammability classification “1” is given to refrigerants that, when tested, show no 

flame propagation. The flammability classification “2” is given to refrigerants that, when tested, 

exhibit flame propagation, have a heat of combustion less than 19,000 kJ/kg (8,174 British 

thermal units (BTU)/lb), and have a LFL greater than 0.10 kg/m3. Refrigerants within 

flammability classification 2 may optionally be designated in the LFL subclass “2L” if they have 

a maximum burning velocity of 10 cm/s or lower when tested at 23.0 °C and 101.3 kPa. The 

flammability classification “3” is given to refrigerants that, when tested, exhibit flame 

propagation and that either have a heat of combustion of 19,000 kJ/kg (8,174 BTU/lb) or greater 

or an LFL of 0.10 kg/m3or lower. Thus, refrigerants with flammability classification “3” are 

highly flammable while those with flammability classification “2” are less flammable and those 

with flammability classification “2L” are mildly flammable. For both toxicity and flammability 

classifications, refrigerant blends are designated based on the worst-case of fractionation 

determined for the blend (which may be different when evaluating toxicity than when evaluating 

flammability).
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Figure 1. Refrigerant Safety Group Classification

Safety Group

Increasing 

Flammability

Higher 

Flammability

A3 B3

Lower 

Flammability

A2 B2

A2L B2L

No Flame 

Propagation

A1 B1

Lower 

Toxicity

Higher 

Toxicity

Increasing Toxicity

Refrigerants with a flammability classification of 3 identified by ASHRAE in ASHRAE 

34–2013 include the HCs R-1150 (ethylene), R-170 (ethane), R-1270 (propylene), R-290 

(propane), R-50 (CH4), R-600 (n-butane), R-600a (isobutane), R-601 (n-pentane), and R-601a 

(isopentane); the HC blends R-433A, R-433B, R-433C, R-436A, R-436B, R-441A, and R-443A; 

and the refrigerant blends R-429A, R-430A, R-431A, R-432A, R-435A, and R-511A. All but 

one of these refrigerants contain HCs, with some also containing the flammable compounds 

dimethyl ether and HFC-152a. 

In addition to refrigerants specifically identified in the ASHRAE 34-2013 standard as 

having a flammability classification of 3, EPA is proposing that refrigerants meeting the criteria 

of that standard are unacceptable. In other words, refrigerants are unacceptable if they exhibit 

flame propagation and either have a heat of combustion of 19,000 kJ/kg (8,174 BTU/lb) or 

greater or an LFL of 0.10 kg/m3or lower, when tested in accordance with ASTM E681 using a 

spark ignition source at 60 °C and 101.3 kPa. We are aware of a number of refrigerant products 

sold over the internet aimed at the market for retrofit usage in refrigeration and AC equipment
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using HCFC-22 with names containing “22a,” such as R-22a, Blue Sky 22a refrigerant, Coolant 

Express 22a, DURACOOL-22a, EC-22, Ecofreeeze 22a, EF-22a, Envirosafe 22a, ES-22a, Frost 

22a, HC-22a, Maxi-Fridge, MX-22a, Oz-Chill 22a, and RED TEK 22a. EPA has analyzed one of 

these refrigerants and determined that it contained propane mixed with a pine-scented odorant. 

These refrigerants are also identified as flammable in their Safety Data Sheets and are often 

identified as “liquified petroleum gases.” Although none of these liquified petroleum gas 

refrigerants have been submitted to SNAP for review, EPA expects that they all are comparable 

in their flammability to propane and other refrigerants that meet an ASHRAE flammability 

classification of 3. It is our understanding these refrigerants are all of the same or similar 

composition, are produced by only one or two facilities using the same process, and then are 

marketed under different names.

We request comment on whether we should list as unacceptable both any refrigerant that 

meets the criteria in ASHRAE 34-2013 for a flammability classification of 3 and those 

refrigerants currently identified in the ASHRAE standard with a flammability classification of 3.

We also request comment on whether the listing decision should specifically describe the 

criteria, i.e., “Any refrigerant that (1) exhibits flame propagation when tested by ASTM E681 at 

standard temperature and pressure and at 60 °C and (2) that either has a heat of combustion of 

19,000 kJ/kg (8,174 BTU/lb) or greater or has an LFL of 0.10 kg/m3or lower.” 

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for these end–uses with respect to SNAP criteria?

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; ecosystem effects, particularly 
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from negative impacts on aquatic life. These and other environmental and health risks (e.g., 

flammability, exposure, and toxicity) are discussed below. In addition, a technical support 

document that provides the Federal Register citations concerning data on the SNAP criteria (e.g., 

ODP, GWP, VOC, toxicity, flammability) for acceptable alternatives in the relevant end-uses 

may be found in the docket for this rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015a).

(a) Environmental impacts

EPA has listed a number of alternatives as acceptable for retrofit usage in unitary split 

AC systems and heat pumps. All of the listed alternatives are HFC blends, with some containing 

small percentages (approximately five percent or less) of HCs. Specific blends include: R125/134a/600a (28.1/70/1.9), R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R407F, R-417A, R-417C, R-421A, R-422B, R-422C, R-422D, R-424A, R-427A, R-434A, R438A, R-507A, and RS-44 (2003 composition). These blends are all non-ozone-depleting. As 

shown in Table 3, they have GWPs ranging from approximately 1,770 for R-407C to 3,990 for 

R-507A. Knowingly venting or releasing these refrigerants is limited by the venting prohibition 

under section 608(c)(2) of the CAA, codified at 40 CFR 82.154(a)(1). The HFC components of 

these refrigerant blends are excluded from the definition of VOC under CAA regulations (see 40 

CFR 51.100(s)) addressing the development of SIPs to attain and maintain the NAAQS, while 

the HC components are VOC. 

Table 3: GWP, ODP, and VOC Status of Flammable Refrigerants Compared to Other Refrigerants for 

Retrofit in Existing Equipment for Residential and Light Commercial AC (Unitary Split AC systems and 

Heat Pumps)1,2, 3,4

Refrigerants GWP ODP VOC Proposal

All refrigerants identified as 

flammability Class 3 in 

ANSI/ASHRAE Standard 34-2013

2-120 0 Yes3 Unacceptable

All refrigerants meeting the criteria 

for flammability Class 3 in 

ANSI/ASHRAE Standard 34-2013, 

including, but not limited1, to the 

products named R-22a, 22a, Blue 

2-120 0 Yes3 Unacceptable
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Sky22a refrigerant, Coolant Express 

22a, DURACOOL-22a, EC-22, 

Ecofreeeze EF-22a, EF-22a, 

Envirosafe 22a, ES-22, Frost 22a, HC22a, Maxi-Fridge, MX-22a, OZ-Chill 

22a, Priority Cool, and RED TEK22a

R-404A, R-407A, R-407C, R-407F, 

R-421A, R-427A, R-507A 

1,770-3,990 0 No No change

Hot Shot 2, R-125/R-134a/R-600a 

(28.1/70.0/1.9), R-125/R-290/R134a/R-600a (55.0/1.0/42.5/1.5), R417A, R-422B, R-422C, R-422D, R424A, R-427A, R-434A, R-437A, R438A, RS-44 (2003 formulation) 

1,810-3,390 0 Yes4 No change

1The table does not include not-in-kind technologies listed as acceptable for the stated end-use.

2HCFC-22 and several blends containing HCFCs are also listed as acceptable but their use is severely restricted by 

the phasedown in HCFC production and consumption.

3The entire refrigerant or most of the constituents are VOC.

4One or more constituents of the refrigerant are VOC.

Both the acceptable refrigerants and those proposed to be unacceptable are non-ozone 

depleting. The refrigerants proposed to be unacceptable would result in higher VOC emissions 

than the acceptable refrigerants, with the saturated HCs (e.g., propane, isobutane) having a low 

impact and unsaturated HCs (e.g., propylene) having a significant impact (see section VI.A.1.b.i 

above. The refrigerants proposed to be unacceptable have significantly lower GWPs than the 

refrigerants that would remain acceptable.

(b) Flammability

All refrigerants currently listed as acceptable in this end-use are nonflammable, resulting 

in no risk of fire or explosion from flammability of the refrigerant. In comparison, ASHRAE 

Class 3 refrigerants are highly flammable. t As discussed further below in section 

VI.A.3.b.iii.(b), EPA analyzed the flammability impacts of one ASHRAE Class 3 refrigerant, R443A, and found that a release of the entire refrigerant charge inside a building from a unitary 

split AC system or heat pump could result in surpassing the LFL (ICF, 2015f). Because of the 

large charge sizes required for this type of equipment and the similar LFLs for other ASHRAE 

Class 3 refrigerants, it is likely the LFL would be surpassed for other ASHRAE Class 3 
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refrigerants. Fires and harm to people and property have already occurred in multiple cases due 

to retrofit or drop-in use of R-22a and similar products in existing unitary split AC systems.

(c) Toxicity

The HFC components of acceptable substitutes in this end-use, as well as the HFC 

components of the unacceptable refrigerant blends have exposure limits, such as WEELs from 

the AIHA or manufacturer acceptable exposure limits, of 1,000 ppm on an 8-hr TWA and the 

HC components of both the acceptable refrigerants and those proposed unacceptable have 

exposure limits ranging from 500 to 1,000 ppm (8-hr TWA for TLVs from ACGIH and 10-hr 

TWA for recommended exposure limits (RELs) from NIOSH). Both the acceptable refrigerants 

and the proposed unacceptable refrigerants are able to be used be used in this end-use in 

accordance with their respective 8-hr or 10-hr workplace exposure limits. Acute exposure may 

also be of concern during use in unitary split AC systems and heat pumps because of possible 

exposure to consumers in the event of a sudden release. The currently acceptable refrigerants 

typically have high acute exposure limits for their components based upon cardiotoxic effects of 

halocarbons over 10,000 ppm (e.g., 350,000 cardiotoxic no-observed adverse effect level for 

HFC-32 over 5 minutes) or have components with STELs or AEGLs (e.g., 8,000 ppm 10-minute 

AEGL-1 for HFC-134a component). Acute exposure limits for components of the ASHRAE 

Class 3 refrigerants are comparable or lower, ranging from 1,500 ppm (e.g., excursion limit for 

propylene) to 6,900 ppm (AEGL-1 over 30 minutes for propane). Because of the large charge 

sizes required for this type of equipment and somewhat lower acute exposure limits for the 

hydrocarbon components of ASHRAE Class 3 refrigerants, acute exposure could be a concern 

for specific refrigerants. For example, as discussed further below in section VI.A.3.b.iii.(c), EPA 

analyzed the toxicity impacts of the propylene component of R-443A, and found that a 
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catastrophic leak of that refrigerant inside a building from a unitary split AC system or heat 

pump resulted in estimated exposure levels at least four-fold that of the 1,500 ppm acute 

exposure limit (ICF, 2015f).

At this time, despite the potential reduced climate risks from using a highly flammable 

refrigerant with lower GWP does not outweigh the flammability risks of using these refrigerants 

in existing equipment that was designed for nonflammable refrigerants poses significantly 

greater risk. In addition to flammability risk, in at least some cases, acute exposure limits of the 

proposed unacceptable refrigerants may be more difficult to attain than those for acceptable 

refrigerants in this end-use. Therefore, EPA proposes that the highly flammable refrigerants 

proposed to be unacceptable pose greater overall risk to human health and the environment than 

other substitutes for retrofit in the residential and light commercial AC and heat pumps end-use. 

However, the Agency may look back at these end-uses for other reasons through a separate 

action if we receive information on how risks from the refrigerants proposed for listing as 

unacceptable can be sufficiently mitigated, we may reconsider any final action listing these 

refrigerants as unacceptable in this end use.

iv. When would the listings apply?

EPA proposes that these listings would apply 30 days after the date of publication of a 

final rule. To date, only one of these substitutes have been submitted to EPA for this end-use and 

this submission is currently incomplete. Thus, under 40 CFR 82.174, manufacturers are 

prohibited from introducing them into interstate commerce for this end-use. Thus, manufacturers 

and service technicians should not be currently using these substitutes in the manner that would 

be prohibited by this proposed listing decision. Further, a date or 30 days after the date of 

publication of a final rule, the same as the proposed effective date of this regulation, would 
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protect technicians and consumers from the risks of these substitutes at the earliest opportunity.

v. What is the relationship between this SNAP rule and other federal

rules?

EPA is not aware of other federal rules that would apply to the use of these flammable 

refrigerants for retrofits in existing unitary split AC systems and heat pumps. 

vi. On which topics is EPA specifically requesting comment?

EPA requests comment on all aspects of this proposal. In particular, we request comment 

on our proposal to list as unacceptable for retrofit use in existing unitary split AC systems and 

heat pumps all refrigerants identified as flammability Class 3 in ANSI/ASHRAE Standard 34–

2013 and all refrigerants meeting the criteria for flammability Class 3 in ANSI/ASHRAE 

Standard 34–2013, including, but not limited to, refrigerant products sold under the names R22a, 22a, Blue Sky 22a refrigerant, Coolant Express 22a, DURACOOL-22a, EC-22, Ecofreeeze 

22a, EF-22a, Envirosafe 22a, ES-22a, Frost 22a, HC-22a, Maxi-Fridge, MX-22a, Oz-Chill 22a, 

Priority Cool, and RED TEK 22a.

b. Proposed listing of propylene and R-443A as unacceptable for new 

residential and light commercial AC and heat pumps, cold storage

warehouses, and centrifugal and positive displacement chillers

EPA is proposing to list the refrigerants propylene (R-1270) and R-443A as unacceptable 

in new equipment in residential and light commercial AC and heat pumps, cold storage 

warehouses, and centrifugal and positive displacement chillers for commercial comfort AC.

i. What are the affected end-uses?

The refrigeration and AC end-uses addressed in this action include: 

o centrifugal and positive displacement chillers;
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o residential and light commercial AC and heat pumps, including

both self-contained units and split systems; and

o cold storage warehouses.

EPA has received a submission for R-443A in new residential and light 

commercial AC and heat pumps and for new window air conditioners, a subset of 

that end-use. We have also received a submission for propylene for use in new 

chillers for commercial comfort AC (centrifugal and positive displacement 

chillers) and for cold storage warehouses. Because the two refrigerants have 

similar properties and risk profiles, we reviewed both refrigerants for all four enduses.

ii. Which refrigerants is EPA proposing to list as unacceptable?

Propylene, also known as propene or R-1270, is a HC with three carbons, the chemical 

formula C3H6, and the CAS Reg. No. 115-17-1. R-443A is a HC blend27 consisting of 55 percent

propylene, 40 percent propane, and five percent isobutane by weight. 

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for these end–uses with respect to SNAP criteria?

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks (e.g., 

flammability, exposure, and toxicity) are discussed below. In addition, a technical support 

 

27 EPA notes that under the SNAP program, we review and list refrigerants with specific compositions (59 FR 

13,044; March 18, 1994). To the extent possible, we follow ASHRAE’s designations for refrigerants. Blends of 

refrigerants must be reviewed separately. For example, we consider each blend of propane with isobutane to be a 

different and unique refrigerant, and each would require separate submission, review and listing. 
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document that provides the Federal Register citations concerning data on the SNAP criteria (e.g., 

ODP, GWP, VOC, toxicity, flammability) for acceptable alternatives in the relevant end-uses 

may be found in the docket for this rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015a).

(a) Environmental impacts

Propylene and R-443A have an ODP of zero. Many acceptable substitutes in the 

refrigeration and AC end-uses addressed in this proposed rule also have an ODP of zero (e.g., 

HFCs, HFOs, CO2, ammonia, HCs, and not-in-kind technologies).28 Of the acceptable 

refrigerants having an ODP, they have ODPs ranging from 0.00024 to 0.047 (EPA, 2015a).29

Thus, propylene and R-443A have ODPs comparable to or less than the ODPs of other 

alternatives in the end-uses proposed in this rule.

Propylene and the components of R-443A have relatively low GWPs of less than ten. As 

shown in Table 4, GWPs of acceptable refrigerants in these end-uses range from zero to 3,990, 

depending on the specific end-use. (Elsewhere in this proposal, we propose to find unacceptable 

a number of higher GWP blends for use in new chillers and new cold storage warehouses; if that 

portion of this proposed rule was finalized as proposed, the highest GWP for any acceptable 

refrigerant in new chillers would be 630 and in new cold storage warehouses would be 

approximately 1,830.) The GWPs of propylene and R-443A are comparable to or higher than 

those of CO2, propane, isobutane, R-441A, ammonia, HFO-1234ze(E), trans-1-chloro-3,3,3-

trifluoroprop-1-ene, and not-in-kind technologies such as Stirling cycle, water/lithium bromide 

absorption, dessicant cooling, or evaporative cooling, each of which is acceptable in new 

 

28 We assume that substitutes containing no chlorine, bromine, or iodine have an ODP of zero.

29 Under EPA’s phaseout regulations, virgin HCFC-22, HCFC-142b, and blends containing HCFC-22 or HCFC142b may only be used to service existing appliances. Consequently, virgin HCFC-22, HCFC-142b and blends 

containing HCFC-22 or HCFC-142b may not be used to manufacture new pre-charged appliances or appliance 

components or to charge new appliances assembled onsite. Substitutes containing these HCFCs have ODPs ranging 

from 0.01 to 0.065. Class I and II ODS historically used as refrigerants in these end-uses have ODPs that range from 

0.01 to 1.0.
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equipment for one or more of the four proposed end-uses. In addition, propylene and R-443A 

have lower GWPs than those of ODS historically used in these end-uses, CFC–12 (GWP = 

10,900); HCFC–22 (GWP = 1,810); and R–502 (GWP = 4,660) (IPCC, 2007).

Table 4: GWP, ODP, and VOC Status of Propylene and R-443A Compared to Other Refrigerants in New 

Equipment for Residential and Light Commercial AC and Heat Pumps, Cold Storage Warehouses, 

Centrifugal Chillers and Positive Displacement Chillers. 1,2,3,4

Refrigerants GWP ODP VOC Proposal

Propylene, R-443A 2-3 0 Yes Unacceptable

New Residential and Light Commercial AC and Heat Pumps

HFC-323, HFC-134a, R-404A, R407A, R-407C, R-407F, R-410A, R410B, R-417A, R-421A, R-507A 675-3,990 0 No No change

R-290 3,R-441A3, THR-033, R-125/R134a/R-600a (28.1/70.0/1.9), R125/R-290/R-134a/R-600a 

(55.0/1.0/42.5/1.5), R-422B, R-422C, 

R-422D, R-424A, R-434A, R-437A, 

R-438A, RS-44 (2003 formulation)

3-3,390 0 Yes4 No change

New Cold Storage Warehouses

CO2, R-450A, R-513A 1-630 0-0.040 No No change

IKON A, IKON B, RS-24 (2002 

composition), RS-44, SP34E, THR02, THR-03, THR-04

30-1,825 0 Yes4 No change

New Centrifugal Chillers

Ammonia, HFO-1234ze(E), trans-1-

chloro-3,3,3-trifluoroprop-1-ene, R450A, R-513A

0-630 0-0.00034 No No change

IKON A, IKON B, THR-02 30-920 Not public Yes4 No change

New Positive Displacement Chillers

Ammonia, HFO-1234ze(E), R-450A, 

R-513A 

0-631 0 No No change

IKON B, THR-02 0-920 0 Yes4 No change

1The table does not include not-in-kind technologies listed as acceptable for the stated end-use.

2HCFC-22 and several blends containing HCFCs are also listed as acceptable but their use is severely restricted by 

the phasedown in HCFC production and consumption.

3Listed only for use in room AC units.

4One or more constituents of the refrigerant are VOC.

In addition to global impacts on the atmosphere, EPA evaluated potential impacts of 

propylene and the components of R-443A on local air quality. Propylene and the three 

components of R-443A, propylene, propane and isobutane are not excluded from the definition 

of VOC under CAA regulations (see 40 CFR 51.100(s)) addressing the development of SIPs to 
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attain and maintain the NAAQS. However, there is a significant difference in the photochemical 

reactivity between propylene and the other two HCs. Propylene, because it has an unsaturated 

double bond between two carbons, is significantly more reactive in the atmosphere than propane, 

the saturated HC with the same number of carbon atoms, and isobutane. For example, the 

Maximum Incremental Reactivity (MIR) of propylene, in gram ozone per gram of the substance, 

is 11.57 while the MIR of propane is 0.56 g O3/g and the MIR of isobutane is 1.34 g O3/g (ICF, 

2014a). Thus, propylene is roughly 21 times more reactive than propane and roughly nine times 

more reactive than isobutane for the same mass. Propylene is also more than 100 times more 

reactive than HFC-134a (MIR<0.1) and a number of other HFCs acceptable for these end-uses 

and is significantly more reactive than unsaturated halogenated substitutes in these end-uses, 

such as HFO-1234yf (MIR=0.28), HFO-1234ze(E) (MIR=0.098), or trans-1-chloro-3,3,3-

trifluoroprop-1-ene (Solstice TM 1233zd(E)) (MIR=0.040).

Based on analyses described below, EPA estimates that potential emissions of saturated 

HCs if used as refrigerant substitutes in all end-uses in the refrigeration and AC sector would 

have little impact on local air quality, while emissions of propylene, including propylene from R443A, could have a significant negative impact (ICF, 2014a). 

EPA analyzed a number of scenarios to consider the potential impacts on local air quality 

if HC refrigerants were used widely. We used EPA’s Vintaging Model to estimate the HC 

emissions from these scenarios and EPA’s Community Multiscale Air Quality (CMAQ) model to 

assess their potential incremental contributions to ground-level ozone concentrations (ICF, 

2014a). The first analysis assumed that all refrigerant used was emitted to the atmosphere, as it 

could be if refrigerants were exempted from the venting prohibition of CAA section 608. In that 

highly conservative scenario, the model predicted that the maximum increase in the 8-hour 
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average ground-level ozone concentration would be 0.72 parts per billion (ppb) in Los Angeles if 

the most reactive saturated HC, isobutane, were the only refrigerant and it was all emitted to the 

atmosphere. If the unsaturated HC propylene was assumed to be the only refrigerant used in 

equipment and it was all emitted (if it were to be exempted from the venting prohibition under 

CAA section 608), the model predicted that the maximum increase in the 8-hour average groundlevel ozone concentration would be 6.61 ppb in Los Angeles, which is the area with the highest 

level of ozone pollution in the United States. For purposes of comparison, the ground-level 

ozone limit under the NAAQS has been 75 ppb since 2008.

30 We have concerns that widespread 

emissions of propylene from use as a refrigerant could interfere with the ability of some 

nonattainment areas to reach attainment, both with the 2008 NAAQS and the new, more 

stringent standard.

EPA also performed less conservative analyses that considered the end-uses where these 

refrigerants would more likely be used, based upon submissions received and upon end-uses 

where there are industry standards addressing the use of flammable refrigerants. Propylene was 

previously listed as an acceptable substitute in industrial process refrigeration. EPA has received 

submissions for use of R-443A in residential and light commercial AC and heat pumps and 

window air conditioners. We have received a SNAP submission for use of propylene in cold 

storage warehouses and in commercial comfort AC in chillers, and have received inquiries about 

using propylene in retail food refrigeration. In addition, EPA is aware that UL has developed 

standards addressing use of flammable refrigerants in stand-alone retail food refrigeration 

equipment and coolers; vending machines; water coolers; commercial ice machines; household 

refrigerators and freezers; and room air conditioners; and is currently developing revisions to UL 

 

30 The standard has recently been lowered to 70 ppb (80 FR 65292; October 26, 2015).
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1995 for residential AC equipment. Thus, we considered scenarios where propylene would be 

used and emitted 1) in all stationary AC and refrigeration end-uses, but excluding MVAC, 2) in 

all refrigeration end-uses and all AC end-uses except for MVAC and chillers for commercial 

comfort AC. For further details on the scenarios and end-uses in the analysis, see ICF, 2014a.

Based on this still conservative assessment of refrigerant use, we found that if all the 

refrigerant in appliances in the end-uses analyzed were to be emitted, there would be a worstcase impact of 4.47 ppb ozone in the Los Angeles area. In the other cities examined in the 

analysis, Houston and Atlanta, which have also had historically high levels of ambient ozone, 

impacts were smaller (as much as 0.67 and 0.39 ppb, respectively) (ICF, 2014a). Approximately 

72-73 percent of the emissions were estimated to come from the residential and light commercial 

AC and heat pumps end-use in those less conservative analyses, indicating that emissions from 

this end-use could have a particularly large impact. Both the most conservative as well as the less 

conservative but more probable assessments indicated there could be significant air quality 

impacts of these refrigerants if they are released to the atmosphere. 

A more recent analysis specifically examining use of R-443A and propylene in 

residential and light commercial AC and heat pumps, cold storage warehouses, and commercial 

comfort AC (centrifugal and positive displacement chillers) found noticeable impacts from these 

end-uses. If propylene were the only refrigerant in these end-uses and it was emitted from 

residential and light commercial AC and heat pumps and cold storage warehouses,31 the analysis 

indicated there would be a worst-case impact of 4.45 ppb ozone in the Los Angeles area, 1.21 

ppb in Houston, and 0.65 in Atlanta, respectively. (ICF, 2015a) Assuming that propylene were 

used in all cold storage warehouses and centrifugal and positive displacement chillers; room air 

 

31 The analysis assumed that local and state safety regulations required recovery of refrigerant from commercial 

comfort air conditioning equipment.
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conditioners could use either R-443A or the currently listed VOC refrigerants propane or R441A; other residential and light commercial AC and heat pumps all used R-443A; and these 

refrigerants were all emitted from cold storage warehouses and residential and light commercial 

AC and heat pumps, there would be a worst-case impact of 2.57 ppm ozone in the Los Angeles 

area, 0.77 ppb in Houston, and 0.44 ppb in Atlanta, respectively (ICF, 2015a). 

We anticipate that propylene and R-443A in the proposed end-uses would be subject to 

the CAA section 608 venting prohibition. While potential air quality impacts of propylene and 

R-443A would likely be reduced through the CAA section 608 venting prohibition, but we do 

not consider this sufficient to mitigate the risks of these refrigerants in the proposed end-uses, 

particularly in light of their photochemical reactivity and toxicity. EPA is not aware of 

commercially available recovery equipment for flammable refrigerants (e.g., built with sparkproof components and other features to reduce flammability risks), and without such equipment, 

emissions could occur. Further, other emissions could occur that are not subject to the venting 

prohibition and no equipment is free of refrigerant emissions. Because of the reactivity of these 

refrigerants, those emissions could interfere with the ability of some nonattainment areas to reach 

attainment, both with the 2008 NAAQS and the new, more stringent standard.

Ecosystem effects, primarily effects on aquatic life, of the substitutes are expected to be 

small as are the effects of other acceptable substitutes. Propylene, propane and isobutane are all 

highly volatile and would evaporate or partition to air, rather than contaminate surface waters. 

Neither propylene nor R-443A pose a greater risk of aquatic or ecosystem effects than those of 

other substitutes for these uses.

(b) Flammability

Propylene and R-443A are both designated as A3 refrigerants according to ASHRAE 34-
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2013 and subsequent addenda. Thus, their flammability is comparable to that of ethane, propane, 

isobutane, and R-441A, other refrigerants that EPA has listed as acceptable, subject to use 

conditions, in a number of end-uses (76 FR 78832, December 20, 2011; 80 FR 19454, April 10, 

2015).

Due to their flammable nature, propylene and R-443A could pose a significant safety 

concern for workers and consumers if they are not properly handled. In the presence of an 

ignition source (e.g., static electricity spark resulting from closing a door, using a torch during 

service, or a short circuit in wiring that controls the motor of a compressor), an explosion or a 

fire could occur when the concentration of refrigerant exceeds its LFL. The LFLs of the 

substitutes are: 2.03 percent for R-443A (A.S. Trust & Holdings, 2014) and 2.0 percent for 

propylene (Airgas, 2015). 

To determine whether flammability would be a concern for manufacturing and service 

personnel or for consumers, EPA analyzed a plausible worst-case scenario to model a 

catastrophic release of the refrigerants. The worst-case scenario analysis for each refrigerant 

revealed that even if the full charge of a window AC unit is emitted within one minute, neither of 

these refrigerants reached their respective LFLs. However, for larger residential AC systems, 

such as for a unitary split AC system, charges are significantly higher, and a catastrophic leak of 

refrigerant inside a building could result in surpassing the LFL (ICF, 2015f).

EPA also reviewed the submitters’ detailed assessments of the probability of events that 

might create a fire and engineering risk and approaches to avoid sparking from the refrigeration 

equipment. Further information on these analyses and EPA’s risk assessments are available in 

public docket EPA-HQ-OAR-2015-0663. Although the analysis showed no potential for the 

released refrigerant from one piece of equipment to reach the LFL, manufacturing and service 
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personnel or consumers may not be familiar with refrigeration or AC equipment containing a 

flammable refrigerant. Thus, additional risk mitigation would be appropriate. Use conditions 

such as those recently finalized for ethane, isobutane, propane, and R-441A could potentially be 

adopted by regulation as use conditions to mitigate flammability concerns from propylene and R443A in end-uses for self-contained refrigeration and AC equipment such as stand-alone retail 

food refrigeration units, household refrigerators and freezers, vending machines, and room air 

conditioners for residential and light commercial AC and heat pumps. We further note that 

refrigerant handling equipment designed to be used safely with flammable refrigerants are not 

commercially available in the United States nor are standards to test and certify such equipment 

in place. Assuming these substitutes would not be exempted from the venting prohibition under 

CAA section 608 due to potential local air quality impacts, the lack of such equipment and 

standards for refrigerant recovery calls into question whether flammability risks could be 

adequately addressed through use conditions at this time.

(c) Toxicity 

In evaluating potential toxicity impacts of propylene and R-443A on human health, EPA 

considered both occupational risk, and for end-uses in the household or in retail establishments, 

also consumer risks. EPA investigated the risk of asphyxiation and of exposure to toxic levels of 

refrigerant for a plausible worst-case scenario and a typical use scenario for each refrigerant. In 

the worst-case scenario of a catastrophic leak, we modeled release of the unit’s full charge within 

one minute into a confined space to estimate concentrations that might result. We considered a 

conservatively small space appropriate to each end-use, such as a small utility room of 18 m3for 

a unitary split AC system, or a small bedroom of 41 m3for a room air conditioner. EPA used the 

same assumptions when evaluating other substitutes, such as CO2, HFC-32, propane and R-
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441A.

To evaluate toxicity of both refrigerants, EPA estimated the maximum TWA exposure 

both for a short-term exposure scenario, with a 30-minute TWA exposure, and for an 8-hour 

TWA that would be more typical of occupational exposure for a technician servicing the 

equipment. We compared these short-term and long-term exposure values to relevant industry 

and government workplace exposure limits for propylene and the components of R-443A 

(including potential impurities). The modeling results indicate that both the short-term (30-

minute) and long-term (8-hour) worker exposure concentrations would be below the relevant 

workplace exposure limits, such as the OSHA PEL, the NIOSH REL, or the ACGIH’s TLV in 

cold storage warehouses, commercial comfort AC equipment, and residential and light 

commercial AC and heat pumps (ICF, 2015 f,g,h). Because there is not an established short-term 

exposure limit (STEL) for propylene, propane, or isobutane, we considered information on shortterm exposure such as a short-term excursion limit based on the TLV or the National Research 

Council’s AEGL. The respective workplace exposure limits we considered for the various 

compounds, including components of the refrigerant blend R-443A, are as follows:

 Isobutane: 800 ppm REL on 10-hr TWA; 6,900 ppm over 30 minutes 

 Propane: 1,000 ppm PEL/TLV on 8-hr TWA; 6,900 ppm AEGL-1 over 30 minutes

 Propylene: 500 ppm TLV on 8-hr TWA; 1,500 ppm excursion limit over 30 minutes

In comparison, HFCs and the HFC components of acceptable substitutes in these enduses, have exposure limits, such as WEELs from the AIHA or manufacturer acceptable exposure 

limits, of 1,000 ppm on an 8-hr TWA and the HC components of both the acceptable refrigerants 

and those proposed unacceptable have exposure limits ranging from 500 to 1,000 ppm (8-hr 

TWA for TLVs from ACGIH and 10-hr TWA for recommended exposure limits (RELs) from 
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NIOSH). HFOs acceptable in centrifugal and positive displacement chillers have WEELs of 800 

ppm. Both the acceptable refrigerants and the proposed unacceptable refrigerants are able to be 

used in these end-uses in accordance with their respective workplace exposure limits.

For equipment with which consumers might come into contact, such as residential air 

conditioners and heat pumps, EPA also performed a consumer exposure analysis. In this 

analysis, we examined potential catastrophic release of the entire charge of the substitute in one 

minute under a worst-case scenario. We did not examine exposure to consumers in cold storage 

warehouses and commercial comfort AC (chillers), since such equipment is typically used in 

workplaces where access is controlled and not in homes or public spaces. The analysis was 

undertaken to determine the 30-minute TWA exposure levels for the substitute, which were then 

compared to the toxicity limits to assess the risk to consumers.

EPA considered toxicity limits for consumer exposure that reflect a short-term exposure 

such as might occur at home or in a store or other public setting where a member of the general 

public could be exposed and could then escape. Specific toxicity limits that we used in our 

analysis of consumer exposure include:

 Isobutane: 6,900 ppm over 30 minutes

 Propane: 6,900 ppm AEGL-1 over 30 minutes

 Propylene: 1,500 ppm excursion limit32 over 30 minutes

The analysis of consumer exposure assumed that 100 percent of the unit’s charge would 

be released over one minute, at which time the concentration of refrigerant would peak in an 

enclosed space, and then steadily decline. Refrigerant concentrations were modeled under two air 

change scenarios, believed to represent the baseline of potential flow rates for a home or other 

 

32 The ACGIH recommends that short-term exposures of chemicals not surpass three times the 8-hr TWA TLV over 

15 minutes and at no time surpass five times the 8-hr TWA TLV. For propylene, this equates to 1,500 to 2,500 ppm.
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public space, assuming flow rates of 0.11 and 0.67 ACH (ICF, 2015f). Under the very 

conservative assumptions used in the consumer exposure modeling, the estimated 30-minute 

consumer exposures to the refrigerants substantially exceed the toxicity limits for the propylene 

component of R-443A. All of the estimates of exposure exceeded the 1,500 ppm excursion limit 

for propylene by at least four-fold, with estimates ranging from approximately 6,200 ppm to 

26,500 ppm. This occurred whether considering lower or higher charge sizes of 1,000 g or 1,500 

g; lower or higher ventilation levels of 0.11 or 0.67 ACH; or whether stratification was assumed 

to occur or not. Even if the charge of R-443A were reduced to 100 g, there would still be an 

exceedance of the short-term excursion limit. In comparison, EPA previously found that a charge 

of 180 g of propane in a room air conditioner could meet its AEGL-1 and a charge of 195 g of R441A in a room air conditioner could meet the various short-term exposure limits for its 

components under the same assumptions of ventilation and room size (ICF, 2014b; ICF, 2014c). 

Thus, EPA has concern about the exposure levels and toxicity of propylene and R-443A in 

residential and light commercial AC and heat pumps. 

In comparison, the currently acceptable refrigerants typically have high acute exposure 

limits for their components based upon cardiotoxic effects of halocarbons over 10,000 ppm (e.g., 

350,000 cardiotoxic no-observed adverse effect level for HFC-32 over 5 minutes) or have 

components with STELs or AEGLs (e.g., 8,000 ppm 10-minute AEGL-1 for HFC-134a 

component). Acute exposure limits for propylene and R-443A’s components range from 1,500 

ppm for propylene to 6,900 ppm (AEGL-1 over 30 minutes for propane). Because of the 

relatively low acute exposure limit for propylene, acute exposure is a greater concern than for 

other acceptable refrigerants in residential and light commercial AC systems and heat pumps. 

In summary, EPA’s concerns about propylene and R-443A encompass both toxicity and 
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exposure and impacts of these refrigerants on local air quality.33 Other acceptable refrigerants are 

available in the same end-uses that offer lower toxicity and air quality impacts, and comparable 

flammability, GWP, and ODP to R-443A and propylene. Thus, we are proposing to list 

propylene and R-443A as unacceptable in these end-uses because they pose significantly more 

risk than other available refrigerants. For further information, including EPA’s risk screens and 

risk assessments as well as information from the submitters of the substitutes, see docket EPA–

HQ–OAR–2015-0663.

iv. When would the listings apply?

EPA proposes that this listing would apply 30 days after the date of publication of a final 

rule. To date, the submissions for R-443A and propylene are incomplete. Thus, under 40 CFR 

82.174, manufacturers are prohibited from introducing them into interstate commerce for these 

end-uses. Thus, manufacturers and service technicians should not be currently using these 

substitutes in the manner that would be prohibited by this proposed listing decision. Further, a 

date of 30 days after the date of publication of a final rule, the same as the proposed effective 

date of this regulation, would protect against the risks of these substitutes at the earliest 

opportunity.

v. What is the relationship between this SNAP rule and other

 federal rules? 

EPA is not aware of other federal rules applying to these two refrigerants in the four 

proposed end-uses.

vi. On which topics is EPA specifically requesting comment?

EPA requests comment on all aspects of this proposal. In particular, we request comment 

 
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on our proposal to list the refrigerants propylene (R-1270) and R-443A as unacceptable in new 

equipment in residential and light commercial AC and heat pumps, cold storage warehouses, and 

centrifugal and positive displacement chillers for commercial comfort AC. EPA specifically 

requests comment on the end-uses proposed here.

4. Proposed changes in listing status

a. Proposed change of status for certain HFC refrigerants for new 

centrifugal chillers

As provided in the following table, EPA is proposing to change the status of numerous 

refrigerants from acceptable to unacceptable for new centrifugal chillers:

Table 5. Proposed Change of Status Decisions for New Centrifugal Chillers

End-use Substitutes Proposed Decision

Centrifugal Chillers (new only) FOR12A, FOR12B, HFC-134a, HFC227ea, HFC-236fa, HFC-245fa, R125/134a/600a (28.1/70/1.9), R125/290/134a/600a (55.0/1.0/42.5/1.5), 

R-404A, R-407C, R-410A, R-410B, R417A, R-421A, R-422B, R-422C, R422D, R-423A, R-424A, R-434A, R438A, R-507A, RS-44 (2003 

composition), and THR-03.

Unacceptable as of January 1, 

2022

i. What is the affected end-use?

(a) Overview of equipment covered

In the initial rule establishing the SNAP program (59 FR 13044; March 18, 1994), EPA 

included within the refrigeration and AC sector the end-use “commercial comfort air 

conditioning” and then elaborated on that end-use saying that “CFCs are used in several different 

types of mechanical commercial comfort AC systems, known as chillers.” EPA indicated “that 

over time, existing cooling capacity [from chillers] will be either retrofitted or replaced by 

systems using non-CFC refrigerants in a vapor compression cycle or by alternative 

technologies.” We also explained in that rule that vapor compression chillers can be categorized 
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by the types of compressor used, including centrifugal, rotary, screw, scroll and reciprocating 

compressors. These compressor types are also divided into centrifugal and positive displacement 

chillers, the latter of which includes those with reciprocating, screw, scroll or rotary 

compressors. This section of the proposed rule covers centrifugal chillers.

Centrifugal chillers are equipment that utilize a centrifugal compressor in a vaporcompression refrigeration cycle. Centrifugal chillers are typically used for commercial comfort 

AC although other uses do exist. All uses of centrifugal chillers would be affected by this 

proposed rule except as described below. Centrifugal chillers can be found in office buildings, 

hotels, arenas, convention halls, airport terminals and other buildings. Centrifugal chillers tend to 

be used in larger buildings.

For commercial comfort, centrifugal chillers typically cool water that is then pumped to fan 

coil units or other air handlers to cool the air that is supplied to the occupied spaces rejecting the 

heat to the water. The heat absorbed by the water can then be used for heating purposes, and/or 

can be rejected directly to the air (“air-cooled”), to a cooling tower or body of water (“watercooled”) or through evaporative coolers (“evaporative-cooled”). A centrifugal chiller or a group 

of centrifugal chillers could similarly be used for district cooling where the chiller plant cools 

water or another fluid that is then pumped to multiple locations being served such as several 

different buildings within the same complex. All such centrifugal chillers are covered by this 

section of the proposed rule.

Centrifugal chillers are used for other applications besides commercial comfort AC and are 

covered under this section of the proposed rule except as noted below.in section VI.A.4.a.i.(c). 

For instance, centrifugal chillers used to cool equipment, such as in data centers, are covered 

under this section of the proposed rule.
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(b) What other types of equipment are used for similar 

applications but are not covered by this section of the proposed rule? 

Other equipment including packaged rooftop units and split system air conditioners, both of 

which fall under the SNAP end-use “household and light commercial air conditioning,” can also 

be used for commercial comfort AC, typically for smaller capacity needs. These equipment types 

are not centrifugal chillers and hence are not covered under this section of the proposed rule.

(c) What other applications of centrifugal chillers are not covered 

by this section of the proposed rule?

EPA understands that chillers are often employed for comfort AC in commercial settings 

but can also be applied for other uses. Centrifugal chillers applied in the following SNAP enduses are not covered by this section of the proposed rule:

 Industrial process refrigeration

 Industrial process air conditioning

 Ice skating rinks

 Retail food refrigeration

 Cold storage warehouses

 Very low temperature refrigeration

(d) What refrigerants are used in centrifugal chillers?

Centrifugal chillers historically employed either CFC-11 (called “low pressure chillers”) 

or CFC-12 (“high pressure chillers”), although other CFCs have been used, including CFC-114 

and R-500 (a blend of CFC-12 and HFC-152a). When the production and consumption of CFCs 

were phased out in the United States in the 1990s, centrifugal chillers was one of the first enduses to be redesigned for alternative refrigerants and HCFC-123 and HFC-134a became the 

Commented [A8]: The AHRI/NRDC letter had suggested that 

all chillers regardless of application could be phased out by 2025. 

Even if centrifugal chillers in these applications cannot be phased 

out by 2022 (as proposed for comfort cooling), has EPA considered 

some other date that is no later than 2025 for these?

Will EPA also explain the justification for any dates earlier than 

2025 knowing that AHRI/NRDC agreed on 2025?
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primary refrigerants used in centrifugal chillers. HCFC-123 was used in low pressure chillers 

while HFC-134a was used in high pressure chillers. Both of these alternatives continue to be 

used today. HCFC-22 was also used in some centrifugal chillers, primarily only in equipment 

produced before approximately the year 2000. HFC-245fa was also identified as a possible 

refrigerant for low pressure centrifugal chillers, but has found only limited use.

More recently, centrifugal chillers that use alternatives listed as acceptable including 

trans-1-chloro-3,3,3-trifluoroprop-1-ene and HFO-1234ze(E) (JARN, 2015) have been 

demonstrated or announced. For instance, one manufacturer has introduced centrifugal chillers 

using trans-1-chloro-3,3,3-trifluoroprop-1-ene, a nonflammable low-GWP refrigerant (Cooling 

Post, 2014).

ii. Which refrigerants is EPA proposing to list as unacceptable?

For new centrifugal chillers, EPA is proposing to change the status of the following 

refrigerants from acceptable to unacceptable: FOR12A, FOR12B, HFC-134a, HFC-227ea, HFC236fa, HFC-245fa, R-125/134a/600a (28.1/70/1.9), R-125/290/134a/600a (55.0/1.0/42.5/1.5), R404A, R-407C, R-410A, R-410B, R-417A, R-421A, R-422B, R-422C, R-422D, R-423A, R424A, R-434A, R-438A, R-507A, RS-44 (2003 composition), and THR-03.

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for this end-use with respect to SNAP criteria? 

For new centrifugal chillers, acceptable refrigerants for which we are not proposing a 

change of status in this end-use include: HFO-1234ze(E), IKON A, IKON B, R–450A, R-513A, 

R-717 (ammonia), THR-02, and trans-1-chloro-3,3,3-trifluoroprop-1-ene. 

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 
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Page 111 of 289

potential impacts on smog formation from emissions of VOC; and ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks are 

discussed below. In addition, a technical support document that provides the Federal Register 

citations concerning data on the SNAP criteria (e.g., ODP, GWP, VOC, toxicity, flammability) 

for acceptable alternatives for new centrifugal chillers may be found in the docket for this 

rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015a).

a. Environmental impacts

The refrigerants for which we are proposing a change of status have an ODP of zero. 

Other alternatives also with an ODP of zero that we are not proposing a change of status for new 

centrifugal chillers include HFO-1234ze(E), IKON A, IKON B, R-450A, R-513A, R-717, and 

THR-0. Also, the alternative refrigerant trans-1-chloro-3,3,3-trifluoroprop-1-ene has an ODP of 

0.00024 to 0.00034 (Wang et al, 2011; Patten and Wuebbles, 2010). Estimates of this 

compound’s potential to deplete the ozone layer indicate that even with worst-case estimates of 

emissions, which assume that this compound would substitute for all compounds it could 

replace, the impact on global atmospheric ozone abundance would be statistically insignificant

(Wang et al, 2011). Thus, the acceptable alternatives not subject to the proposed status change 

have ODPs lower than or of the same practical effect to the ODPs of other alternatives for which 

EPA is proposing a change of status, and lower than the ODPs of ODS historically used in this

end-use. The refrigerants we are proposing to find unacceptable through this action have GWPs 

ranging from about 918 to 9,810. As shown in Table 6, other alternatives acceptable for this enduse have GWPs ranging from zero to 631.

Table 6: GWP, ODP, and VOC Status of Refrigerants in New Centrifugal Chillers1,2,3

Refrigerants GWP ODP VOC Proposal

Ammonia, HCFC-123, HCFC-124, HFO1234ze(E), R-450A, R-513A, trans-1-chloro3,3,3-trifluoroprop-1-ene0 – 630 0-0.022 No No change
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IKON A, IKON B, THR-02 30-560 0 Yes3 No change

HFC-134a, HFC-245fa 1,030 – 1,430 0 No Unacceptable

FOR12A, FOR12B, THR-03 920 – 1,220 0 Yes3 Unacceptable

R-407C, R-410A, R-410B, R-421A, R-423A, 

HFC-227ea 

1,770 –3,220 0 No Unacceptable

R-125/134a/600a (28.1/70/1.9), R125/290/134a/600a (55/1/42.5/1.5), R-417A, 

R-422B, R-422C, R-422D, R-424A, R-434A,

R-438A, RS-44 (2003 composition)

1,770 –3,250 0 Yes3 Unacceptable

HFC-236fa, R-404A, R-507A 3,920 – 9,810 0 No Unacceptable

1The table does not include not-in-kind technologies listed as acceptable for the stated end-use.

2HCFC-22 and several blends containing HCFCs are also listed as acceptable but their use is severely restricted by 

the phasedown in HCFC production and consumption.

3One or more constituents of the refrigerant are VOC.

One of the refrigerant blends not subject to the proposed status change (THR-02), as well 

as several of the substitutes subject to the proposed status change, include small amounts of R290 (propane), R-600 (butane) or other substances that are VOCs. These amounts are small and 

for this end-use are not expected to contribute significantly to ground level ozone formation 

(ICF, 2014e). In the actions where EPA listed these refrigerants as acceptable, EPA concluded 

none of these refrigerants in this end-use pose significantly greater risk to ground-level ozone 

formation than other alternative refrigerants that are not VOCs or that are specifically excluded 

from the definition of VOC under CAA regulations (see 40 CFR 51.100(s)) addressing the 

development of SIPs to attain and maintain the NAAQS. 

The refrigerants not subject to the proposed status change are highly volatile and 

typically evaporate or partition to air, rather than contaminating surface waters. Their effects on 

aquatic life are expected to be small and pose no greater risk of aquatic or ecosystem effects than 

those of other refrigerants that are subject to the proposed status change for this end-use.

b. Flammability

For the centrifugal chillers end-use, with the exceptions of HFO-1234ze(E) and R-717, 

all other refrigerants listed as acceptable, including those for which we are proposing to change 
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the status to unacceptable, are not flammable. HFO-1234ze(E) is non-flammable at standard 

temperature and pressure using the standard test method ASTM E681; however, at higher 

temperatures it is mildly flammable. It is classified as a Class 2L (lower flammability, low 

burning velocity) refrigerant under the standard ASHRAE 34 (2013). Our assessment and listing 

decision (77 FR 47768; August 10, 2012) found that the overall risk, including the risk due to 

this mild flammability at elevated temperature, is not significantly greater than for other 

refrigerants or for the refrigerants we are proposing to list as unacceptable.

R-717 is slightly flammable with a low flame speed; it is classified as a 2L refrigerant 

under ASHRAE 34 (2013). R-717 has a long history of use in cold storage warehouses and other 

applications, but it is not believed to be used extensively in centrifugal chillers. In the original 

SNAP rule, EPA noted “[a]mmonia has been used as a medium to low temperature refrigerant in 

vapor compression cycles for more than 100 years. Ammonia has excellent refrigerant 

properties, a characteristic pungent odor, no long-term atmospheric risks, and low cost. It is, 

however, slightly flammable and toxic, although it is not a cumulative poison. OSHA standards 

specify a 15 minute short-term exposure limit of 35 ppm for ammonia.” (53 FR 13072; March 

18, 1994). We further noted its use in various food and beverage processing and storage 

applications as well as other industrial applications. In that rule, we found R-717 acceptable for 

use in new centrifugal chillers, concluding that its overall risk to human health and the 

environment was not significantly greater than the other alternatives found acceptable. This 

conclusion was based on the assumption that the regulated community adheres to OSHA 

regulations on such use as well as standard refrigeration practices, such as the adherence to 

ASHRAE Standard 15, which is often utilized by local authorities when setting their own 

building and safety requirements.
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For further information, including EPA’s risk screens and risk assessments as well as 

information from the submitters of the substitutes, see docket EPA–HQ–OAR–2015-0663.

c. Toxicity

The toxicity of the refrigerants we are proposing to list as unacceptable is comparable to 

that of other alternatives that are acceptable in this end-use, with the exception of R-717. R-717, 

for which we are not proposing a change of status, is of a higher toxicity than some other 

refrigerants and is classified as a B refrigerant under ASHRAE 34 (2013). See section 

VI.A.4.a.iii.(b) for a discussion on the long history of use of R-717 and our original decision 

finding it acceptable in new centrifugal chillers. The other acceptable alternatives listed above 

that are included in ASHRAE 34 (2013) are classified as A (lower toxicity) refrigerants. 

For all refrigerants, the relatively large charge sizes employed in centrifugal chillers, and 

the fact that some such chillers are placed in an enclosed mechanical room, raise a concern 

regarding oxygen displacement. This concern has been addressed over the long history of the use 

of centrifugal chillers, including the use of HCFC-123, another B refrigerant as classified by 

ASHRAE 34 (2013), by providing adequate ventilation, reducing leaks to small levels, and other 

techniques such as employing refrigerant sensors and automatic air movement. Commonly 

followed standards and practices have reduced toxicity concerns equally for historically used 

ODS, the alternatives for which we are proposing a status change, and the alternatives for which 

we are not proposing a status change. 

d. Summary

EPA has listed as acceptable several alternatives that pose lower overall risk to human 

health and the environment than the refrigerants whose status we are proposing to change to 

unacceptable. The risks other than GWP are not significantly different for the alternatives than 
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for the refrigerants we are proposing to list as unacceptable, and the GWPs for the refrigerants 

we are proposing to list as unacceptable are significantly higher and thus pose significantly 

greater risk. 

iv. When would the status change?

EPA is proposing a change of status date for new centrifugal chillers of January 1, 2022,

which the Agency believes is the earliest date by which the technical challenges can be met for a 

safe and smooth transition to alternatives particularly considering the complexity of chiller 

designs and the need to ensure energy efficiency levels are met. This period is needed to develop 

designs of new centrifugal chillers using an acceptable alternative. We are aware that some 

equipment has been introduced with acceptable alternatives and that additional research and 

development is underway with these and other possible alternatives. 

v. What is the relationship between this SNAP rule and other federal

rules? 

DOE has established efficiency requirements, based on ANSI/ASHRAE/IES Standard 

90.1-2010, for chillers used in federal buildings.34 EPA is not aware of any DOE energy 

efficiency requirements for chillers used in non-federal buildings. Although EPA is not aware of 

any federal standards that apply, EPA recognizes, however, that state and local building codes 

may place certain requirements that affect the desired efficiency of chillers. Many state and local 

codes reference ASHRAE Standard 90.1. EPA’s understanding of ASHRAE Standard 90.1 is 

that it provides both a prescriptive and performance-based measures to achieve compliance. 

Under the prescriptive approach, depending on the version of the standard, one or two “paths” 

exist setting specific energy efficiency requirements based on the type and capacity of the chiller. 

 

34 U.S. DOE, 2014. Building Energy Codes Program. Energy Efficiency Standards for Federal Buildings. Available 

at: https://www.energycodes.gov/regulations/federal-building-standards. Last updated February 13, 2014.
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Under a performance-based approach, the energy consumption of the chiller may exceed the 

prescriptive requirements provided that the building as a whole meets or exceeds the applicable 

reference building. 

vi. On which topics is EPA specifically requesting comment?

EPA requests comment on all aspects of this proposal. In particular, we request comment 

on the specific steps that must be undertaken to commercialize centrifugal chillers with 

alternative refrigerants, including the time each such step would take, which steps must occur in 

sequence, and which steps could occur in parallel. EPA requests comments on if and how this 

timing might vary based on the characteristics of the chiller, such as but not limited to, 

compressor type, capacity range, evaporator design, condenser design (e.g., air cooled or water 

cooled), and refrigerant currently used and potentially used. 

EPA requests comment on the current use of four refrigerants not subject to the proposed 

change of status, trans-1-chloro-3,3,3-trifluoroprop-1-ene, HFO-1234ze(E), R-450A and R513A, in centrifugal chillers, including the status of product availability and the capacity range 

covered by such products. We also request comment on the on-going research, development, 

deployment and expected increased market penetration of centrifugal chillers using refrigerants 

such as trans-1-chloro-3,3,3-trifluoroprop-1-ene, HFO-1234ze(E), R-290, R-450A, R-513A, DR55,35 R-718 and R-744.

EPA requests comment on the distinctions between end-uses where centrifugal chillers 

are employed as well as the other uses for which various types of centrifugal chillers are applied, 

or where the term “chiller” is used, including an indication of which type(s) of chiller and the 

refrigerant(s) used for such uses. Because this action proposes a change in status for certain 

 

35 DR-55 is a temporary name identifying a specific HFC/HFO blend.
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refrigerants in all centrifugal chillers (except those employed in applications noted in section 

VI.A.4.a.i.(c) above), we request comment and technical information on any types of centrifugal 

chillers that cannot be redesigned in the timeline proposed to use other alternatives listed as 

acceptable.

Additionally, EPA requests comment on energy efficiency requirements for centrifugal 

chillers in the United States and on the ability of centrifugal chillers using refrigerants other than 

those for which we are proposing a status change to meet those requirements. In particular, we 

request comment on the specific steps and timing of such steps required to design and develop 

centrifugal chillers to meet applicable energy efficiency requirements.

b. Proposed change of status for certain HFC refrigerants for new

positive displacement chillers

As provided in the following table, EPA is proposing to change the status of numerous 

refrigerants from acceptable to unacceptable for new positive displacement chillers:

Table 7. Proposed Change of Status Decisions for New Positive Displacement Chillers

End-use Substitutes Proposed Decision

Positive Displacement Chillers (new 

only)

FOR12A, FOR12B, HFC-134a, HFC227ea, KDD6, R-125/134a/600a 

(28.1/70/1.9), R-125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, R-407C, 

R-410A, R-410B, R-417A, R-421A, R422B, R-422C, R-422D, R-424A, R434A, R-437A, R-438A, R-507A, RS44 (2003 composition), SP34E, and 

THR-03.

Unacceptable as of January 1, 

2022

i. What is the affected end-use? 

(a) Overview of equipment covered

As discussed in section VI.A.4.a.i, vapor compression cycle chillers are divided into 

centrifugal chillers and positive displacement chillers. This section deals with positive 

displacement chillers, which are those that utilize positive displacement compressors such as 
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reciprocating, screw, scroll or rotary types. Positive displacement chillers are applied in similar 

situations as centrifugal chillers, again primarily for commercial comfort AC, except that 

positive displacement chillers tend to be used for smaller capacity needs such as in mid- and lowrise buildings.

For commercial comfort, positive displacement chillers typically cool water that is then 

pumped to fan coil units or other air handlers to cool the air that is supplied to the occupied 

spaces rejecting the heat to the water. The heat absorbed by the water can then be used for 

heating purposes, and/or can be rejected directly to the air (“air-cooled”), to a cooling tower or 

body of water (“water-cooled”) or through evaporative coolers (“evaporative-cooled”). 

Positive displacement chillers are used for other applications besides commercial comfort 

AC and are covered under this section of the proposed rule except as noted below in section 

VI.A.4.b.i.(c). For instance, positive displacement chillers used to cool equipment, such as in 

data centers, are covered under this section of the proposed rule.

(b) What other types of equipment are used for similar 

applications but are not covered by this section of the proposed rule? 

Other equipment including packaged rooftop units and split system air conditioners, both of 

which fall under the SNAP end-use “household and light commercial air conditioning,” can also 

be used for commercial comfort AC, typically for even smaller capacity needs than positive 

displacement chillers. These equipment types are not positive displacement chillers and hence 

are not covered under this section of the proposed rule.

(c) What other applications of centrifugalpositive displacement

chillers are not covered by this section of the proposed rule?
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EPA understands that chillers are often employed for comfort AC in commercial settings 

but can also be applied for other uses. Positive displacement chillers applied in the following 

SNAP end-uses are not covered by this section of the proposed rule:

 Industrial process refrigeration

 Industrial process air conditioning

 Ice skating rinks

 Retail food refrigeration

 Cold storage warehouses

 Very low temperature refrigeration

(d) What refrigerants are used in positive displacement chillers?

Positive displacement chillers historically used CFC-12, although HCFC-22 was also 

used and became more common after the production and consumption of CFC-12 were phased 

out. In accordance with CAA 605(a) and the implementing regulations codified at 40 CFR part 

82, subpart A, in the United States, the use of newly manufactured HCFC-22 for new positive 

displacement chillers (and other new equipment) ceased as of January 1, 2010. Both R-407C and 

to a larger extent R-410A are used in new positive displacement chillers primarily in lower 

capacity ranges previously served by HCFC-22 chillers. HFC-134a is also used for new positivedisplacement chillers, including some mid-level capacity water-cooled screw chillers. More 

recently, positive displacement chillers that use alternatives listed as acceptable including HFO1234ze(E) and R-513A (a blend of HFC-134a and HFO-1234yf) have been demonstrated or 

announced. EPA is aware of air-cooled rotary chillers in the 115 to 500 refrigeration ton (404 to 

1,760 kW) range using R-513A (Trane, 2015). Other chiller models using low-GWP refrigerants 

have also been introduced; for instance an air-cooled chiller using DR-55 at the IIR International 

Commented [A9]: The AHRI/NRDC letter had suggested that 

all chillers regardless of application could be phased out by 2025. 

Even if centrifugal chillers in these applications cannot be phased 

out by 2022 (as proposed for comfort cooling), has EPA considered 

some other date that is no later than 2025 for these?

Will EPA also explain the justification for any dates earlier than 

2025 knowing that AHRI/NRDC agreed on 2025?
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Conference of Refrigeration (JARN 2015a).36 EPA also notes that a water-cooled screw chiller 

using HFO-1234ze37 has been installed in Europe (JARN, 2015b).38

ii. Which refrigerants is EPA proposing to list as unacceptable?

For new positive displacement chillers, EPA is proposing to change the status of the 

following refrigerants from acceptable to unacceptable: FOR12A, FOR12B, HFC-134a, HFC227ea, KDD6, R-125/134a/600a (28.1/70/1.9), R-125/290/134a/600a (55.0/1.0/42.5/1.5), R404A, R-407C, R-410A, R-410B, R-417A, R-421A, R-422B, R-422C, R-422D, R-424A, R434A, R-437A, R-438A, R-507A, RS-44 (2003 composition), SP34E, and THR-03.

iii. How do these proposed unacceptable refrigerants compare to 

other refrigerants for this end-use with respect to SNAP criteria? 

For new positive displacement chillers, acceptable refrigerants for which we are not 

proposing a change of status in this end-use include: HFO-1234ze(E), IKON B, R–450A, R513A, R–717, and THR–02.

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; and ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks are 

discussed below. In addition, a technical support document that provides the Federal Register 

citations concerning data on the SNAP criteria (e.g., ODP, GWP, VOC, toxicity, flammability) 

for acceptable alternatives for new positive displacement chillers may be found in the docket for 

this rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015x). 

 

36 Trane Exhibits First Air-cooled Chiller with Climate-friendly Refrigerant DR-55, September 21, 2015. Available 

at: www.ejarn.com/news.aspx?ID=36282.

37 EPA assumes the refrigerant used is the stereoisomer HFO-1234ze(E) but requests comment on this assumption.

38 First Carrier AquaForce Chillers using HFO-1234ze, August 2, 2015. www.ejarn.com/news.aspx?ID=35619.
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(a) Environmental impacts

The refrigerants for which we are proposing to change the status to unacceptable have 

zero ODP and GWPs ranging from about 918 to 3,990. As shown in Table 8, other alternatives 

for which we are not proposing a change of status in this end-use have GWPs ranging from zero 

to 631. 

Table 8: GWP, ODP, and VOC Status of Refrigerants in New Positive Displacement Chillers1,2,3

Refrigerants GWP ODP VOC Proposal

Ammonia, HFO-1234ze(E), R-450A, R-513A 0 – 630 0 No No change

IKON B, THR-02 30 – 560 0 Yes3 No change

HFC-134a 1,430 0 No Unacceptable

FOR12A, FOR12B, SP34E, THR-03 920 – 1,410 0 Yes3 Unacceptable

HFC-227ea, R-407C, R-410A, R-410B, R-421A 1,770 –

3,220

0 No Unacceptable 

KDD6, R-125/134a/600a (28.1/70/1.9), R125/290/134a/600a (55/1/42.5/1.5), R-417A, R-422B, 

R-422C, R-422D, R-424A, R-434A, R-437A, R438A, RS-44 (2003 composition)

1,810 –

3,250

0 Yes3 Unacceptable

R-404A, R-507A 3,920 –

3,990

0 No Unacceptable

1The table does not include not-in-kind technologies listed as acceptable for the stated end-uses.

2HCFC-22 and several blends containing HCFCs are also listed as acceptable but their use is severely restricted by 

the phasedown in HCFC production and consumption.

3One or more constituents of the refrigerant are VOC.

One of the refrigerant blends not subject to the proposed status change (THR-02), as well 

as several of the substitutes subject to the proposed status change, include small amounts of R290 (propane), R-600 (butane), or other substances that are VOCs. These amounts are small and 

for this end-use are not expected to contribute significantly to ground level ozone formation 

(ICF, 2014e). In the actions where EPA listed these refrigerants as acceptable, EPA concluded 

none of these refrigerants in this end-use pose significantly greater risk to ground-level ozone 

formation than other alternative refrigerants that are not VOCs or that are specifically excluded 

from the definition of VOC under CAA regulations (see 40 CFR 51.100(s)) addressing the 

development of SIPs to attain and maintain the NAAQS. 

The refrigerants not subject to the proposed status change are highly volatile and 
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typically evaporate or partition to air, rather than contaminating surface waters. Their effects on 

aquatic life are expected to be small and pose no greater risk of aquatic or ecosystem effects than 

those of other refrigerants that are subject to the proposed status change for this end-use.

(b) Flammability

For the positive displacement chillers end-use, with the exception of HFO-1234ze(E) and 

R-717, all other refrigerants listed as acceptable, including those for which we are proposing to 

change the status to unacceptable, are not flammable. HFO-1234ze(E) is non-flammable at 

standard temperature and pressure using the standard test method ASTM E681; however, at 

higher temperatures it is mildly flammable. It is classified as a Class 2L (lower flammability, low 

burning velocity) refrigerant under the standard ASHRAE 34 (2013). Our assessment and listing 

decision (77 FR 47768; August 10, 2012) found that the overall risk, including the risk due to 

this mild flammability at elevated temperature, is not significantly greater than for other 

refrigerants or for the refrigerants we are proposing to list as unacceptable. As noted above, a 

positive displacement chiller using this refrigerant has already been installed.

R-717 is slightly flammable with a low flame speed; it is classified as a 2L refrigerant 

under ASHRAE 34 (2013). R-717 has a long history of use as a refrigerant in positive 

displacement chillers, especially in water-cooled screw chillers, and other applications. In our 

evaluation finding R-717 acceptable in this end-use, EPA noted “Ammonia has been used as a 

medium to low temperature refrigerant in vapor compression cycles for more than 100 years. 

Ammonia has excellent refrigerant properties, a characteristic pungent odor, no long-term 

atmospheric risks, and low cost. It is, however, slightly flammable and toxic, although it is not a 

cumulative poison. Ammonia may be used safely if existing OSHA and ASHRAE standards are

followed” (61 FR 47015).
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(c) Toxicity

With the exception of R-717, the toxicity of the refrigerants we are proposing to list as 

unacceptable is comparable to that of other alternatives that are acceptable in this end-use. R717, for which we are not proposing a change of status, is of a higher toxicity than some other 

refrigerants and is classified as a B refrigerant under ASHRAE 34 (2013). See section 

VI.A.4.b.iii.(b) for a discussion on the long history of use of R-717 and our original decision 

finding it acceptable in new positive displacement chillers.

For all refrigerants, the possible relatively large charge sizes of some positive 

displacement chillers, and the fact that some such chillers are place in an enclosed mechanical 

room, raise a concern regarding oxygen displacement. This concern has been addressed over the 

long history of the use of positive displacement chillers by providing adequate ventilation, 

reducing leaks to small levels, and other techniques such as employing refrigerant sensors and 

automatic air movement. Commonly followed standards and practices have reduced toxicity 

concerns equally for historically used ODS, the alternatives subject to the proposed status 

change, and the alternatives not subject to the proposed status change.

(d) Summary

EPA has listed as acceptable several alternatives that pose lower overall risk to human 

health and the environment than the refrigerants whose status we are proposing to change to 

unacceptable. The risks other than GWP are not significantly different for the alternatives than 

for the refrigerants we are proposing to list as unacceptable, and the GWPs for the refrigerants 

we are proposing to list as unacceptable are significantly higher and thus pose significantly 

greater risk. 
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iv. When would the status change?

EPA is proposing a change of status date for new positive displacement chillers of 

January 1, 2022, which the Agency believes is the earliest date by which the technical challenges 

can be met for a safe and smooth transition to alternatives particularly considering the 

complexity of chiller designs and the desire to maintain or improve energy efficiency when 

undergoing such a transition. EPA recognizes that this period may be needed to develop designs 

of new positive displacement chillers using an alternative that remains acceptable, or other 

alternatives that may be listed between now and the proposed change of status date, while at the 

same time meeting or exceeding today’s energy efficiency levels. However, we are aware that 

such development has already occurred resulting in positive displacement chillers using the 

lower-GWP alternatives already being commercialized, as discussed above. We also find that 

additional research is underway with these alternatives and some, such as R-450A and R-513A, 

were specifically designed to operate similarly with similar characteristics to a refrigerant used in 

positive displacement chillers today (i.e., HFC-134a) , which may ease the transition for those 

choosing to use such alternatives. Further, we note that when CFCs were being phased out in the 

United States in the early 1990s, positive displacement chillers were among the first end-uses to 

be redesigned for alternative refrigerants and HFC-134a and HCFC-22 became the primary 

refrigerants used in positive displacement chillers. 

v. What is the relationship between this SNAP rule and other federal

rules? 

DOE has established efficiency requirements, based on ANSI/ASHRAE/IES Standard 

90.1-2010, for chillers used in federal buildings.39 See section VI.A.4.a.v for more information. 

 

39 U.S. DOE, 2014. Building Energy Codes Program. Energy Efficiency Standards for Federal Buildings. Available 

at: https://www.energycodes.gov/regulations/federal-building-standards. Last updated February 13, 2014.
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vi. On which topics is EPA specifically requesting comment?

EPA requests comment on all aspects of this proposal. In particular, we request comment 

on the specific steps that must be undertaken to commercialize positive displacement chillers 

with alternative refrigerants, including the time each such step would take, which steps must 

occur in sequence, and which steps could occur in parallel. EPA requests comments on if and 

how this timing might vary based on the characteristics of the chiller. Such characteristics could 

include, but are not limited to, compressor type, capacity range, evaporator design, condenser 

design (e.g., air-cooled or water-cooled), and refrigerant currently used and potentially used.

EPA requests comment on the current use of three refrigerants, HFO-1234ze(E), R-450A 

and R-513A, in positive displacement chillers, including the status of product availability and the 

capacity range covered by such products. We also request comment on the on-going research, 

development, deployment and expected increased market penetration of positive displacement 

chillers using refrigerants such as HFO-1234ze(E), R-290, R-450A, R-513A, DR-55, R-718 and 

R-744.

EPA requests comment on the distinctions between end-uses where chillers are employed 

as well as the other uses for which various types of chillers are applied, or where the term 

“chiller” is used, including an indication of which type(s) of chiller and the refrigerant(s) used 

for such uses. Because this action proposes a change in status for certain refrigerants in all 

chillers (except those employed in applications noted in section VI.A.4.b.i.(c) above), we request 

comment and technical information on any types of chillers that cannot be redesigned in the 

timeline proposed to use the remaining alternatives.

Additionally, EPA requests comment on efficiency requirements for positive 

displacement chillers in the United States and on the ability of positive displacement chillers 
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using refrigerants other than those for which we are proposing a status change to meet those 

requirements. In particular, we request comment on the specific steps and timing of such steps 

required to design and develop positive displacement chillers to meet those energy efficiency 

requirements that are identified.

c. Proposed change of status for certain HFC refrigerants for new cold 

storage warehouses 

As provided in the following tale, EPA is proposing to change the status of 

numerous refrigerants from acceptable to unacceptable for new cold storage warehouses. 

Table 9. Proposed Change of Status Decisions for Cold Storage Warehouses 

End-use Substitutes Proposed Decision

Cold Storage 

Warehouses (new)

HFC-227ea, R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, 

R-407A, R-407B, R-410A, R-410B, R-417A, R-421A, R-421B, 

R-422A, R-422B, R-422C, R-422D, R-423A, R-424A, R-428A, 

R-434A, R-438A, R-507A, and RS-44 (2003 composition).

Unacceptable as of January 1, 

2023

i. What is the affected end-use? 

Cold storage warehouses are temperature-controlled facilities used to store meat, 

produce, dairy and other products that are delivered to other locations for sale to the ultimate 

consumer. This end-use within the SNAP program describes an application of refrigeration 

equipment for an intended purpose, and hence the listings of acceptable and unacceptable 

refrigerants for this end-use apply regardless of the type of refrigeration system used. In addition 

to traditional vapor-compression cycle systems, EPA has found several not-in-kind systems 

acceptable for this end-use, including ammonia absorption, evaporative cooling, desiccant 

cooling, and Stirling cycle systems, which are not subject to the proposed status change.

Cold storage warehouses are usually deemed “private” or “public,” describing the 

relationship between the owner or operator of the cold storage warehouse and the owner of the 

products stored within. Private cold storage warehouses are ones owned by a company for the 
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purpose of storing its products; for instance, a food producer, processor or shipper may own and 

operate a facility as a distribution point for its products. Likewise, a supermarket chain may own 

and operate a facility to control the distribution of a variety of products to multiple stores in a 

given region. A public cold storage warehouse provides storage for lease and hence may receive 

and hold products from multiple producers and for multiple supermarkets or other vendors. Some 

cold storage warehouses may be both public and private, with one part dedicated to the owner’s 

products and another part available for lease. All such types of cold storage warehouses are 

included within the SNAP end-use.

Cold storage warehouses are also often divided into two general uses: those storing 

products at temperatures above 32°F (0°C) and those storing products below this temperature. 

The former is referred to as a “cooler” while the term “freezer” is used for the latter. The 2014

ASHRAE Handbook of Refrigeration provides an additional cooler application called 

“controlled atmosphere for long-term fruit and vegetable storage” and three subdivisions of 

freezers: “high-temperature freezers” storing goods at 27 to 28°F (-2.8 to -2.2°C), “lowtemperature storage rooms for general frozen products, usually maintained at -5 to -20°F” (-21 to 

-29°C), and low-temperature storage at the same temperature range as before but “with a surplus 

of refrigeration for freezing products received at above 0°F” (-18°C). 

Several other end-uses under the SNAP program cover other parts of the food (and 

product) cold chain, and are distinct from the cold storage warehouse end-use. These are 

discussed here as examples of what EPA considers to be part of or separate from the “cold 

storage warehouse” end-use for which we are proposing changes of status.

Many food products require refrigeration during the production process. The application 

of refrigerating equipment used during the production of food and beverages falls within the 
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SNAP end-use “industrial process refrigeration.” The industrial process refrigeration end-use 

would include all equipment and operations (that use a refrigerant) used to make and prepare 

food that is not immediately available for sale to the ultimate consumer and would require 

shipping it, possibly through intermediate points, to the point where such sale would occur. The 

industrial process refrigeration end-use could be applied at facilities where food is processed and 

packaged by the food producer. An example could be a meat processor that prepares and 

packages individual cuts of meat within a single facility or building while maintaining the 

required temperatures within that facility or building. Although such facilities may be designed 

in a fashion similar to a cold storage warehouse, the fact that items are being processed by the 

food producer indicates that the application falls in the industrial process refrigeration end-use. 

However, if a food producer operates a refrigerated storage area solely for the holding of already 

packaged products, and possibly packing such products in larger containers or bundles for 

shipment, that application would fall under the cold-storage warehouse end-use. In the example 

above, such a cold storage warehouse might be a facility, separate from the industrial process 

refrigeration system in a different facility, where the individually-packaged cuts of meat are 

packed in a larger container that is placed on a pallet and then shipped.

Another example of an industrial process refrigeration system is a “blast cooler” or “blast 

freezer.” As described previously in a separate SNAP rulemaking “[a] ‘blast chiller’ or ‘blast 

freezer’ is a type of equipment in which cold air is supplied and circulated rapidly to a food 

product, generally to quickly cool or freeze a product before damage or spoilage can occur.” (80 

FR 42901; July 20, 2015). Such devices might be used as part of a food production line in an 

industrial setting. They also can be placed separately at public facilities including hospitals, 

schools, restaurants and supermarkets. These public facilities might use the blast chiller on 
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products that they will store for later use after they receive products from a vendor or that they 

cook or prepare as part of their operations. Such units might also be placed near entranceways to 

cold storage warehouses, for instance to receive food shipped refrigerated at one temperature and 

bring it down to a lower temperature for storage. EPA does not consider a separate blast chiller 

or blast freezer (i.e., one with its own refrigerant-containing circuit, including the compressor, 

evaporator and the condenser or heat exchanger) to be part of a cold storage warehouse. Another 

design, however, could consist of a refrigeration system that is used to provide refrigerant (or a 

secondary fluid in an indirect system) to the evaporators extracting heat from the cold storage 

warehouse as well as to the evaporators used by a blast chiller or blast freezer that is installed at 

the facility. In this situation, EPA expects that the majority of the load and intended use of the 

combination system is for the cold storage of products, including those that undergo the blast 

cooling or freezing, and hence we consider the system to be a cold storage warehouse. For such 

systems, certain refrigerants would be subject to the proposed change of status as explained 

below.

As discussed in section VI.A.4.d, because products from refrigerated food processing and 

dispensing equipment are generally available for sale to the ultimate consumer, that end-use 

category, part of the retail food refrigeration end-use, is distinct from industrial process 

refrigeration. 

Another application in the food cold chain is the use of a “cold room” at a retail facility 

where refrigerated food is kept generally for short periods of time. In the July 20, 2015, final rule 

(80 FR 42870), EPA changed the status of certain refrigerants used in “remote condensing units” 

and “stand-alone systems,” two categories within the “retail food refrigeration” end-use that 

include equipment that can be used for such cold rooms. Remote condensing units may include a 
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dedicated one- or two-compressor system with condensers located on a roof or the side of a 

building providing cooling through unit coolers to an insulated room, for instance in a restaurant 

or supermarket, that are built and charged with refrigerant at the site. Also, some cold rooms are 

stand-alone systems that are pre-charged at the factory and ready to use once placed at the 

retailer’s facility and provided with electrical and possibly plumbing connections, and are 

accessed via a door to store refrigerated products. In general, both types of applications are often 

called “walk-in coolers” or “walk-in freezers,” depending on the design temperature.

Such cold rooms are used to store products at required temperatures until sale to the 

ultimate consumer, such as a shopper in a supermarket or a diner in a restaurant. In some cases, 

one side of the room is fitted with glass doors and racks where the owner stacks products on the 

racks and the consumer obtains the product from the rack. In other cases, the cold room is only 

accessible by employees of the retail food establishment. For these applications, even if this 

equipment is not accessible to the public—for instance, it is in the back of a supermarket and 

holds products that are later brought to display cases from which customers obtain the products; 

or in the back of a restaurant where a cook takes and prepares the food that is brought to the 

diner by a waiter—it is considered part of the retail establishment and hence is part of the “retail 

food refrigeration” end-use and is not included in the “cold storage warehouse” end-use. The 

changes of status proposed in this action would not apply to such “cold rooms,” “walk-in 

coolers,” or “walk-in freezers;” however, EPA refers the reader to a previous rulemaking that 

does apply (80 FR 42870; July 20, 2015).

R-717 is believed to be the most common refrigerant used in cold storage warehouses. 

While R-717 is not used extensively in many other types of refrigeration and air-conditioning 

equipment, certain characteristics of cold storage warehouses have facilitated the widespread use 
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of that refrigerant in this end-use. For example, because cold storage warehouses are often large 

in size for economies of scale reason and require a large amount of land use—as opposed to 

other systems that might be located on a building roof or a small slab next to the building—they 

are typically located away from population centers where land costs and taxes may be higher. 

Also, because they often service multiple retail locations and may receive goods from multiple 

producers, cold storage warehouses are often sited where major transportation services (i.e., 

highways and rail lines) are available and are less prone to high traffic delays and similar 

disruptions that are more common in population centers. In addition, the transportation of goods 

is typically done in large volumes—by truck or train—to reduce costs, which in turn reduces the 

workforce needed and the number of people at the warehouse and in particular near the 

refrigeration equipment. These factors allow for more consideration of the use of refrigerants that 

do pose toxicity and flammability risks, such as R-717, than in other applications where more 

people might be at risk, such as an office building.

Limitations on the use of R-717 do exist. For example, it is reported that charge sizes 

exceeding 10,000 pounds of R-717 “may require government-mandated process safety 

management (PSM) and [a] risk management plan (RMP).” (ASHRAE, 2014). Various state and 

local building codes could also apply and adherence to such codes might hinder or even 

eliminate the use of R-717 in some cold storage warehouses. Likewise, regulations may require 

employing operators with special levels of expertise, reporting of use or accidental releases, and 

other actions not typically required for other alternatives, increasing the operating cost compared 

to facilities using other refrigerants. These increased costs however are often offset given the 

high energy efficiencies typically achieved with ammonia systems.

Some of the limitations on the use of R-717 in cold storage warehouses may be overcome 
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with system designs that have been introduced or have been more fully explored recently. These 

include low charge packaged R-717 system, R-717/R-744 cascade systems, and indirect 

secondary-loop systems using R-717 as the primary refrigerant in a machine room separated 

from the cooled interior. These systems are described in market characterizations found in the 

docket to this proposed rule (EPA-HQ-OAR-2015-0663) (ICF, 2015X).

Where R-717 was not used, cold storage warehouses traditionally used CFC-12, R-502 

and HCFC-22. With the 1996 CFC phaseout, and the restriction on the use of newly 

manufactured HCFC-22 in new equipment that took effect January 1, 2010, R-404A or R-507A 

are generally used when R-717 is not chosen. Two nonflammable HFC/HFO blends, R-448A 

and R-449A, are designed to perform similarly to R-404A and R-507A and are under 

investigation for this use. EPA also notes that a major retailer recently announced progress on 

implementing HFC-free food distribution centers.40

ii. Which refrigerants is EPA proposing to list as unacceptable? 

For new cold storage warehouses, EPA is proposing to change the status of the following 

refrigerants from acceptable to unacceptable: HFC-227ea, R-125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, R-407A, R-407B, R-410A, R-410B, R-417A, R-421A, R-421B, R422A, R-422B, R-422C, R-422D, R-423A, R-424A, R-428A, R-434A, R-438A, R-507A, and 

RS-44 (2003 composition).

EPA understands that existing cold storage warehouses may undergo expansion to handle 

needs such as increased production, consolidation of distribution points, or increased population 

or other reasons for increased demands of the products stored. Such expansions could include a 

 

40 The White House, 2015. FACT SHEET: Obama Administration and Private-Sector Leaders Announce Ambitious 

Commitments and Robust Progress to Address Potent Greenhouse Gases, October 15, 2015. Accessible at 

https://www.whitehouse.gov/the-press-office/2015/10/15/fact-sheet-obama-administration-and-private-sectorleaders-announce.
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physical expansion of the storage space or using racking techniques to increase the amount of 

product within a given facility. The owner of cold storage warehouses undergoing such 

expansions (or the owner’s designer) may determine that a new system needs to be added. That 

new system could be a complete newly manufactured system separate from the existing system, 

or it could be equipment and refrigerant added to the existing system increasing the capacity of 

the existing system. In both cases, EPA considers these actions as the manufacturing of a new

system and hence that equipment could be affected by the proposed changes of status, as 

explained further below. 

EPA addressed the difference between a “new” and “retrofit” system as used in the 

SNAP program in a previous rule (80 FR 42902-42903; July 20, 2015). As used in the SNAP 

program, “new” refers to the manufacture and often installation of a refrigeration system, which 

may occur on a newly manufactured or an existing cold storage warehouse. This proposed action 

would apply to expansion of the refrigeration system in an existing cold storage warehouse as 

being designated a “new” system if the capacity of that existing refrigeration system is increased 

to handle the expansion. On the other hand, if an existing refrigeration system is extended (for 

instance, by adding additional refrigerant lines and evaporators to a newly manufactured or 

newly commissioned building, to a portion of the existing facility previously not used for cold 

storage, or to an extension of the previous building), without requiring an increase in capacity, 

the system is not considered “new” and hence may continue its operations with the existing 

refrigerant. Likewise, a facility may increase the amount of products it handles while at the same 

time providing better sealing around infiltration points and/or increasing the insulation on walls 

and roofs, and thereby avoid the need to increase the refrigeration capacity of the equipment 

serving the cold storage warehouse. EPA requests comment on the definition of “new” and how 
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it applies to cold storage warehouses. In particular, EPA request comments on the likelihood and 

frequency that existing cold storage warehouses are expanded and whether it is typical to utilize 

or expand the existing refrigeration system to address the increased load from the facility 

expansion or whether it is typical to install a new system specifically to handle that expansion.

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for this end-use with respect to SNAP criteria? 

For new cold storage warehouses, acceptable refrigerants for which we are not proposing 

a change of status in this end-use include: FOR12A, FOR12B, HFC-134a, IKON A, IKON B, 

KDD6, R-407C, R-407F, R-437A, R-450A, R-513A, R-717, R-744, RS-24 (2002 composition), 

SP34E, THR-02, and THR-03.

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; and ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks are 

discussed below. In addition, a technical support document that provides the Federal Register 

citations concerning data on the SNAP criteria (e.g., ODP, GWP, VOC, toxicity, flammability) 

for acceptable alternatives for new cold storage warehouses may be found in the docket for this 

rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015x). 

(a) Environmental impacts

The refrigerants we are proposing to find unacceptable through this action have zero 

ODPs, but they have GWPs ranging from 2,088 to 3,990. As shown in Table 10, acceptable 

alternatives have GWPs ranging from zero to 1,830. 

Table 10: GWP, ODP, and VOC Status of Refrigerants in New Cold Storage Warehouses1,2,3

Refrigerants GWP ODP VOC Proposal
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Ammonia, CO2, R-450A, R-513A 0 – 630 0 No No change

IKON A, IKON B, THR-02 30 – 560 0 Yes3 No change

HFC-134a, R-407C, R-407F 1,430 – 1,820 0 No No change

FOR12A, FOR12B, KDD6, R-437A, RS24 (2002 composition), SP34E, THR-03920 – 1,810 0 Yes3 No change

R-407A, R-407B, R-410A, R-410B, R421A, R-423A2,090 – 2,800 0 No Unacceptable

R-125/290/134a/600a (55/1/42.5/1.5), R417A, R-422B, R-422D, R-424A, R-438A,

RS-44 (2003 composition)

2,260 – 2,730 0 Yes3 Unacceptable

HFC-227ea, R-421B, R-404A, R-507A 3,190 – 3,990 0 No Unacceptable

R-422A, R-422C, R-428A, R-434A 3,080 – 3,610 0 Yes3 Unacceptable

1The table does not include not-in-kind technologies listed as acceptable for the stated end-uses.

2HCFC-22 and several blends containing HCFCs are also listed as acceptable but their use is severely restricted by 

the phasedown in HCFC production and consumption.

3One or more constituents of the refrigerant are VOC.

Some of the refrigerant blends not subject to the proposed status change, as well as 

several of the substitutes subject to the proposed status change, include small amounts of R-290, 

R-600, or other substances that are VOCs. These amounts are small and for this end-use, are not 

expected to contribute significantly to ground level ozone formation (ICF, 2014e). In the actions 

where EPA listed these refrigerants as acceptable or acceptable subject to use conditions, EPA 

concluded none of these refrigerants in this end-use pose significantly greater risk to groundlevel ozone formation than other alternative refrigerants that are excluded from the definition of 

VOC or that are specifically excluded from the definition of VOC under CAA regulations (see 

40 CFR 51.100(s)) addressing the development of SIPs to attain and maintain the NAAQS. 

The refrigerants not subject to the proposed status change are highly volatile and 

typically evaporate or partition to air, rather than contaminating surface waters. Their effects on 

aquatic life are expected to be small and pose no greater risk of aquatic or ecosystem effects than 

those of other refrigerants that are subject to the proposed status change for this end-use.

(b) Flammability

For the cold storage warehouse end-use, with the exception of R-717, the acceptable 
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refrigerants not subject to proposed changes of status , as well as those that are subject to 

proposed changes of status, are not flammable. R-717 is slightly flammable with a low flame 

speed; it is classified as a 2L refrigerant under ASHRAE 34 (2013). R-717 has a long history of 

use as a refrigerant in cold storage warehouses and other applications. In the original SNAP rule, 

EPA noted “[a]mmonia has been used as a medium to low temperature refrigerant in vapor 

compression cycles for more than 100 years. Ammonia has excellent refrigerant properties, a 

characteristic pungent odor, no long-term atmospheric risks, and low cost. It is, however, slightly

flammable and toxic, although it is not a cumulative poison. OSHA standards specify a 15 

minute short-term exposure limit of 35 ppm for ammonia.” (53 FR 13072; March 18, 1994). We 

further noted its use in various food and beverage processing and storage applications as well as 

other industrial applications. In that rule, we found R-717 acceptable for use in new cold storage 

warehouses, concluding that its overall risk to human health and the environment was not 

significantly greater than the other alternatives found acceptable. This conclusion was based on 

the assumption that the regulated community adheres to OSHA regulations on such use as well 

as standard refrigeration practices, such as the adherence to ASHRAE Standard 15, which is 

often utilized by local authorities when setting their own building and safety requirements.

(c) Toxicity

For the cold storage warehouse end-use, with the exception of R-717, the acceptable 

refrigerants not subject to the proposed status change, as well as those that are subject to the 

proposed status change, are of low toxicity (e.g., those listed under ASHRAE Standard 34-2013 

are class A toxicity). R-717, for which we are not proposing a change of status, is of a higher 

toxicity than some other refrigerants and is classified as a B refrigerant under ASHRAE 34 

(2013). See section VI.A.4.c.iii.(b) for a discussion on the long history of use of R-717 and our 
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original decision finding it acceptable in new cold storage warehouses.

(d) Summary

EPA has listed as acceptable several alternatives that pose lower overall risk to human 

health and the environment than the refrigerants whose status we are proposing to change to 

unacceptable. The risks other than GWP are not significantly different for the alternatives than 

for the refrigerants we are proposing to list as unacceptable, and the GWPs for the refrigerants 

we are proposing to list as unacceptable are significantly higher and thus pose significantly 

greater risk. 

iv. When would the status change?

EPA is proposing a change of status date for new cold storage warehouses of January 1, 

2023, which the Agency believes is the earliest date by which the technical challenges can be 

met for a safe and smooth transition to alternatives, particularly considering the various 

equipment types that could be employed to provide the cooling necessary for new cold storage 

warehouses and the requirement for many of these equipment types to meet energy conservation 

standards while undergoing such a transition. Given the widespread use of other acceptable 

alternatives, particularly R-717, EPA expects that only a limited number of new cold storage 

warehouses, including expansions at existing facilities, would otherwise have been designed to 

use one of the alternatives for which we are proposing a change of status. Nonetheless, because 

of the restrictions that may apply on the use of ammonia at the local level, and the variety of 

equipment that could be applied at a cold storage warehouse, EPA expects that this period of 

time is necessary until acceptable alternatives will become available for cold storage warehouses. 

HFC blends, primarily R-404A and R-507A, like CFCs and HCFCs in the past, may have been 

used where R-717 was deemed by the owner as impractical, costly, onerous and/or too risky to 
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use, given the restrictions that might exist in certain locations or for certain applications. For 

such locations and applications, the cold storage warehouse industry may need the time proposed 

to develop equipment with other alternative refrigerants or address the issues that exist with R717 and the other alternatives that are not subject to the proposed change in status. As explained 

below, certain types of equipment potentially applied in cold storage warehouses are subject to 

energy conservation standards, and hence time will be required to design, test and certify 

equipment for those standards, while at the same time using acceptable alternatives.

v. What is the relationship between this SNAP rule and other federal 

rules? 

EPA is not aware of other federal rules applying to efficiency of cold storage warehouses 

(i.e., the buildings), but we find that some federal rules apply to equipment that could be used in 

this specified end-use. Specifically, EPA notes that air-cooled commercial unitary air 

conditioners and heat pumps ("CUACs" and "CUHPs") might be applied at cold storage 

warehouses, and such equipment is subject to DOE energy conservation standards. 

DOE recently issued a pre-publication version of a direct final rule affecting CUACs and 

CUHPs (see docket numbers EERE–2013–BT–STD–0007 and EERE–2013–BT–STD–0021). 

These standards require that minimum energy efficiency levels be met by January 1, 2018 and 

that a second phase of minimum energy efficiency levels be met by January 1, 2023. The 2023 

date was chosen as a time when alternative refrigerants could be adopted during design 

modifications for the second phase of minimum energy efficiency levels. In adopting a 2023 

date, DOE stated “In recognition of the issues related to alternative refrigerants, members of the 

Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC) Working Group 

agreed as part of the Term Sheet to delay implementation of the second phase of increased 
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energy conservation standard levels until January 1, 2023, in part to align dates with potential 

refrigerant phase-outs and to provide sufficient development lead time after safety requirements 

for acceptable alternatives have been established.” 

(http://energy.gov/sites/prod/files/2015/12/f27/CUACCUHP%20CWAF%20Direct%20Final%20Rule.pdf). Further, DOE indicated that “Delaying the 

implementation of the second phase of standards in the manner recommended and agreed to by 

the Working Group will provide manufacturers with flexibility and additional time to comply 

with both energy conservation standards and potential refrigerant changes, allowing 

manufacturers to better coordinate equipment redesign to reduce the cumulative burden.

vi. On which topics is EPA specifically requesting comment?

EPA requests comment on all aspects of this proposal. In particular, we request comment 

on the types and subdivisions of cold storage warehouses explained here and whether other 

subdivisions of the end-use should be considered for this action. In particular, EPA requests 

comments on whether different alternatives are used or are otherwise available for different types 

of cold storage warehouses, why such differences exist, and whether the proposed change of 

status decisions, including the date such changes occur, might be affected considering such 

differences.

EPA requests comment on the specific steps that must be undertaken to commercialize 

cold storage warehouse refrigeration equipment with alternative refrigerants, including the time 

each such step would take, which steps must occur in sequence, and which steps could occur in 

parallel. EPA requests comments on if and how this timing might vary based on the 

characteristics of the cold storage warehouse and application of the equipment. Such 

characteristics could include but are not limited to the equipment and system design (i.e., direct 
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or indirect, central or unitary/packaged equipment), the required temperatures, jurisdictional 

limitations (e.g., at State or local levels), and considerations of risk and safety (e.g., to workers, 

those transporting goods to/from the facility, and the local public depending on the location). 

EPA requests comment on the distinctions made here between cold storage warehouses 

and other SNAP end-uses. In particular, EPA requests comments on whether such distinctions 

are clear and if not, comments on how to make such distinctions clear so that they are understood 

by the regulated community.

EPA also requests comment on the current and expected use of refrigerants in cold 

storage warehouses. In particular, we request comment on the continued use of ODS and on the 

use of the HFCs for which we propose a change of status. We request comment on the factors 

that led to the decision to use those refrigerants as opposed to other refrigerants for which we are 

not proposing a change of status, including especially R-717, which as explained above has been 

used widely in this end-use. We request comment on the use of other alternatives, including the 

ones for which we are not proposing a change of status and others that may be in development, 

and the expected availability and penetration into the cold storage warehouse market for such 

alternatives. Two nonflammable HFC/HFO blends, R-448A and R-449A, are designed to 

perform similarly to R-404A and R-507A and are under investigation for this use. EPA requests 

comment on the status of such investigations and results seen to date.

d. Proposed change of status for certain HFC refrigerants for new retail 

food refrigeration (refrigerated food processing and dispensing equipment)

As provided in the following table, EPA is proposing to change the status of numerous 

refrigerants from acceptable to unacceptable for new retail food refrigeration (refrigerated food 

processing and dispensing equipment):
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Table 11. Proposed Change of Status Decisions for Retail Food Refrigeration (Refrigerated Food 

Processing and Dispensing Equipment)

End-use Substitutes Proposed Decision

Retail food refrigeration 

(refrigerated food processing and 

dispensing equipment) (new only)

HFC-227ea, KDD6, R-125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, R-407A, R407B, R-407C, R-407F, R-410A, R-410B, 

R-417A, R-421A, R-421B, R-422A, R422B, R-422C, R-422D, R-424A, R-428A, 

R-434A, R-437A, R-438A, R-507A, RS-44 

(2003 formulation).

Unacceptable as of 

January 1, 2021

i. What is the affected end-use? 

In the SNAP July 20, 2015, final rule (80 FR 42870), EPA clarified in the response to 

comments that “equipment designed to make or process cold food and beverages that are 

dispensed via a nozzle, including soft-serve ice cream machines, ‘slushy’ iced beverage 

dispensers, and soft-drink dispensers” was not included as part of the retail food refrigeration 

end-use categories specifically identified in that final rule. In the July 20, 2015, final rule, EPA 

clarified that this equipment is part of a separate end-use category within the retail food 

refrigeration end-use - “refrigerated food processing and dispensing equipment.” A variety of 

food and beverage products are delivered and often processed by equipment within this end-use 

category, including but not limited to: chilled and frozen beverages (carbonated and 

uncarbonated, alcoholic and nonalcoholic); frozen custards, gelato, ice cream, Italian ice, sorbets 

and yogurts; milkshakes, “slushies” and smoothies, and whipped cream. For instance, some such 

equipment will process the product by combining ingredients, mixing and preparing it at the 

proper temperature, while others function mainly as a holding tank to deliver the product at the 

desired temperature or to deliver chilled ingredients for the processing, mixing and preparation. 

Some may use a refrigerant in a heat pump, or utilize waste heat from the cooling system, to 

provide hot beverages. Some may also provide heating functions to melt or dislodge ice or for 

sanitation purposes. 
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We noted in the July 20, 2015, final rule that refrigerated food processing and dispensing 

equipment “can be self-contained or can be connected via piping to a dedicated condensing unit 

located elsewhere” (80 FR 42902) and clarify here that both types fall within this end-use 

category. The equipment can be air-cooled although in some cases where multiple units are 

together and/or other space constraints exist (and hence air movement to the condenser would be 

compromised), a separate water line could be used to remove heat.

This end-use category does not include certain types of refrigeration equipment. For 

example, units designed solely to cool and dispense water, including those that feature 

detachable containers of water as well as those that are supplied directly from a shared water 

supply, fall under the separate “Water Coolers” end-use within the SNAP program. In addition, 

this end-use category does not include the preparation of chilled products in factory situations; 

such equipment falls under the SNAP end-use “Industrial Process Refrigeration” and are 

characterized as being those that do not provide products to the ultimate consumer for immediate 

or near-immediate consumption. Also included in the industrial process refrigeration end-use are 

blast chillers and freezers, including those that may be used at consumer settings such as schools, 

hotels, supermarkets, hospitals, restaurants, etc. Further, this end-use category does not include 

the equipment used to transport food products between distinct points of production and storage, 

such as refrigerated trucks that may transport products from a factory to a cold storage 

warehouse or from that warehouse to a supermarket or restaurant. That type of equipment falls 

under the SNAP end-use “Refrigerated Transport.” 

As part of the retail food refrigeration end-use, any alternative that has been listed 

broadly acceptable for the retail food refrigeration end-use, as opposed to being listed for only an 

individual end-use category within the retail food end-use, is likewise acceptable for this end-use 
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category. For example, because R-744 was found acceptable for the retail food refrigeration enduse (74 FR 50129; September 30, 2009), it is acceptable for the refrigerated food processing and 

delivery equipment category within the retail food refrigeration end-use. Those alternatives that 

have been found broadly unacceptable for this end-use, or those that have been found acceptable 

only for other specific end-use categories in this end-use, would not be acceptable alternatives 

under current regulations. For example, propane has been listed specifically for certain end-use 

categories such as standalone reach in coolers indicating it is not necessarily acceptable for all 

other end-use categories within the retail food end-use. Hence, the following alternatives are 

currently acceptable for new refrigerated food process and dispensing equipment: FOR12A, 

FOR12B, HFC-134a, HFC-227ea, IKON A, IKON B, KDD6, R-125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, R-407A, R-407B, R-407C, R-407F, R-410A, R-410B, R-417A, R421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-428A, R-434A, R437A, R-438A, R-450A, R-507A, R-744, RS-24 (2002 formulation), RS-44 (2003 formulation), 

SP34E, THR-02, and THR-03. On the other hand, because in our December 2011 and April 2015 

final rules we found R-290, R-600a and R-441A acceptable only for stand-alone units, those 

alternatives are not currently acceptable for equipment in this end-use category. 

ii. Which refrigerants is EPA proposing to list as unacceptable? 

For new refrigerated food processing and dispensing equipment, EPA is proposing to 

change the status of the following refrigerants from acceptable to unacceptable: HFC-227ea, 

KDD6, R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407A, R-407B, R-407C, R-407F, 

R-410A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R428A, R-434A, R-437A, R-438A, R-507A, RS-44 (2003 formulation).

iii. How do these proposed unacceptable refrigerants compare to other 
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refrigerants for this end-use with respect to SNAP criteria? 

For new retail food refrigeration (refrigerated food processing and dispensing 

equipment), acceptable refrigerants for which we are not proposing a change of status in this 

end-use category include: FOR12A, FOR12B, HFC–134a, IKON A, IKON B, R–426A, RS–24 

(2002 formulation), R–450A, R–744, SP34E, THR-02 and THR–03.

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; and ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks are 

discussed below. In addition, a technical support document that provides the Federal Register 

citations concerning data on the SNAP criteria (e.g., ODP, GWP, VOC, toxicity, flammability) 

for acceptable alternatives for new refrigerated food processing and dispensing equipment may 

be found in the docket for this rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015x).

(a) Environmental impacts

The refrigerants for which we are proposing a change of status through this action have 

zero ODP, but they have GWPs ranging from 1,770 to 3,990. As shown in Table 12, acceptable 

alternatives have GWPs ranging from one to 1,510. 

Table 12: GWP, ODP, and VOC Status of Refrigerants in New Retail Food Refrigeration (Refrigerated 

Food Processing and Dispensing Equipment) 1,2,3

Refrigerants GWP ODP VOC Proposal

CO2, HFC-134a, R-450A 1 – 1,430 0 No No change

FOR12A, FOR12B, IKON A, IKON B, R426A, RS-24 (2002 composition), SP34E, 

THR-02, THR-03

30 – 1,510 0 Yes3 No change

R-407A, R-407B, R-407C, R-407F, R410A, R-410B, R-421A 1,770 –

2,800

0 No Unacceptable

KDD6, R-125/290/134a/600a 

(55/1/42.5/1.5), R-417A, R-422B, R-422D, 

R-424A, R-437A, R-438A, RS-44 (2003 

composition)

1,810 –

2,730

0 Yes3 Unacceptable
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HFC-227ea, R-404A, R-421B, R-507A 3,190 –

3,990

0 No Unacceptable

R-422A, R-422C, R-428A, R-434A 3,080 –

3,610

0 Yes3 Unacceptable

1The table does not include not-in-kind technologies listed as acceptable for the stated end-uses.

2HCFC-22 and several blends containing HCFCs are also listed as acceptable but their use is severely restricted by 

the phasedown in HCFC production and consumption.

3One or more constituents of the refrigerant are VOC.

Some of the refrigerant blends not subject to the proposed status change, as well as 

several of the substitutes subject to the proposed status change, include small amounts of VOC 

such as R-290 (propane) and R-600 (butane). These amounts are small, and for this end-use are 

not expected to contribute significantly to ground level ozone formation (ICF, 2014e). In the 

actions where EPA listed these refrigerants as acceptable, EPA concluded none of these 

refrigerants in this end-use pose significantly greater risk to ground-level ozone formation than 

other alternative refrigerants that are not VOCs or that are specifically excluded from the 

definition of VOC under CAA regulations (see 40 CFR 51.100(s)) addressing the development 

of SIPs to attain and maintain the NAAQS.

The refrigerants not subject to the proposed status change are highly volatile and 

typically evaporate or partition to air, rather than contaminating surface waters. Their effects on 

aquatic life are expected to be small and pose no greater risk of aquatic or ecosystem effects than 

those of other refrigerants that are subject to the proposed status change for this end-use.

(b) Flammability 

For the retail food refrigeration (refrigerated food processing and dispensing equipment) 

end-use category, all other refrigerants, including those for which we are proposing to change the 

status to unacceptable, are not flammable (e.g., those listed under ASHRAE Standard 34-2013 

are class 1 flammability).

(c) Toxicity

Toxicity is not a significant concern for the refrigerants we are proposing to list as 
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unacceptable. Their toxicity is comparable to that of other alternatives that are acceptable in this 

end-use. For the retail food refrigeration (refrigerated food processing and dispensing equipment) 

end-use category, all other refrigerants, including those for which we are proposing to change the 

status to unacceptable, are of lower toxicity (e.g., those listed under ASHRAE Standard 34-2013 

are class A toxicity).

(d) Summary

EPA has listed as acceptable several alternatives that pose lower overall risk to human 

health and the environment than the refrigerants whose status we are proposing to change to 

unacceptable. The risks other than GWP are not significantly different for the alternatives than 

for the refrigerants we are proposing to list as unacceptable, and the GWPs for the refrigerants 

we are proposing to list as unacceptable are significantly higher and thus pose significantly 

greater risk. 

iv. When would the status change?

EPA is proposing a change of status date for new retail food refrigeration (refrigerated 

food processing and dispensing equipment) of January 1, 2021, which the Agency believes is the 

earliest date by which the technical challenges can be met for a safe and smooth transition to 

alternatives particularly considering the need for equipment to comply with any sanitation, safety 

and energy conservation standards while continuing to maintain the properties, characteristics 

and quality of the food or beverage provided by the equipment. EPA recognizes that some 

manufacturers will need time to test alternative refrigerants and develop equipment to use them 

while meeting other standards that may apply. We find however that components for some 

refrigerants, such as HFC-134a, are in wide supply. Further, as noted in our July 2015 rule, at 

least one major beverage retailer has chosen R-744 as its alternative refrigerant for stand-alone 
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equipment and vending machines. Given the change of status dates established for such products 

in that rule (from January 1, 2018 to January 1, 2020) precede the change of status date we are 

proposing here, we expect an increasing supply of R-744 components that could be utilized in 

refrigerated food processing and dispensing equipment. [We note that two substitutes are 

currently awaiting SNAP review for this end-use. These two substitutes, R-448A and R-449A, 

are designed to mimic R-404A and could be readily adapted to those refrigerants if they are 

listed as acceptable in the future.] As discussed below, there are other relevant requirements that 

mean that newly designed equipment will need to be certified as complying with sanitation and 

safety standards, and some may be required to meet energy conservation standards issued by 

DOE. These standards apply to similar equipment that falls within other end-use categories of 

the retail food refrigeration end-use, and changes of status for those end-use categories take 

effect January 1, 2020, or before. Those requirements will provide additional incentive for 

refrigerant producers to increase low-GWP refrigerant supply, for component manufacturers to 

test and qualify components for such low-GWP refrigerants, and for manufacturers to gain the 

technical knowledge necessary to successfully implement those refrigerants. Hence, we foresee 

that additional equipment using similar low-GWP refrigerants, and using components that are 

expected to become available, could be similarly transitioned in a similar amount of time as 

finalized for those other end-use categories.

v. What is the relationship between this SNAP rule and other federal 

rules? 

EPA understands that energy conservation standards issued by DOE apply to some but 

not all refrigerated food processing and dispensing equipment. EPA also understands that food 

safety and sanitation standards, such as those from the U.S. Food and Drug Administration and 

Commented [A10]: The commenting agency is not aware of any 

overlap and does not believe this statement to be true. Probably 

confusing the existence of DOE’s ice-cream unit standards with 

coverage of this; however, DOE has only regulated holdingtemperature equipment and not process equipment such as this. The 

things discussed here may be within the scope of the statutory CRE 

definitions, but there are currently no standards. 

Suggest going out for comment on any regulatory overlap so that 

industry can point out any places where there products may be 

impacted by EPA and other agency energy efficiency standards.
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the National Sanitation Foundation (NSF), as well as product safety standards, such as those 

from UL, apply. 

vi. On which topics is EPA specifically requesting comment?

EPA requests comment on all aspects of this proposal. In particular, we request comment 

on the refrigerant(s) used for equipment in this end-use category, and detailed descriptions of the

functions and why a particular refrigerant is used. We also seek comment on the applicability, 

technical feasibility, research, development and use of HCs, HFC/HFO blends, R-744 or other 

low-GWP alternatives for equipment within this end-use category. Additionally, we request 

comment on applicable standards for equipment used in the United States as well as those that 

apply to products that are pre-charged with refrigerant and exported to other countries and 

specifically request comment on how those standards may affect when equipment can be 

transitioned away from the alternatives we are proposing to list as unacceptable.

EPA requests detailed comment on the specific steps that must be undertaken for

refrigerated food processing and dispensing equipment with alternative refrigerants to be 

available, including the time each such step would take, which steps must occur in sequence, and 

which steps could occur in parallel. EPA requests comments on if and how this timing might 

vary based on the characteristics of the equipment. Such characteristics could include, but are not 

limited to, compressor type, condenser design (e.g., air cooled or water cooled), refrigeration 

capacity, intended dispensing rate (e.g., short-term rush dispensing or steady dispensing over 

longer time), and refrigerant currently used and potentially used. 

Additionally, EPA requests comment on our description of this end-use category to 

ensure it is sufficiently understood particularly by those in the equipment manufacturing and 

equipment servicing industry. For example, are there other technical factors that should be used 
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to describe this end-use category? In particular, do such factors describe equipment types that are 

sufficiently distinct such that they are better described as two separate end-use categories (e.g., 

processing/dispensing and dispensing-only)? 

e. Proposed change of status for certain HFC refrigerants for new 

household refrigerators and freezers

As provided in the following table, EPA is proposing to change the status of numerous 

refrigerants from acceptable to unacceptable for new household refrigerators and freezers:

Table 13. Proposed Change of Status Decisions for Household Refrigerators and Freezers

End-use Substitutes Proposed Decision

Household refrigerators and freezers 

(new only)

FOR12A, FOR12B, HFC-134a, KDD6, R125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, 

R-407C, R-407F, R-410A, R-410B, R-417A, R421A, R-421B, R-422A, R-422B, R-422C, R422D, R-424A, R-426A, R-428A, R-434A, R437A, R-438A, R-507A, RS-24 (2002 

formulation), RS-44 (2003 formulation), SP34E, 

and THR-03.

Unacceptable as of 

January 1, 2021

i. What is the affected end-use?

Household refrigerators, freezers and combination refrigerator/freezers are intended 

primarily for residential use, although they may be used outside the home. The designs and 

refrigeration capacities of equipment vary widely. Household refrigerators and freezers are 

composed of three main categories of equipment. Household freezers only offer storage space at 

freezing temperatures, while household refrigerators only offer storage space at non-freezing 

temperatures. Products with both a refrigerator and freezer in a single unit are most common. In 

addition to the most common types, other small refrigerated household appliances exist (i.e., 

chilled kitchen drawers, wine coolers, and mini-fridges). Household refrigerators and freezers 

have all refrigeration components integrated, and for the smallest types, the refrigeration circuit 

is entirely brazed or welded. These systems are charged with refrigerant at the factory and 

typically require only an electricity supply to begin operation.
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The 2014 ASHRAE Handbook of Refrigeration provides an overview of food 

preservation in regards to household refrigerators and freezers. Generally, a storage temperature 

between 32 and 39°F (0 to 3.9°C) is desirable for preserving fresh food. Humidity and higher or 

lower temperatures are more suitable for certain foods and beverages. Wine chillers, for 

example, are frequently used for storing wine, and have slightly higher optimal temperatures 

from 45 to 65°F (7.2 to 18.3°C). Freezers and combination refrigerator-freezers that are designed 

to store food for long durations have temperatures below 8°F (-13.3°C) and are designed to hold 

temperatures near 0 to 5°F (-17.7 to -15°C). In single-door refrigerators, the optimum conditions 

for food preservation are typically warmer than this due to the fact that food storage is not 

intended for long-term storage.

The following alternatives are currently acceptable for new household refrigerators and 

freezers: FOR12A, FOR12B, HFC-134a, HFC-152a, IKON A, IKON B, KDD6, R125/290/134a/600a (55.0/1.0/42.5/1.5), R-290, R-404A, R-407C, R-407F, R-410A, R-410B, R417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-427A, R428A, R-434A, R-437A, R-438A, R-441A, R-450A, R-513A, R-507A, R-600a, RS-24 (2002 

formulation), RS-44 (2003 formulation), SP34E, THR-02 and THR-03. Of those, R-290, R-441A 

and R-600a are acceptable subject to use conditions.

Currently, the most commonly used refrigerant in the United States for household 

refrigerators and freezers is R-134a, a HFC with a GWP of 1,430. However, throughout many 

parts of the world, R-600a with a GWP of 8 is the most commonly used refrigerant and there are 

ongoing efforts to help facilitate the adoption and continued use of R-600a in this industry 

(ORNL, 2015). The European Union (EU) banned the use of HFCs with a GWP greater than 150 
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(which includes R-134a) for household refrigerators and freezers as of January 1, 2015.41 R-600a 

has been used in Europe for approximately two decades. Throughout parts of Asia, Africa, and 

South America, R-600a is the dominant refrigerant for this end-use. In its 2014 assessment 

report,42 the TEAP’s RTOC projects that by 2020 about 75 percent of new household 

refrigerators globally will use R-600a, a small percentage will use HFOs, and the rest will use 

HFC-134a. There are other alternatives that can be considered too. EPA also listed R-450A and 

R-513A as acceptable for use in this end-use (79 FR 62863, October 21, 2014; 80 FR 42053, 

July 16, 2015, respectively). As noted in the preamble to those Notices of Acceptability, both R450A and R-513A were designed to match the characteristics and performance of HFC-134a and 

therefore we conclude that they may be under consideration by manufacturers as well. 

EPA previously found a number of flammable HC refrigerants including R-290, R-441A 

and R-600a as acceptable, subject to use conditions in household refrigerators and freezers (76 

FR 78832, December 20, 2011; 80 FR 19454, April 10, 2015). Hydrocarbon refrigerants have 

been in use for over 20 years in countries such as Germany, the United Kingdom, Australia, and 

Japan.43

ii. Which refrigerants is EPA proposing to list as unacceptable? 

For new household refrigerators and freezers, EPA is proposing to change the status of 

the following refrigerants from acceptable to unacceptable: FOR12A, FOR12B, HFC-134a, 

KDD6, R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R-407F, R-410A, R-410B, 

 

41 Regulation (EU) No 517/2014 of the European Parliament and of the Council of 16 April 2014 on fluorinated 

greenhouse gases and repealing Regulation (EC) No 842/2006. Available online at: http://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=uriserv:OJ.L_.2014.150.01.0195.01.ENG.

42 TEAP 2014 assessment report. Available at: http://conf.montreal-protocol.org/meeting/mop/mop27/presession/Background%20Documents%20are%20available%20in%20English%20only/RTOC-AssessmentReport-2014.pdf.

43 Ecomall, 2015. Greenfreeze: A Revolution in Domestic Refrigeration. Accessible at:

http://www.ecomall.com/greenshopping/greenfreeze.htm.
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R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-428A, R434A, R-437A, R-438A, R-507A, RS-24 (2002 formulation), RS-44 (2003 formulation), SP34E, 

and THR-03.

iii. How do these proposed unacceptable refrigerants compare to other 

refrigerants for this end-use with respect to SNAP criteria? 

For new household refrigerators and freezers, acceptable refrigerants for which we are 

not proposing a change of status in this end-use include: HFC-152a, IKON A, IKON B, and 

THR-02; two HFC/HFO blends R-513A and R-450A; and HC refrigerants R-290, R-441A and 

R-600a.

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; and ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks are 

discussed below. In addition, a technical support document that provides the Federal Register 

citations concerning data on the SNAP criteria (e.g., ODP, GWP, VOC, toxicity, flammability) 

for acceptable alternatives for new household refrigerators and freezers may be found in the 

docket for this rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015x). 

(a) Environmental impacts

The refrigerants we are finding unacceptable through this action also have zero ODP, but 

they have GWPs ranging from 918 to 3,990. As shown in Table 14, other alternatives, some of 

which are acceptable subject to use conditions, have GWP ranging from one to 630. 

Table 14: GWP, ODP, and VOC Status of Refrigerants in New Household Refrigerators and Freezers1,2,3

Refrigerants GWP ODP VOC Proposal

IKON A, IKON B, R-290, R-441A, R-600a, 

THR-02

3 – 560 0 Yes3 No change
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HFC-152a 124 0 No No change

R-450A, R-513A 600 – 630 0 No No change

HFC-134a 1,430 0 No Unacceptable

FOR12A, FOR12B, R-426A, RS-24 (2002 

composition), SP34E, THR-03

920 – 1,510 0 Yes3 Unacceptable

R-407C, R-407F, R-410A, R-410B, R-421A 1,770 – 2,630 0 No Unacceptable

KDD6, R-125/290/134a/600a (55/1/42.5/1.5), 

R-417A, R-422B, R-422D, R-424A, R-437A, 

R-438A, RS-44 (2003 composition)

1,810 – 2,730 0 Yes3 Unacceptable

R-404A, R-421B, R-507A 3,190 – 3,990 0 No Unacceptable

R-422A, R-422C, R-428A, R-434A 3,080 – 3,610 0 Yes3 Unacceptable

1The table does not include not-in-kind technologies listed as acceptable for the stated end-uses.

2HCFC-22 and several blends containing HCFCs are also listed as acceptable but their use is severely restricted by 

the phasedown in HCFC production and consumption.

3One or more constituents of the refrigerant are VOC.

Three substitutes that remain acceptable subject to use conditions, R–290, R–600a, and 

R–441A, are or are composed primarily of VOC. EPA’s analysis indicates that their use as 

refrigerants in this end-use are not expected to contribute significantly to ground level ozone 

formation (ICF, 2014e). In the actions where EPA listed these refrigerants as acceptable subject 

to use conditions, EPA concluded none of these refrigerants in this end-use pose significantly 

greater risk to ground-level ozone formation than other alternative refrigerants that are not VOCs 

or that are specifically excluded from the definition of VOC under CAA regulations (see 40 CFR 

51.100(s)) addressing the development of SIPs to attain and maintain the NAAQS.

The refrigerants not subject to the proposed status change are highly volatile and 

typically evaporate or partition to air, rather than contaminating surface waters. Their effects on 

aquatic life are expected to be small and pose no greater risk of aquatic or ecosystem effects than 

those of other refrigerants that are subject to the proposed status change for this end-use.

(b) Flammability

For household refrigerators and freezers, with the exception of HFC-152a, R-290, R-600a 

and R-441A, all other refrigerants listed as acceptable, including those for which we are 

proposing to change the status to unacceptable, are not flammable. The HCs R-290 and R-600a 
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are classified as Class A3 (lower toxicity, higher flammability) refrigerants under the standard 

ASHRAE 34 (2013) while HFC-152a is classified as Class A2 (lower toxicity, lower 

flammability). To address flammability, EPA listed these HCs as acceptable, subject to use 

conditions. The use conditions include conditions consistent with industry standards, limits on 

charge size, and requirements for warnings and markings on equipment to inform consumers and 

technicians of potential flammability hazards. Our assessment and listing decisions (76 FR 

78832; December 20, 2011 and FR 80 1954; April 10, 2015) found that the overall risk, 

including the risk due to flammability with the use conditions, is not significantly greater than for 

other refrigerants at that time and likewise are not significantly greater than for the refrigerants 

we are proposing to list as unacceptable. EPA found HFC-152a acceptable for new household 

refrigerators and freezers in the original SNAP rule indicating “[a]lthough HFC-152a is 

flammable, a risk assessment demonstrated it could be used safely in this end-use” (59 FR 

13081; March 18, 1994).

(c) Toxicity

Toxicity is not a significant concern for the refrigerants we are proposing to list as 

unacceptable. Their toxicity is comparable to that of other alternatives that are acceptable in this 

end-use. The refrigerants subject to the proposed status change and the refrigerants not subject to 

the proposed status change, if listed under ASHRAE 34 (2013), are classified as A refrigerants 

(lower toxicity).

(d) Summary

EPA has listed as acceptable several alternatives that pose lower overall risk to human 

health and the environment than the refrigerants whose status we are proposing to change to 

unacceptable. The risks other than GWP are not significantly different for the alternatives than 
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for the refrigerants we are proposing to list as unacceptable, and the GWPs for the refrigerants 

we are proposing to list as unacceptable are significantly higher and thus pose significantly 

greater risk. 

iv. When would the status change?

EPA is proposing a change of status date for new household refrigerators and freezers of 

January 1, 2021, by this date the Agency believes the technical challenges can be met for a safe 

and smooth transition to alternatives, particularly considering the likely use of alternatives that 

are acceptable subject to use conditions such as isobutane or propane. As noted above, most 

experts, including the TEAP, anticipate the majority of the household refrigeration market will 

use HC refrigerants globally and EPA does not have information suggesting anything different 

for the United States. Although some models may be able to transition in compliance with use 

conditions required for alternatives earlier, the Agency believes that most can transition by 2021.

EPA recognizes that manufacturers will need time to continue product design work for 

alternative refrigerants, drawing from current models used both in the United States and 

elsewhere. Household refrigerators are subject to DOE energy conservation standards and will 

need to be tested to demonstrate compliance with those standards. We understand that there may 

be limitations with regards to the availability of testing facilities. If the proposed change of status 

date was exceedingly ahead of the next anticipated DOE energy conservation standard date, it 

could affect the availability of testing facilities. DOE’s previous energy conservation rulemaking 

for this end-use was finalized in 2011 with a compliance date of September 15, 2014 (76 FR 

57516; September 15, 2011). EPA anticipates that any amended standard set by DOE for these 

products in an upcoming rulemaking will, consistent with prior rulemakings, have a compliance 

date no earlier than 2020. As a result, EPA’s proposed change of status in 2021 likely would 
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come after such an expected compliance date.Therefore, the next standard is expected to have a 

compliance date in or shortly after 2020 and thus the Agency’s proposed change of status for 

2021 is not exceedingly ahead of the next anticipated DOE energy conservation standard – it is 

after that expected compliance date. 

v. What is the relationship between this SNAP rule and other federal 

rules? 

DOE energy conservation standards apply to household refrigerators and freezers, as 

discussed in section VI.A.4.e.iv.

vi. On which topics is EPA specifically requesting comment?

EPA requests comment on all aspects of this proposal. In particular, we request comment 

on the proposed change of status date of January 1, 2021. In particular, EPA requests comments 

on the specific steps that must be undertaken to commercialize household refrigerators and 

freezers with alternative refrigerants in the United States, including the time each step would 

take, which steps must occur in sequence, and which steps could occur in parallel. EPA requests 

comments on how and if this timing might vary based on the characteristics of the household 

refrigerator and freezer. Such characteristics could include, but are not limited to, capacity range, 

internal volume, design (e.g., refrigerator-only, freezer-only, or both) and refrigerant currently 

used and potentially used.

B. Motor vehicle air conditioning 

1. Proposed listing of HFO-1234yf as acceptable, subject to use conditions, for 

newly manufactured MVAC systems

EPA is proposing to list HFO-1234yf as acceptable, subject to use conditions, in MVAC 

systems for newly manufactured MDPVs, HD pickup trucks, and complete HD vans. EPA is 

Commented [A11]: Commenting agency expects the 

compliance date for energy efficiency standards for these equipment 

to 2021/2022 at this point.
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proposing to list HFO-1234yf as acceptable, subject to use conditions, for use in complete HD 

vans; we also are requesting comment and information on listing HFO-1234yf as acceptable 

subject, to use conditions for some incomplete HD vans. At this time, our proposal only includes

complete HD vans because we do not have sufficient information on the potential for 

modifications to OEM-installed MVAC systems of incomplete HD vans by secondary and 

tertiary manufacturers and the impact of those modifications on safe use of HFO-1234yf. The 

use conditions are detailed below in section V.B.1.c, “What are the proposed use conditions?”

2. What is the affected end-use?

The vehicle types within the MVAC end-use that are addressed in today’s proposal 

include limited types of heavy-duty (HD) vehicles, specifically, MDPVs,44 HD trucks, and 

complete HD vans.45 EPA has previously listed HFO-1234yf as acceptable subject to use 

conditions in light-duty (LD) motor vehicles and trucks (76 FR 17490; March 29, 2011).

HD vehicles are often subdivided by vehicle weight classifications, as defined by the 

vehicle’s gross vehicle weight rating (GVWR), which is a measure of the combined curb (empty) 

weight and cargo carrying capacity of the truck. HD vehicles have GVWRs above 8,500. Table 

15 outlines the HD vehicle weight classifications commonly used. MDPVs,46 HD pickup trucks, 

and HD vans are Class 2b and 3 vehicles with GVWRs between 8,501 and 14,000 pounds.

Table 15. Vehicle Weight Classification

Class 2b 3 4 5 6 7 8

GVWR (lb) 8,501 -

10,000

10,001-

14,000

14,001-

16,000

16,001-

19,500

19,501 -

26,000

26,001-

33,000

> 33,000

 

44 Defined at 40 CFR 86.1801-03.

45 MVAC systems provide passenger comfort cooling for light-duty cars and trucks, heavy-duty vehicles (large 

pick-ups, delivery trucks, recreational vehicles, and semi-trucks), off-road vehicles, buses, and rail vehicles. EPA is 

not addressing other types of HD vehicles, off-road vehicles, buses, or trains in the proposed listing decision. 

46 MDPVs are classified as HD vehicles based on their GVWR, but due to their similarities to LD vehicles they are 
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The types of HD vehicles for which EPA is proposing to list HFO-1234yf as acceptable, 

subject to use conditions, are in many ways more similar to LD vehicles, for which HFO-1234yf 

has already been approved under SNAP,47 than they are to the HD vehicles with a higher GVWR 

classification. These vehicle types are similar to LD vehicles technologically and most are 

manufactured by companies with major light-duty markets in the United States and in a similar 

manner to LD vehicles.

48 Ford, General Motors, and Fiat Chrysler Automobiles (FCA) produce 

approximately100 percent of HD pickup trucks and approximately 95 percent of HD vans, with 

Daimler and Nissan producing the remaining approximately 5 percent of HD vans.49 In many 

cases, these types of HD vehicles are versions of their LD counterparts (ICCT 2015x). For 

example, the Silverado 1500, Ram 1500, and Ford F-150 are the LD counterparts of the HD 

Silverado 2500/3500, Ram 2500/3500, and Ford F-250/F-350/F-450 pickup trucks (ICF, 2015x). 

The primary difference between HD pickup trucks and vans and their LD counterpart vehicles is 

that HD pickups and vans are occupational or work vehicles that are designed for much higher 

towing and payload capabilities than are LD pickups and vans.

All types of HD vehicles can be sold as “complete” or “incomplete” vehicles (76 FR 

57259-60; September 15, 2011). Complete vehicles are sold by vehicle manufacturers to endusers with no secondary manufacturer making substantial modifications prior to registration and 

use. Incomplete vehicles are sold by vehicle manufacturers to secondary manufacturers without 

 

subject to the GHG emissions standards established for LD trucks.

47 HFO-1234yf is listed as acceptable, subject to use conditions for newly manufactured passenger cars and lightduty trucks only (40 CFR part 82 subpart G).

48 This is more broadly true for heavy-duty pickup trucks than vans because every manufacturer of heavy-duty 

pickup trucks also makes light-duty pickup trucks, while only some heavy-duty van manufacturers also make lightduty vans. (80 FR 40148; July 13, 2015)

49 EPA, 2015. Draft Regulatory Impact Analysis: Proposed Rulemaking for Greenhouse Gas Emissions and Fuel 

Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles–Phase 2. EPA-420-D-15-900. June 2015.

Available at http://www3.epa.gov/otaq/climate/documents/420d15900.pdf.
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the primary load-carrying device or container attached. With regard to HD pickup trucks and 

vans, 90 percent are sold as complete vehicles while only 10 percent are sold as incomplete (80 

FR 40331; July 13, 2015). Of the 10 percent of HD pickups and vans that are sold as incomplete 

vehicles to secondary manufacturers, about half are HD pickup trucks and half are HD vans. 

Examples of modifications by secondary manufacturers to HD pickup trucks are 

installing a flatbed platform or tool storage bins. EPA is not aware of any equipment added by a 

secondary manufacturer to an incomplete HD pickup truck that would result in a secondary 

manufacturer modifying or adjusting the already installed MVAC system to provide cooling 

capacity. 

Incomplete vans are typically sold with no enclosed cabin area behind the driver’s seat, 

and secondary manufacturer modifications could include applications such as conversion to

ambulances, shuttle vans, and motor homes. Incomplete vans may include OEM MVAC systems 

that are identical to those installed in the complete van on which the incomplete model is based. 

In some cases these systems are designed solely for cooling the front driver area, while other 

systems are manufactured by the OEM with additional capability to provide cooling behind the 

driver area to the cabin. Some, but not all, secondary manufacturers use the OEM MVAC system 

with no modification to the contained refrigerant system (hoses, connections, heat exchangers, 

compressor, etc.). 

3. How does HFO-1234yf compare to other refrigerants for these MVAC 

applications with respect to SNAP criteria?

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; and ecosystem effects, particularly 
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from negative impacts on aquatic life. These and other environmental and health risks are 

discussed below. In addition, a technical support document that provides the Federal Register 

citations concerning data on the SNAP criteria (e.g., ODP, GWP, VOC, toxicity, flammability) 

for acceptable alternatives in the relevant end-uses may be found in the docket for this 

rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015x).

Available refrigerants in the end-uses subject to this proposal include HFC-134a, HFC152a,50 and CO2.

51 There are also several blend refrigerants that are listed as acceptable for new 

HD MVAC systems, subject to use conditions, including the HFC blends SP34E and R-426A 

(also known as RS-24) and the HCFC blends, R-416A (also known as HCFC Blend Beta or 

FRIGC FR12), R-406A, R-414A (also known as HCFC Blend Xi or GHG-X4), R-414B (also 

known as HCFC Blend Omicron), HCFC Blend Delta (also known as Free Zone), Freeze 12, 

GHG-X5, and HCFC Blend Lambda (also known as GHG-HP). EPA is not aware of the use or 

development of any of these blend refrigerants in newly manufactured MDPVs, HD pickup 

trucks, or HD vans. HFC-134a is the refrigerant most widely used today in HD MVAC systems.

All MVAC refrigerants are subject to use conditions requiring labeling and the use of unique 

fittings, and the two lower-GWP alternatives (HFC-152a, CO2) currently approved for use in HD 

vehicles are subject to additional use conditions mitigating flammability and toxicity as 

appropriate to the alternative. 

As explained more fully below, to evaluate environmental, flammability, and toxicity 

risks resulting from the use of HFO-1234yf in new MDPVs, HD pickup trucks, and complete 

HD vans, the Agency is relying on EPA’s analysis conducted in support of the 2011 listing 

 

50 HFC-152a is listed as acceptable, subject to use conditions, for new vehicles only at 40 CFR part 82 subpart G; 

final rule published June 12, 2008 (73 FR 33304).

51 CO2 is listed as acceptable, subject to use conditions, for new vehicles only at 40 CFR part 82 subpart G; final rule 

published June 6, 2012 (77 FR 33315).
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decision for HFO-1234yf for LD vehicles. In addition, we considered risk assessments 

performed by OEMs and independent consultants on the use of HFO-1234yf in LD vehicles 

through SAE Cooperative Research Programs (CRPs) and found these were consistent with our 

analysis. Based on that analysis, in 2011 EPA concluded that for LD vehicles HFO-1234yf did 

not pose significantly greater risk to human health and the environment than the other 

alternatives when used in accordance with use conditions established as part of the listing 

decision. The refrigerants to which HFO-1234yf was compared in the 2011 action for LD 

vehicles are the same refrigerants available for use in the vehicle types included in today’s

proposal.

EPA is able to rely on the 2011 analysis of HFO-1234yf in LD vehicles in support of this 

proposal because the MVAC systems, vehicle designs, and the potential for exposure for the HD 

vehicle types for which EPA is proposing to list HFO-1234yf as acceptable, subject to use 

conditions, in today’s action are identical or very similar to those of LD vehicles. As discussed in 

more detail below, EPA has determined that the analyses conducted on HFO-1234yf in LD 

vehicles are sufficiently conservative to support today’s proposal, and, in turn, that the use of 

HFO-1234yf in the MVAC systems of MDPVs, HD pickup trucks, and complete HD vans does 

not pose greater risk to human health or the environment than other alternatives, when used in 

accordance with use conditions.

a. Environmental impacts

HFO-1234yf has a GWP of one to four. HFO-1234yf has a GWP similar to or lower than 

the GWP of other alternatives for the HD vehicle types addressed in today’s proposal. For 

example, its GWP is significantly lower than that of HFC-134a, the refrigerant most widely used 

in these vehicles today, which has a GWP of 1,430. As shown in Table 16, two other 
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alternatives, HFC-152a,52 and CO2

53 have GWPs of 1,430, 124, and one, respectively. Other 

acceptable refrigerants for the HD vehicle types addressed in today’s proposal have GWPs 

ranging from 1 to 2,340.

Table 16: GWP, ODP, and VOC Status of HFO-1234yf Compared to Other Refrigerants in MVAC 

Systems of Newly Manufactured MDPVs, HD Pickup Trucks, and Complete HD Vans1,2,3

Refrigerants GWP ODP VOC Status Proposal

HFO-1234yf 1-4 0 No Acceptable, 

subject to use 

conditions

CO2, HFC-152a, HFC134a 1-1,430 0 No No change

IKON A, R-416A, R426A, SP34E30-1,510 0-0.009 Yes3 No change

1The table does not include not-in-kind technologies listed as acceptable for the stated end-use.

2HCFC-22 and several blends containing HCFCs are also listed as acceptable but their use is severely restricted by 

the phasedown in HCFC production and consumption.

3One or more constituents of the blend are VOC.

HFO-1234yf does not deplete the ozone layer. Like HFO-1234yf, HFC-134a, HFC-152a, 

CO2 and the HFC blends SP34E and R-426Ado not deplete the ozone layer; however, the HCFC 

blends have ODPs ranging from 0.012 to 0.056. 

HFO-1234yf, HFC-134a, HFC-152a, and CO2 are exempt from the definition of VOC 

under CAA regulations (see 40 CFR 51.100(s)) addressing the development of SIPs to attain and 

maintain the NAAQS. The HFC blends and some of the HCFC blends have one or more 

components that are VOCs.

Another potential environmental impact of HFO-1234yf is its atmospheric decomposition 

to trifluoroacetic acid (TFA, CF3COOH). TFA is a strong acid that may accumulate on soil, on 

plants, and in aquatic ecosystems over time and that may have the potential to adversely impact 

 

52 HFC-152a is listed as acceptable, subject to use conditions, for new vehicles only at 40 CFR part 82 subpart G; 

final rule published June 12, 2008 (73 FR 33304).

53 CO2 is listed as acceptable, subject to use conditions, for new vehicles only at 40 CFR part 82 subpart G; final 

rule published June 6, 2012 (77 FR 33315).
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plants, animals, and ecosystems.54 Simulations have found that the amount of TFA in rainfall

produced from a transition of all mobile air conditioners in the continental United States to HFO1234yf has been estimated to be double or more the values observed in the United States in 2009 

from all sources, natural and artificial (i.e., HFC-134a) sources(Luecken et al., 2009). In 

comparison, the amount of TFA produced from HFO-1234yf is expected to be higher than that of 

other fluorinated refrigerants in this end-use.

In support of the 2011 listing decision for HFO-1234yf in LD vehicles, EPA analyzed 

potential TFA concentrations from a full transition to HFO-1234yf in all MVAC applications, 

not limited to LD vehicles (ICF, 2009; ICF, 2010a,b,c,e). The analysis found a maximum 

projected concentration of TFA in rainwater of approximately 1,700 ng/L. This maximum 

projected concentration identified in EPA’s analysis, 1700 ng/L (ICF, 2010b), was roughly 34

percent higher than that projected in a 2009 peer reviewed article (Luecken et al., 2009). The 

differences in projected TFA concentrations in water is a reflection of EPA’s reliance on higher 

emission estimates (ICF, 2010b). Even when relying on more conservative emission estimates, a

concentration of 1700 ng/L corresponds to roughly 1/600th of the No-Observed-Adverse-EffectLevel (NOAEL) for the most sensitive algae species, which is also well below the NOAEL for 

the most sensitive aquatic animal species (ICF, 2009). 

Since the 2011 final rule listing HFO-1234yf as acceptable for LD vehicles, additional 

research on TFA has been conducted. The UNEP Ozone Secretariat provided a summary of key 

information pertaining to TFA based on the 2014 Assessment Reports of the Environmental 

Effects Assessment Panel (EEAP) and the Scientific Assessment Panel (SAP) of the Montreal 

Protocol. The brief states, “While it is well established that TFA is a ubiquitous natural 

 

54 Other fluorinated compounds also decompose into TFA, including HFC-134a.
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component in rivers, lakes, and other surface water bodies, uncertainties remain regarding 

anthropogenic sources, long-term fate and abundances as these are linked to current and future 

use and emissions of HFCs, HCFCs, and HFOs. Based on estimates to 2040, increases are 

predicted to remain relatively low and are therefore not expected to be a significant risk to 

human health or detrimental to the environment. Projected future increased loadings of TFA to 

playas, land-locked lakes, and the oceans due to continued use of HCFCs, HFCs, and 

replacement products such as HFOs are still judged to present negligible risks for aquatic 

organisms and humans.” The UNEP background document also states that TFA and its salts “do 

not bioconcentrate in aquatic organisms, and do not biomagnify in the food chain. Thus they 

present negligible risk to organisms higher on the food chain, including humans.”

A 2014 study by Kazil, et al.55 analyzed TFA deposition in the United States assuming 

100 percent of all MVAC systems use HFO-1234yf. The results indicated that rainwater TFA 

concentrations, while varying strongly geographically, will on average be low compared to the 

levels at which toxic effects are observed in aquatic systems. The additional information 

available since our 2011 listing decision shows no greater risk than our earlier analysis.

Taking into consideration the analysis conducted in support of the 2011 listing decision, 

which was based on conservative emissions assumptions and a transition from HFC-134a to 

HFO-1234yf for all MVAC systems (not limited to LD vehicles), and the research that has been 

conducted since, EPA concludes that the use of HFO-1234yf in the HD vehicle types addressed 

in this action will not pose a significant risk to the environment from atmospheric decomposition

to TFA.

 

55 Deposition and rainwater concentrations of trifluoroacetic acid in the United States from the use of HFO-1234yf’

(Kazil et al., 2014). JGR-Atmospheres, 2014.
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Based on the consideration of all of these environmental impacts, EPA concludes that 

HFO-1234yf does not pose significantly greater risk to the environment than the other 

alternatives for use in newly manufactured MDPVs, HD pickup trucks, and complete HD vans, 

and it poses significantly less risk than several of the alternatives with high-GWPs and ODPs.

b. Flammability 

HFO-1234yf is a flammable refrigerant classified as A2L under ASHRAE 34-2013. 

HFC-134a and CO2 are nonflammable refrigerants, while HFC-152a is slightly more flammable 

than HFO-1234yf with an ASHRAE classification of A2. 

To evaluate human health and safety impacts, including flammability risks, of the use of 

HFO-1234yf in MDPVs, HD pickup trucks, and complete HD vans, the Agency is relying on 

EPA’s analysis conducted in support of the 2011 listing decision for HFO-1234yf for LD 

vehicles and information submitted during the public comment period of the proposal for the 

2011 final decision (October 19, 2009; 74 FR 53445), including the SAE CRP risk assessments. 

With regards to occupational exposure, EPA’s risk screen on the use of HFO-1234yf in LD 

vehicles evaluated flammability risks (e.g., potential for a fire from release and ignition) in 

workplace situations, such as during equipment manufacture and disposal or recycling of vehicle 

end-of-life. Modeling of concentrations of HFO-1234yf in the workplace scenarios found shortterm, 15-minute concentrations of 28 ppm or less—far below the lower LFL of 6.2 percent by 

volume (62,000 ppm) (ICF, 2008). 

The SAE CRP’s risk assessments also evaluated flammability risks to technicians. The 

SAE CRP conducted Computational Fluid Dynamics (CFD) modeling of exposure levels in case 

of a leak in a system in a service shop. The SAE CRP found that a leaked concentration of HFO1234yf could exceed the LFL of 6.2%, but only within ten centimeters or less of the leak. The 
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SAE CRP risk assessment concluded that the risk of this occupational exposure scenario is

“inconsequential” because ignition sources would not be located within ten centimeters of the 

MVAC system given technicians’ familiarity with precautions necessary to avoid flammability 

risks due to the presence of other flammable materials in the engine compartment (SAE, 2013). 

EPA notes that HFO-1234yf is less flammable and results in a less energetic flame than a 

number of fluids that motor vehicle service technicians and recyclers or disposers deal with on a 

regular basis, such as oil, anti-freeze, transmission fluid, and gasoline. The results of the CRP 

indicate that HFO-1234yf does not pose a greater risk in occupational settings than 

nonflammable alternatives, or HFC-152a, which is more flammable than HFO-1234yf and 

already approved for use in the HD vehicle types being addressed in this action.

Regarding the flammability risks of HFO-1234yf to passengers inside a LD vehicle, in 

support of the 2011 listing decision, EPA determined the following (76 FR 17490; March 29, 

2011):

“Depending on the charge size of an HFO-1234yf MVAC system, which may range from 

as little as 400 grams to as much as 1600 grams (ICF, 2008), it is possible in a worst case 

scenario to reach a flammable concentration of HFO-1234yf inside the passenger 

compartment. This could occur in the case of a collision that ruptures the evaporator in 

the absence of a switch or other engineering mitigation device to prevent flow of high 

concentrations of the refrigerant into the passenger compartment, provided that the 

windows and windshield remain intact. As stated in the SAE CRP, ignition of the 

refrigerant once in the passenger cabin is unlikely (probability on the order of 10-14

occurrences per operating hour) because the only causes of ignition within the passenger 

cabin with sufficient energy to ignite the refrigerant would be use of a butane lighter 
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(EPA-OAR-2008-0664-0056.2). If a passenger were in a collision, or in an emergency 

situation, it is unlikely that they would choose to operate a butane lighter in the passenger 

cabin. Additionally, it is unlikely ignition would occur from a flame from another part of 

the vehicle because automobiles are constructed to seal off the passenger compartment 

with a firewall. If a collision breached the passenger compartment such that a flame from 

another part of the vehicle could reach it, that breach would also create ventilation that 

would lower the refrigerant concentration below the lower flammability limit. Similarly, 

if either a window or the windshield were broken in the collision, the ventilation created 

would lower the refrigerant concentration below the lower flammability limit. Therefore, 

EPA finds that flammability risks of HFO-1234yf to passengers inside a vehicle will be 

low. Further, these risks are likely to be less than those from HFC-152a, another 

flammable refrigerant that EPA has previously found acceptable subject to use 

conditions, because HFC-152a has a lower LFL and a lower minimum ignition energy 

than HFO-1234yf (EPA-HQ-OAR-2008-0664-0008, -0013.4, -0056.2).”

Since that time additional analysis has been conducted under more recent SAE CRPs. 

The fourth and most recent SAE CRP, SAE CRP1234-4, was established in October 2012 

in response to a press release issued by the German OEM Daimler “suggesting that new testing 

conducted by the company had shown R-1234yf to pose greater risk of vehicle fire than was 

estimated by the prior CRP1234 analysis.” The final report for SAE CRP1234-4 was released on 

July 24, 2013, and concluded that the “refrigerant release testing completed by Daimler was 

unrealistic.” And, “their testing created extreme conditions that favored ignition while ignoring 

many mitigating factors that would be present in an actual real-world collision.”56 The OEM 

 

56 Executive Summary for Additional Risk Assessment of Alternative Refrigerant R-1234yf, Prepared by Gradient 
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members of CRP1234-4 included FCA, Ford, General Motors, Honda, Hyundai, Jaguar Land 

Rover, Mazda, PSA, Renault, and Toyota.

To fully assess the newly raised concerns, CRP1234-4 completed two new fault tree 

scenarios as refinements to the original fault tree analysis (FTA). “The two new fault tree 

scenarios consider the possibility of an individual being unable to exit the vehicle due to a 

collision or a non-collision event that involves a refrigerant/oil release, the refrigerant/oil being 

ignited and the fire propagating. The FTA examined average risks across the entire global fleet 

of light-duty vehicles and used a number of conservative assumptions to ensure that the final risk 

estimate would be more likely to overestimate rather than underestimate actual risks.” SAE 

CRP1234-4 concluded that:

“Based on the updated analysis, the estimated overall risk of vehicle fire exposure 

attributed to use of R-1234yf is conservatively estimated at 3x1012 events per 

vehicle operating hour. This is nearly six orders of magnitude less than the current 

risk of vehicle fires due to all causes (approximately 1 x 10-6per vehicle operating 

hour) and also well below other risks accepted by the general public. The current 

overall risk of occupant exposure to adverse events based on R-1234yf usage is 

on the same order of magnitude as that estimated in the prior work of 

CRP1234. Therefore, the conclusions of the former CRP risk assessment are still 

valid: risks are still very small compared to the risks of a vehicle fire from all 

causes and well below risks that are commonly viewed as acceptable by the 

general public” (Gradient, 2013).

 

for SAE International CRP-1234-4. July 24, 2013. Available online at: 

http://www.sae.org/standardsdev/tsb/cooperative/executivesummary.pdf.
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The findings of CRP1234-4 provide additional support for the conclusions of prior CRPs, 

and the EPA’s analysis for its 2011 rule listing HFO-1234yf as acceptable, subject to use 

conditions, for use in LD vehicles. These findings in conjunction with EPA’s earlier evaluation 

for LD vehicles support this proposal to list HFO-1234yf as acceptable, subject to use conditions, 

for the identified HD vehicle types.

To determine the appropriateness of relying on the conclusions of the extensive risk 

assessments conducted on flammability risks to passengers from HFO-1234yf in LD vehicles to 

support today’s proposed SNAP listing of the same alternative in MDPVs, HD pickup trucks, 

and complete HD vans, we conducted an analysis of refrigerant charge size as compared to 

vehicle cabin size.

57 Specifically, we evaluated whether the charge size and vehicle cabin size 

used for the worst case scenario for LD vehicles would be sufficiently conservative to also 

represent a worst case scenario for the HD vehicle types addressed in this proposal. EPA 

analyzed the charge to vehicle cabin size ratios for 38 vehicle models of MDPVs, HD pickup 

trucks, and HD vans and found that the highest ratio of charge size to compartment area, which 

represents the most conservative exposure scenario (smallest passenger compartment with largest 

refrigerant charge), for the types of HD vehicles included in this proposal, is 410 g/m3. This ratio 

is significantly lower than the highest ratio identified for LD vehicles, 641 g/m3, which was 

identified as the most conservative value and used to conduct the risk screen supporting for LD 

listing (ICF, 2008). Thus, the assessment used for the LD vehicles is sufficiently conservative to 

also represent a worst case scenario for the HD vehicle types subject to this proposal.

EPA considered the results of our examination of the ratio of charge size to compartment 

area and our understanding of these vehicle types and their MVAC systems being very similar to 

 

57 ICF International. 2015. Technical Support Document for Acceptability Listing of HFO-1234yf for Motor Vehicle 

Air Conditioning in Limited Heavy-Duty Applications.
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LD vehicles in determining it was appropriate to rely on the currently available analyses on lightduty vehicles. In addition, EPA has considered the characteristics of MDPVs, HD pickup trucks, 

and HD vans that could be different from LD vehicles, such as differences in the engine 

compartment size, passenger cabins, and operating conditions, and how those might impact 

EPA’s reliance on the LD analyses. CRP1234-4 considered the temperature and condition of a 

hot surface that would be necessary to ignite HFO-1234yf released into the engine compartment 

as part of the FTA. The risk assessment conservatively analyzed a refrigerant and oil mixture 

contacting a hot surface, at or above 700 degrees Fahrenheit, in a stagnant zone condition such as 

might occur if the hot surface were covered with a heat shield with limited ventilation. EPA 

considered whether the engine temperatures and configurations of MDPVs, and HD pickup 

trucks and vans would reach higher temperatures (above 700 degrees) more regularly due to 

workload and towing capabilities, and if this would increase the likelihood of a fire under the 

hood of the vehicle. EPA does not believe this is the case. Despite their use as occupational 

vehicles and their towing capabilities, EPA does not expect any engine compartment surfaces to 

reach temperatures above those conservatively assumed for LD vehicles. The engine materials in 

these vehicles are the same as their LD counterparts, or in some cases a different material may be 

used to ensure consistent operating conditions. Also, in many cases the engine compartments for 

these vehicle types are larger than a LD engine compartment, allowing for additional space 

between hot parts and refrigeration lines, as well as increased airflow in the engine, decreasing 

the likelihood that refrigerant would be released onto a hot surface and that contact, if it occurs, 

would occur in a stagnant zone condition.

EPA also considered whether the MVAC systems in diesel vehicles require additional 

analysis, since only gasoline vehicles have been used in the existing risk assessments. Unlike the 
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LD fleet, where few vehicles have diesel engines, about half of HD pickup trucks and vans use 

diesel engines (July 13, 2015; 80 FR 40137). Based on EPA’s understanding that MVAC 

systems and passenger compartments will be the same in gasoline and diesel engines, and 

surface temperatures within a diesel engine are typically lower than those in a gasoline vehicle 

because of the lean combustion and more complete utilization of thermal energy inherent to 

diesel engines, EPA has determined that additional analysis on vehicles with diesel engines is not 

necessary. 

For these reasons, EPA concludes that the currently available assessments on the use of 

HFO-1234yf in LD vehicles are sufficiently conservative to account for all possible flammability 

risks from the use of HFO-1234yf in MDPVs, HD pickup trucks, and complete HD vans.

Relying on the same analysis considered in support of the 2011 SNAP listing of HFO-1234yf as 

acceptable, subject to use conditions, for MVAC in new LD vehicles, ,verifying that more recent 

information is consistent with that analysis, and considering unique factors for these vehicle 

types, EPA concludes that the use of HFO-1234yf in new MVAC systems for MDPVs, HD 

pickup trucks, and complete HD vans does not pose greater flammability risk than the other

alternatives when used in accordance with the proposed use conditions. 

c. Toxicity

To evaluate human health and safety impacts, including toxicity risks, from the use of 

HFO-1234yf in MDPVs, HD pickup trucks, and complete HD vans, the Agency is relying on 

EPA’s analysis conducted in support of the 2011 listing decision for HFO-1234yf for LD 

vehicles and information submitted during the public comment period of the proposal (October 

19, 2009; 74 FR 53445) for the 2011 final decision, including the SAE CRP risk assessments. 

In our analysis supporting the 2011 final decision, EPA compared worker exposures to a 
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workplace exposure limit of 250 ppm58 over an 8-hour time-weighted average for long-term 

occupational exposure to HFO-1234yf, For short-term occupational exposure to HFO-1234yf, 

we compared worker exposure to an acute exposure limit of 98,211 ppm, divided by a margin of 

exposure of 30, for a value of 3270 ppm over 30 minutes.59,60

Concerning workplace exposure, we expect that professional technicians have proper 

training and certification and have the proper equipment and knowledge to minimize their risks

due to exposure to refrigerant from an MVAC system. Thus, worker exposure to HFO-1234yf is 

expected to be low. If workers service MVAC systems using certified refrigerant recovery 

equipment after receiving training and testing, exposure levels to HFO-1234yf are estimated to 

be on the order of 4 to 8.5 ppm on an 8-hour time-weighted average (as compared with a 250 

ppm workplace exposure limit61) and 122 ppm on a 30-minute average (as compared with a 

 

58 This was based on a NOAEL of 4000 ppm from the study, “An Inhalation Prenatal Developmental Toxicity Study 

of HFO-1234yf (2,3,3,3-Tetrafluoropropene) in Rabbits,” EPA-HQ-OAR-2008-0664-0041. We used a factor of 1.9 

to account for differences in blood concentrations between animals and humans, and a margin of exposure or 

collective uncertainty factor of 30. Uncertainty factors of 3 were assigned for animal to human extrapolation, and 10 

for variability within the human population. The long-term workplace exposure limit was calculated as follows: 

4000 ppm (animal exposure) x 1.9 (ratio of estimated human exposure/animal exposure) x 1/3 (UF for animal to 

human extrapolation) x 1/10 (UF for variability within the human population) exposure) = 250 ppm. This value was 

compared against 8-hour average concentrations. See EPA-HQ-OAR-2008-0664-0036 and EPA-HQ-OAR-2008-

0664-0038.

59 This was based on a NOAEL of 51,690 ppm from the study, “Sub-acute (2-week) Inhalation Toxicity Study with 

HFO-1234yf in rats,” EPA-HQ-OAR-2008-0664-0020 through-0020.4, a factor of 1.9 to account for differences in 

blood concentrations between animals and humans and a margin of exposure or collective uncertainty factor of 30.

Uncertainty factors of 3 were assigned for animal to human extrapolation, and 10 for variability within the human 

population. The short-term workplace exposure value was calculated as follows: 51,690 ppm (animal exposure) x 

1.9 (ratio of estimated human exposure/animal exposure)= 98,211 ppm This value was then divided by the expected 

exposure in each scenario, and compared against the target margin of exposure of 30. See EPA-HQ-OAR-2008-

0664-0036 and EPA-HQ-OAR-2008-0664-0038.

60 For comparison, the SAE CRP used exposure limits of 500 ppm over 8 hours and 115,000 ppm over 30 minutes to 

evaluate risks for these same time periods. These are based on the 8-hr Workplace Environmental Exposure Limit 

(WEEL) for HFO-1234yf and for short-term exposure, assuming a NOAEL of approximately 405,800 ppm from the 

study, “Acute (4-hour) inhalation toxicity study with HFO-1234yf in rats.” Note that EPA disagrees with the finding 

that the acute inhalation toxicity study found a NOAEL. We consider this study to show adverse effects at all levels 

because of the presence of grey discoloration in the lungs of the test animals. In order to ensure sufficient protection, 

EPA’s risk assessment used a NOAEL from a subacute study instead of a LOAEL from an acute study.

61 This was based on a NOAEL of 4000 ppm from the study, “An Inhalation Prenatal Developmental Toxicity Study 

of HFO-1234yf (2,3,3,3-Tetrafluoropropene) in Rabbits,” EPA-HQ-OAR-2008-0664-0041. We used a factor of 1.9 

to account for differences in blood concentrations between animals and humans, and a margin of exposure or 
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short-term exposure level of 98,211 ppm divided by a [margin of exposure of 30, for a value of

3270 ppm over 30 minutes62,63).64,65 We also analyzed exposure levels during manufacture and 

final disposition at vehicle end-of-life, and found that they would be no higher than 28 ppm on a 

15-minute average or 8.5 ppm on an 8-hour time-weighted average.

66 The manufacture, use, and 

disposal or recycling of HFO-1234yf MVAC systems are not expected to present a toxicity risk 

to workers. Other alternatives such as HFC-134a and HFC-152a also do not present a toxicity 

risk to workers in the same scenarios; therefore, HFO-1234yf poses the same or less risk than 

other alternatives.

EPA’s review of consumer risks from toxicity of HFO-1234yf indicated that potential 

consumer (passenger) exposure from a refrigerant leak into the passenger compartment of a 

 

collective uncertainty factor of 30. Uncertainty factors of 3 were assigned for animal to human extrapolation, and 10 

for variability within the human population. The long-term workplace exposure limit was calculated as follows: 

4000 ppm (animal exposure) x 1.9 (ratio of estimated human exposure/animal exposure) x 1/3 (UF for animal to 

human extrapolation) x 1/10 (UF for variability within the human population) exposure) = 250 ppm. This value was 

compared against 8-hour average concentrations. See EPA-HQ-OAR-2008-0664-0036 and EPA-HQ-OAR-2008-

0664-0038.

62 This was based on a NOAEL of 51,690 ppm from the study, “Sub-acute (2-week) Inhalation Toxicity Study with 

HFO-1234yf in rats,” EPA-HQ-OAR-2008-0664-0020 through-0020.4, a factor of 1.9 to account for differences in 

blood concentrations between animals and humans and a margin of exposure or collective uncertainty factor of 30. 

Uncertainty factors of 3 were assigned for animal to human extrapolation, and 10 for variability within the human 

population. The short-term workplace exposure value was calculated as follows: 51,690 ppm (animal exposure) x 

1.9 (ratio of estimated human exposure/animal exposure) = 98,211 ppm. This value was then divided by the 

expected exposure in each scenario, and compared against the target margin of exposure of 30. See EPA-HQ-OAR2008-0664-0036 and EPA-HQ-OAR-2008-0664-0038.

63 For comparison, the SAE CRP used exposure limits of 500 ppm over 8 hours and 115,000 ppm over 30 minutes to 

evaluate risks for these same time periods. These are based on the 8-hr Workplace Environmental Exposure Limit 

(WEEL) for HFO-1234yf and for short-term exposure, assuming a NOAEL of approximately 405,800 ppm from the 

study, “Acute (4-hour) inhalation toxicity study with HFO-1234yf in rats.” Note that EPA disagrees with the finding 

that the acute inhalation toxicity study found a NOAEL. We consider this study to show adverse effects at all levels 

because of the presence of grey discoloration in the lungs of the test animals. In order to ensure sufficient protection, 

EPA’s risk assessment used a NOAEL from a subacute study instead of a LOAEL from an acute study. 

64 EPA, 2009. Risk Assessment: PMN 07-0601. Available at: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0664-0036.

65 ICF International. 2009. Risk Screen on Substitutes for CFC-12 in Motor Vehicle Air Conditioning: Substitute: 

HFO-1234yf. Available online at: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0664-

0038.

66 ICF International. 2009. Risk Screen on Substitutes for CFC-12 in Motor Vehicle Air Conditioning: Substitute: 

HFO-1234yf. Available online at: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0664-

0038.
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vehicle is not expected to present an unreasonable risk. The consumer risks due to exposure to 

HFC-152a and HFC-134a are comparable to those of HFO-1234yf, with exposure levels 

expected to be below relevant exposure limits such as their cardiotoxic NOAELs. The consumer 

toxicity risks due to CO2 are mitigated by the use conditions for that refrigerant, resulting in 

comparable risks to other alternatives.

In addition to analyzing exposure to the refrigerant, EPA and the SAE CRPs have also 

considered risks of generating hydrogen fluoride (HF) from combustion of HFO-1234yf. With 

regards to consumer risks from the use of HFO-1234yf in MVAC systems, we have considered 

information concerning consumer exposure to HF from thermal decomposition or combustion of 

HFO-1234yf. The 2009 CRP risk assessments analyzed potential concentrations of HFO-1234yf, 

from a leak inside the passenger compartment, and HF, from thermal decomposition or ignition, 

in the passenger compartment. SAE CRP members conducted testing to measure HF 

concentrations and to identify factors that were most likely to lead to HF formation.

67 One test on 

HF concentrations inside a car cabin found maximum concentrations were in the range of zero to 

35 ppm in trials both with HFO-1234yf and with HFC-134a, with concentrations dropping to 10 

ppm or less after 10 minutes. In a second test of HF generated in the engine compartment, HF 

concentrations from thermal decomposition of HFO-1234yf reached as high as 120 ppm in the 

engine compartment in the worst case, with interior passenger cabin values of 40 to 80 ppm. 

Under the same extreme conditions (flash ignition, temperature of 700 °C, closed hood), HF 

concentrations from thermal decomposition of HFC-134a reached 36.1 ppm in the engine 

compartment with interior passenger cabin values of two to eight ppm. The other trials with less 

extreme conditions found HF concentrations from HFO-1234yf in the engine compartment of 

 

67 http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0664-0056.
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zero to 8 ppm. 

The SAE CRP selected an Acute Exposure Guideline Limit (AEGL)-2 of 95 ppm over 10 

minutes as its criterion for determining toxicity risk from HF.68 Thus, even assuming levels 

inside a passenger compartment reached the highest level that occurred during the tests – 80 ppm 

– a passenger inside a vehicle would at worst experience discomfort and irritation, rather than 

any permanent effects. HF levels that could result in similar effects were also observed for HFC134a. The SAE CRP concluded that the probability of such a worst-case event is on the order of 

10-12 occurrences per operating hour.

69,70 This level of risk is similar to the current level of risk of 

HF generated from HFC-134a.71 To date, EPA is unaware of any reports of consumers affected 

by HF generated by HFC-134a, which has been used in automobile MVAC systems across the 

industry since 1993. Therefore, EPA concludes that when used in accordance with use 

conditions, HFO-1234yf does not pose greater risk overall to human health and the environment 

than other alternatives. 

SAE CRP1234-4 considered the need to reevaluate HF exposure due to decomposition or 

ignition of HFO-1234yf and determined it was unnecessary. This decision considered that: the 

risks of HF evaluated in the earlier CRP were not significantly different from the risks of HF 

generation during use of HFC-134a; a presentation from the German automobile manufacturing 

industry group VDA found that thermal decomposition would not lead to significant amounts of 

HF and confirmed that there is not expected to be additional risk due to HF from HFO-1234yf 

 

68 The AEGL-2 is defined as “the airborne concentration of a substance ...above which it is predicted that the 

general population, including susceptible individuals could experience irreversible or other serious, long lasting 

adverse effects or an impaired ability to escape.” http://www.epa.gov/oppt/aegl/pubs/define.htm.

69 If we assume 250 million passenger vehicles in the US and typical driving times of 500 hours per year per vehicle, 

a risk of 4.6 x 10-12 per operating hour equates roughly to one event every 2 years for all drivers in the entire United 

States

70 Regulations.gov, EPA-HQ-OAR-2008-0664-0056.2.

71 Regulations.gov, EPA-HQ-OAR-2008-0664-0086.1.
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compared to HFC-134a. In addition, the CRP1234-4 considered new scenarios where an 

individual might not be able to leave a car; however, it is expected that because HF is irritating, 

individuals will leave the area unless they are unable to do so. The CRP1234-4 also considered 

that mitigating factors specific to HF, such as convection of HF away from the vehicle due to the 

heat of a fire, mean that the factors already analyzed were likely to be very conservative. Finally, 

the CRP1234-4 was aware of studies conducted by the CRP for a refrigerant blend, referred to as 

“CRP MRB,” that found HF from HFO-1234yf along the side of a vehicle never exceeded the 

health-based HF limit of 95 ppm, even in the case of fire. This additional information confirms 

that the consumer risks from generation of HF are no greater than in EPA’s 2011 evaluation. 

Further, risks of generation of HF are comparable to those from HFC-134a, and likely also from 

HFC-152a. CO2 contains no fluorine, and thus, there are no risks due to HF generation.

EPA did not analyze toxicity concerns from the generation of HF in the workplace. In its 

December 17, 2009, Risk Assessment for Alternative Refrigerants HFO-1234yf and R-744 (CO2), 

the SAE CRP indicated that “service technicians will be knowledgeable about the potential for 

HF generation and will immediately move away from the area when they perceive the irritancy 

of HF prior to being exposed above a health-based limit” (EPA-HQ-OAR-2008-0664-0056.2). 

Because the potential to form HF from HFO-1234yf is similar to that from other MVAC 

refrigerants and because service technicians, recyclers, and disposers have historically handled 

refrigerants with the same concern, including HFC-134a which is the most commonly used 

refrigerant, EPA concludes that HFO-1234yf does not pose greater risk in the workplace with 

regard to HF generation than other available or potentially alternatives. 
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4. What are the proposed use conditions?

All MVAC refrigerants listed as acceptable are subject to use conditions requiring 

labeling and the use of unique fittings. HFC-152a and CO2 are subject to additional use 

conditions mitigating flammability and toxicity as appropriate to the alternative. None of these 

alternative refrigerants can simply be “dropped” into existing HFC-134a AC systems because 

they are listed as acceptable only for newly manufactured vehicles.

EPA is proposing to list HFO-1234yf acceptable, subject to use conditions, because the 

use conditions are necessary to ensure that use of HFO-1234yf will not have a significantly 

greater overall impact on human health and the environment than other alternatives for use in 

MDPVs, HD pickup trucks, and complete HD vans. EPA is proposing to require the same use 

conditions for HFO-1234yf in the HD vehicle types included in today’s proposal that are 

currently required for the use of HFO-1234yf in newly manufactured LD vehicles. Because of 

the similarities in the MVAC systems used for these vehicles, these use conditions will be 

sufficiently protective to ensure use of HFO-1234yf in MDPVs, HD pickup trucks, and complete 

HD vans does not pose significantly greater risk than use of other alternatives. 

The first use condition requires that MVAC systems designed to use HFO-1234yf must 

meet the requirements of SAE J639, “Safety Standards for Motor Vehicle Refrigerant Vapor 

Compression Systems.” This standard sets safety standards that include unique fittings; a 

warning label indicating the refrigerant’s identity and that it is a flammable refrigerant; and 

requirements for engineering design strategies that include a high-pressure compressor cutoff 

switch and pressure relief devices. This use condition also requires that for connections with 

refrigerant containers for use in professional servicing, use fittings must be consistent with SAE 

J2844 (revised October 2011). SAE J639 (2011 version) which specifies quick-connect fittings 
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that are different from those for any other refrigerant. The low-side service port and connections 

will have an outside diameter of 14 mm (0.551 inches) and the high-side service port will have 

an outside diameter of 17 mm (0.669 inches), both accurate to within 2 mm. Under SAE J2844 

(revised October 2011), containers of HFO-1234yf for use in professional servicing of MVAC 

systems must have a left-handed screw valve with a diameter of 0.5 inches and Acme 

(trapezoidal) thread with 16 threads per inch. The SAE standards do not include and EPA has not 

received a submission for unique fittings for small containers of HFO-1234yf refrigerant.

Consistent with the conclusion EPA drew at the time of the EPA’s listing decision for 

HFO-1234yf in LD vehicles relied, EPA believes that the safety requirements that are included 

in SAE J639 sufficiently mitigate risks of both HF generation and refrigerant ignition (March 29, 

2011; 76 FR 17488) for MDPVs, HD pickup trucks, and complete HD vans subject to this 

proposed action. HFO-1234yf is mildly flammable (2L classification) and, like other fluorinated 

refrigerants, can decompose to form the toxic compound HF when exposed to flame or to 

sufficient heat. The SAE J639 standard can also address flammability and HF risks of HFO1234yf for MDPVs, HD pickup trucks, and complete HD vans. For example, SAE J639 provides

for a pressure relief device designed to minimize direct impingement of the refrigerant and oil on 

hot surfaces and for design of the refrigerant circuit and connections to avoid refrigerant entering 

the passenger cabin. The pressure release device ensures that pressure in the system will not 

reach an unsafe level that might cause an uncontrolled leak of refrigerant, such as if the AC 

system is overcharged. The pressure release device will reduce the likelihood that refrigerant 

leaks would reach hot surfaces that might lead to either ignition or formation of HF. Designing 

the refrigerant circuit and connections to avoid refrigerant entering the passenger cabin ensures 

that if there is a leak, the refrigerant is unlikely to enter the passenger cabin. Keeping refrigerant 
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out of the passenger cabin minimizes the possibility that there would be sufficient levels of 

refrigerant to reach flammable concentrations or that HF would be formed and transported where 

passengers might be exposed. 

The second use condition requires the manufacturer of MVAC systems and vehicles to 

conduct Failure Mode and Effects Analysis (FMEA) as provided in SAE J1739 (adopted 2009) 

and keep records of the FMEA on file for three years from the date of creation. SAE J1739 

(adopted 2009) describes a FMEA as “a systematic group of activities intended to: (a) recognize 

and evaluate the potential failure of a product/process and the effects and causes of that failure, 

(b) identify actions that could eliminate or reduce the change of the potential failure occurring, 

and (c) document the process.” Through the FMEA, OEMs determine the appropriate protective 

strategies necessary to ensure the safe use of HFO-1234yf across their vehicle fleet. It is standard 

industry practice to perform the FMEA and to keep it on file while the vehicle is in production 

and for several years afterwards. As with the previous use condition, this use condition is

intended to ensure that new MDPVs, HD pickup trucks, and complete HD vans manufactured 

with HFO-1234yf MVAC systems are specifically designed to minimize release of the 

refrigerant into the passenger cabin or onto hot surfaces that might result in ignition or in 

generation of HF.

5. When would the listing apply? 

EPA proposes that this listing would apply 30 days after the date of publication of a final 

rule. This date, the same as the proposed effective date of this regulation, allows for the safe use 

of this substitute at the earliest opportunity.
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6. What is the relationship between this SNAP rule and other federal rules? 

a. CAA sections 608 and 609

CAA section 609 establishes standards and requirements regarding servicing of MVAC 

systems. Under section 609, no person repairing or servicing motor vehicles for consideration72

may perform any service on an MVAC that involves the refrigerant without properly using 

approved refrigerant recovery or recovery and recycling equipment and no such person may 

perform such service unless such person has been properly trained and certified. Refrigerant 

handling equipment must be certified by EPA or an independent organization approved by EPA.

EPA has issued regulations interpreting this statutory requirement and those regulations are 

codified at subpart B of 40 CFR part 82. The statutory and regulatory provisions regarding 

MVAC servicing apply to all refrigerant alternatives and application is not limited to ozonedepleting refrigerants. Today’s proposal will not have a direct impact on EPA’s regulations 

under section 609. 

Section 608 of the CAA prohibits the intentional release (venting) of all refrigerants 

except those specifically exempted; because HFO-1234yf is not exempt, intentional release from 

MVAC systems of MDVPs, HD pickup trucks, and HD vans addressed in this action would be 

prohibited if the decision to list HFO-1234yf as acceptable subject to use conditions is finalized. 

MVAC end-of-life disposal and recycling specifications are also covered under section 608 of 

the CAA and our regulations issued under that section of the Act, which are codified at subpart F 

of 40 CFR part 82.

 

72 Service for consideration means receiving something of worth or value to perform service, whether in money,

credit, goods, or services.
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b. Would this action listing HFO-1234yf as acceptable, subject to use 

conditions, for MDPVs, HD pickup trucks, and complete HD vans affect 

EPA’s LD GHG standards? 

Today’s proposal to list HFO-1234yf as acceptable, subject to use conditions, if finalized, 

will have no direct effect on the MY 2017-2025 light-duty vehicle GHG standards since today’s

proposed action applies to HD vehicles, not light duty. We raise the issue here, however, because 

today’s proposed action would apply to MPDVs. As noted above in section V.B.1.a., although

MDPVs are classified as HD vehicles based on their GVWR, due to their similarities to LD 

vehicles, GHG emissions from MDPVs are regulated under the LD GHG and fuel economy 

standards, and they are excluded from the HD GHG and fuel economy standards.

73

Nonetheless, this proposed action would have no direct effect on the regulations on 

MDPVs established under the LD GHG standards. Those standards are established by rule and 

EPA is not reopening that rule in this action. We do note, however, that today’s proposal is 

relevant to one of the compliance flexibilities in that rule. As part of the MY 2017-2025 LD 

GHG rule,74 EPA established the availability of credits for the use of alternative refrigerants with 

lower GWPs than that of HFC-134a. If EPA lists HFO-1234yf as acceptable for MDPVs under 

SNAP, as proposed, vehicle manufacturers will be able to obtain credits for the use of HFO1234yf in these vehicles as allowed for in the MY 2017-2025 LD GHG rule. The LD GHG 

standards do not require any specific means of compliance, so manufacturers have the flexibility 

to either switch refrigerants or to comply with the standards by other means.75

c. Would this action listing HFO-1234yf as acceptable, subject to use 

 

73 40 CFR section 1037.5 (c).

74 77 FR 62624, 62807-810 (October 15, 2012); see also 75 FR 25325, 25431-32 (May 7, 2010) (discussing the 

same issue for MY 2012-2016 light-duty vehicles).

75 77 FR 62804-809
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conditions, for certain HD vehicles affect EPA’s HD GHG standards?

The Phase 1 HD GHG rules divided the industry into three discrete categories–

combination tractors, heavy-duty pickups and vans, and vocational vehicles. The Phase 1 rules 

also set separate standards for engines that power vocational vehicles and combination tractors --

based on the relative degree of homogeneity among vehicles within each category (76 FR 57106; 

September 15, 2011). On July 13, 2015, EPA and the National Highway Traffic Safety 

Administration (NHTSA) proposed Phase 2 HD GHG standards that would build on existing 

Phase 1 HD GHG standards, and also proposed GHG standards for certain trailers used in 

combination with HD tractors (80 FR 40137; July 12, 2015). Today’s proposal, should EPA 

adopt it, will have no direct effect on the HD GHG standards, either for Phase 1 or the proposed 

Phase 2.

As part of today’s action, EPA is proposing to list HFO-1234yf as acceptable, subject to 

use conditions, for MDPVs, HD pickup trucks, and complete HD vans. HD pickup trucks and 

vans are one of the categories of HD vehicles regulated under the Phase 1 HD GHG standards, 

and proposed to be further regulated under the Phase 2 program. As part of the Phase 1 HD GHG 

standards, EPA finalized a low leakage requirement of 1.50 percent leakage per year for AC 

systems installed in HD trucks and vans and combination tractors for model years 2014 and later. 

EPA finalized a standard of 1.50 percent leakage per year for heavy-duty pickup trucks and vans

and combination tractors. See section II.E.5 of Phase 1 HD GHG standard preamble (76 FR 

57194-57195) for further discussion of the MVAC leakage standard.

As part of the NPRM for Phase 2 of the HD GHG standards (80 FR 40343; July 12, 

2015), EPA proposed regulatory provisions that would be in place if and when lower-GWP 

alternative refrigerants are approved and adopted by manufacturers of HD vehicles. EPA 
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proposed to adopt the same MVAC leakage standard for vocational vehicles as apply for pickups 

and vans, and for combination tractors. If adopted, these provisions would have the effect of 

easing the burden associated with complying with the lower-leakage requirements when a lowerGWP refrigerant is used instead of HFC-134a. These provisions would recognize that leakage of 

refrigerants would be relatively less damaging from a climate perspective if one of the lowerGWP alternatives is used. Specifically, EPA proposed to allow a manufacturer to be “deemed to 

comply” with the leakage standard set through the Phase 1 regulations by using a lower-GWP 

alternative refrigerant. EPA proposed that in order to be “deemed to comply” the vehicle 

manufacturer would need to use a refrigerant other than HFC-134a that is listed as an acceptable 

alternative refrigerant for heavy-duty MVAC systems under SNAP, and defined under the LD 

GHG regulations at 40 CFR 86.1867-12(e) (80 FR 40343-44; July 12, 2015). The lower-GWP 

refrigerants currently defined at 40 CFR 86.1867-12(e) are HFC-152a, HFO-1234yf, and CO2.

If HFO-1234yf is listed as acceptable under SNAP for use in HD pickup trucks and 

complete HD vans, as proposed, and if the incentive proposed in the Phase 2 HD NPRM is 

finalized, these types of HD vehicles manufactured with HFO-1234yf MVAC systems will be 

“deemed to comply” with the low leakage standard. 

7. On which topics is EPA specifically requesting comment? 

EPA requests comment on all aspects of this proposed action. EPA is particularly 

interested in any additional exposure scenarios or unique characteristics of the types of HD 

vehicles included in today’s action as compared to LD vehicles where HFO-1234yf has 

previously been listed as acceptable. In addition, EPA also specifically requests comment on 

whether the proposed use conditions are adequately protective for MDPVs, HD pickup truck, 

and complete HD vans, or whether more protective use conditions are necessary. If a commenter 
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believes more protective use conditions are necessary, the commenter should identify what 

additional, more protective use conditions could be implemented. 

With regard to incomplete HD pickup trucks and vans, EPA requests information on any 

modifications to incomplete HD pickup trucks by secondary manufacturers that could result in 

modifying the OEM-installed MVAC system. Concerning incomplete HD vans, at this time, 

EPA does not have information on all potential vehicle conversions that could be made by 

secondary manufacturers or the impact those conversions may have with regard to the SNAP 

criteria. Due to lack of information on potential vehicle conversions, EPA cannot assess whether 

or not the same risk analysis used for complete HD vans would be applicable to all incomplete 

HD vans. However, EPA is aware that for some incomplete HD vans, secondary manufacturers 

do not modify the MVAC systems. An example of an incomplete HD van that is manufactured 

by the OEM with cabin cooling that is not altered by the secondary manufacturer might be a HD 

van customized by a secondary manufacturer for transportation of persons with disabilities. In 

this situation, the secondary manufacturer would install wheelchair ramps, lifts, and other 

equipment to meet the needs of their customer in an incomplete HD van from the OEM without 

making any modifications to the OEM-installed MVAC system. However, some secondary 

manufacturers may alter the OEM MVAC system design based on their needs (e.g., alter the 

MVAC system to provide cooling to the back of a vehicle). We request comments on whether 

there is a distinction that can be made between HD vans that could not have the MVAC systems 

modified and those that could have the MVAC systems modified. EPA is not including these 

vehicle types in this proposed action but is interested in receiving information on this topic. If 

such information clearly indicates that necessary distinctions can be made, and EPA establishes 

that use of HFO-1234yf in these vehicles will not result in greater overall risk to human health 
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and the environment, the Agency would consider taking further rulemaking action to include a 

subset of incomplete HD vans in the listing of HFO-1234yf instead. 

Additional risk analysis would be necessary prior to considering a listing decision for 

HFO-1234yf in all incomplete HD vans, especially on those for which the OEM-installed 

MVAC system may be altered. EPA requests comment on secondary manufacturer modifications 

that are likely for HD vans and, we welcome information on the types of modifications that 

could result in altering the MVAC system installed by the OEMs and the procedures for those 

modifications. EPA requests information on potential exposure scenarios, and is especially 

interested in information relevant to risk assessment such as charge sizes, the ratio of charge size 

to cabin size, exposure levels, potential for leaks and for ignition events, and means of mitigating 

risks during system modifications by the secondary manufacturer, and subsequently during the 

useful life of the vehicle. This information may be used to inform a future listing.

Additionally, EPA requests information on development of HFO-1234yf MVAC systems 

for other HD vehicle types or off-road vehicles, or plans to develop these systems in the future. 

This information may be used to inform a future listing.

C. Foam blowing agents

1. Proposed change of status for certain HFC foam blowing agents for rigid PU 

spray foam

As provided in the following table, for rigid PU spray foam, EPA is proposing to list as 

acceptable, subject to narrowed use limits, numerous foam blowing agents for military or spaceand aeronautics-related applications, and change the status from acceptable to unacceptable for 

all other uses:
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Table 17. Proposed Change of Status Decisions for Foam Blowing Agents in Rigid PU Spray Foam

* Under the narrowed use limit, an end user must make reasonable efforts to ascertain that other alternatives are not 

technically feasible due to performance or safety requirements.

EPA is proposing to change the listings from acceptable to unacceptable, for HFC-134a, 

HFC-245fa, and blends thereof; blends of HFC-365mfc with at least four percent HFC-245fa; 

commercial blends of HFC-365mfc with seven to 13 percent HFC-227ea and the remainder 

HFC-365mfc; and the HFC blend Formacel TI for use in rigid PU spray foam, with the exception 

of certain narrowed use limits for military, space, and aeronautics uses. See section VI.C.3 for 

how these proposed changes would apply to imported foam products. 

In the NPRM published on August 6, 2014, EPA proposed to change the listings from 

acceptable to unacceptable for HFC-134a and blends thereof, and the HFC blend Formacel TI for 

End-use Substitutes Proposed Decision

Rigid PU: Spray foam—

high-pressure twocomponent

HFC-134a, HFC-245fa, and blends 

thereof; blends of HFC-365mfc 

with at least four percent HFC245fa, and commercial blends of 

HFC-365mfc with seven to 13 

percent HFC-227ea and the 

remainder HFC-365mfc; and 

Formacel TI. 

Acceptable subject to narrowed use limits for 

military or space- and aeronautics-related 

applications*as of January 1, 2020.

Unacceptable for all applications other than 

military or space- and aeronautics-related 

applications as of January 1, 2020.

Unacceptable for all uses as of January 1, 

2022.

Rigid PU: Spray foam—

low-pressure twocomponent

HFC-134a, HFC-245fa, and blends 

thereof; blends of HFC-365mfc 

with at least four percent HFC245fa, and commercial blends of 

HFC-365mfc with seven to 13 

percent HFC-227ea and the 

remainder HFC-365mfc; and 

Formacel TI. 

Acceptable subject to narrowed use limits for 

military or space- and aeronautics-related 

applications*as of January 1, 2021. 

Unacceptable for all applications other than 

military or space- and aeronautics-related 

applications as of January 1, 2020.

Unacceptable for all uses as of January 1, 

2022.

Rigid PU: Spray foam—

one component foam 

sealants

HFC-134a, HFC-245fa, and blends 

thereof; blends of HFC-365mfc 

with at least four percent HFC245fa, and commercial blends of 

HFC-365mfc with seven to 13 

percent HFC-227ea and the 

remainder HFC-365mfc; and 

Formacel TI. 

Unacceptable as of January 1, 2020.
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spray foam as of January 1, 2017 (79 FR 46149). In that proposal, EPA stated that a number of 

nonflammable HFCs and HFC blends, such as HFC-245fa , blends of HFC-365mfc with at least 

four percent HFC-245fa by weight, and commercial blends of HFC-365mfc and HFC-227ea, 

with seven to 13 percent HFC-227ea and the remainder HFC-365mfc, were available and posed 

significantly less risk in the spray foam end-uses. We noted that these available HFC foam 

blowing agents provide a non-flammable alternative where there are flammability concerns 

associated with in situ use and use with pressurized spray pumps that meant most flammable 

foam blowing agents were not feasible for use based on the current state of knowledge (79 FR 

46149, 46152; August 6, 2014). After considering the comments received on the proposed rule, 

EPA deferred taking final action on spray foam in the final rule. See sections V.D.2.a and 

V.D.3.b of the preamble to the final rule (80 FR 42870; July 20, 2015).

a. What is the affected end-use?

In the past, EPA combined spray foam, commercial refrigeration foam, sandwich panels, 

and marine flotation foam within a single end-use: rigid PU spray foam. However, because of 

differences in the exposure and fire safety characteristics of these uses as well as the fact that 

different alternatives are generally used for each of these applications, EPA more recently 

created separate end-use listings for each of these applications. See 80 FR 42870; July 20, 2015.

Commercial refrigeration and sandwich panels include insulation for walls, pipes (including 

“pipe-in-pipe”), metal doors, vending machines, refrigerated and unrefrigerated coolers, 

refrigerated transport vehicles, and other laboratory and commercial refrigeration equipment, as 

well as foam for taxidermy. These foams may be injected or applied using “pour-in-place” 

equipment, depending on the agent used and on whether the formulation is pressurized. Marine 

flotation foam includes buoyancy or flotation foam used in construction of boats and ships. 
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These foams typically are injected into a cavity in the boat wall from a two-canister (A- and Bside) system under lower pressures and they provide structure as well as buoyancy. Rigid PU 

spray foam, hereafter called “spray foam,” includes insulation for roofing, walls, doors, and other 

construction uses, as well as foam for building breakers for pipelines. These foams are rigid with 

closed cells that still contain the foam blowing agent, which can contribute to the foam’s ability 

to insulate. Spray foam may have similar chemistry to other rigid PU end-uses, but it differs by 

being sprayed onto a surface in the location where it is to be used, either when constructing a 

new building or when adding insulation to an existing building, rather than being injected or 

poured or being produced in a manufacturing facility. As a result, it may be more difficult to 

provide engineered ventilation during application of spray foam than for other foam end-uses.

The proposed action applies only to this last end-use – spray foam and we have identified three 

distinct and separate spray foam applications for this end-use: (1) high-pressure two-component, 

(2) low-pressure two-component, and (3) one-component foam sealants. 

i. High-pressure two-component spray foam 

High-pressure two-component spray foam products are pressurized 800-1600 psi during 

manufacture, are sold in pressurized containers as two parts (i.e., A-side and B-side), and are 

sprayed in the field for thermal insulation and air sealing of buildings and in roofing applications. 

In the United States, Side A typically contains methylene diphenyl isocyanate (MDI), consisting 

of monomeric MDI and higher molecular weight oligomers. Side B typically contains polyols 

and a mixture of other chemicals, including catalysts, flame retardants, blowing agents, and 

surfactants. High-pressure two-component spray foam is blown and applied in situ using highpressure pumps to propel the foam components, and thus, may use liquid blowing agents without 

an additional propellant. Common liquid foam blowing agents used in high-pressure two-
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component spray foam include HFC-245fa; blends of HFC-365mfc with at least four percent 

HFC-245fa; and commercial blends of HFC-365mfc with seven to 13 percent HFC-227ea and 

the remainder HFC-365mfc. This type of spray foam is applied by professionals who wear 

personal protective equipment (PPE) while applying high-density foam insulation for roofing or 

walls. The amount of resin and foam blowing agent is more than for low-pressure twocomponent spray foam and for one-component spray foam sealants. High-pressure twocomponent spray foam comprises the largest portion of the spray foam market.

ii. Low-pressure two-component spray foam 

Low-pressure two-component spray foam products are pressurized to less than 250 psi 

during manufacture, are sold in pressurized containers as two parts (i.e., A-side & B-side), and 

are sprayed in the field for thermal insulation and air sealing of buildings. Low-pressure twocomponent spray foams are typically applied in situ relying upon a gaseous foam blowing agent 

that also serves as a propellant; pumps typically are not needed. This end-use category has 

primarily used the gaseous blowing agent HFC-134a; the Foams Technical Option Committee 

has also identified CO2 and water as options. Low-pressure two-component spray foam is usually 

applied by home improvement contractors to fill in cracks and gaps in a residence using kits that 

are available for sale.

76 The amount of resin and foam blowing agent is smaller than for highpressure two-component spray foam. 

iii. One-component spray foam sealants

One-component foam sealants are packaged in aerosol cans and are applied in situ using 

a gaseous foam blowing agent that is also the propellant for the aerosol formulation. Because the 

 

76 Low-pressure two-component spray foam kits should only be used by trained professionals. The polyurethanes 

industry has guidance on how to use low pressure kits available at: http://spraypolyurethane.org/spf-chemicalhealth-and-safety-training and at http://spraypolyurethane.org/Main-Menu-Category/WeatherizationContractors/Installing-SPF.
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SNAP program has not expressly identified one-component spray foam sealants in the past

descriptions of the end-use, manufacturers of one-component foam sealants may have considered 

acceptable substitutes in the larger rigid PU: commercial refrigeration, spray, and sandwich panel

end-use to apply for this end-use or acceptable propellants in the aerosol sector to apply. This 

end-use category primarily uses light saturated HCs as the blowing agent, as well as HFCs such 

as HFC-134a and HFC-152a. This type of spray foam may be used by consumers and by home 

improvement contractors in order to seal cracks and leaks in a residence, as well as used for pest 

management. The total amount of resin and foam blowing agent is smaller than for low-pressure 

two-component spray foam. 

b. Which foam blowing agents is EPA proposing to list as unacceptable? 

EPA is proposing to change the status of the following HFCs and HFC blends that are 

currently listed as acceptable foam blowing agents for use in spray foam: HFC-134a, HFC245fa, and blends thereof; blends of HFC-365mfc with at least four percent HFC-245fa; 

commercial blends of HFC-365mfc with seven to 13 percent HFC-227ea and the remainder 

HFC-365mfc; and Formacel TI.77

c. How do the proposed unacceptable blowing agents compare to other

blowing agents for these applications with respect to SNAP criteria?

HFCs have been widely used as blowing agents in spray foam in the United States since 

the phaseout of ODS blowing agents such as HCFC-141b, particularly where insulation value 

and flammability have been of greater concern. Over the past ten years, the number of available 

alternatives has increased and the variety of uses for acceptable blowing agents has also 

expanded. A number of new foam blowing agents with low GWPs, both fluorinated and non-

 

77 We note that neat HFC-365mfc has never been listed as acceptable for use in spray foam.
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fluorinated, have been introduced during the past several years. Many end users have indicated 

interest in these newer alternatives, often to improve energy efficiency of the foam products 

manufactured with the foam blowing agent. Production volumes for some of these newer 

substitutes are expanding rapidly to keep pace with growing demand. 

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks (e.g., 

flammability, exposure, and toxicity) are discussed below. In addition, a technical support 

document that provides the Federal Register citations concerning data on the SNAP criteria (e.g., 

ODP, GWP, VOC, toxicity, flammability) for acceptable alternatives in the relevant end-uses 

may be found in the docket for this rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015x).

i. Environmental impacts

The HFCs that we are proposing to find unacceptable have GWPs ranging from 1,030 for 

HFC-245fa to 1,430 for HFC-134a. The HFC blends that we are proposing to find unacceptable 

have GWPs that vary depending on the specific composition; the range of GWPs for blends is

740 to 1,030 for blends of HFC-365mfc with at least four percent HFC-245fa, 900 to 1,100 for 

commercial blends of HFC-365mfc with seven to 13 percent HFC-227ea and the remainder 

HFC-365mfc, and 1,330 to approximately 1,500 for Formacel TI. 

Alternatives for all three spray foam applications include CO2, water, Exxsol blowing 

agents, ecomateTM, HFC-152a, HFO-1234ze(E), and trans-1-chloro-3,3,3-trifluoroprop-1-ene.

As shown in Table 18, these alternatives have GWPs ranging from zero to 1,430. In addition, for 

one-component foam sealants only, light saturated HCs are acceptable, with GWPs in the range 
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of three to 15. For high-pressure two-component spray foam only, HFO-1336mzz(Z) is 

acceptable, with a GWP of approximately nine. These GWPs are significantly lower than the 

GWPs of 740 to 1,430 for the HFC and HFC blend substitutes subject to the proposed change of 

status.

Table 18: GWP, ODP, and VOC Status of Foam Blowing Agents in Rigid Polyurethane High-Pressure 

Two-Component Spray Foam, Low-Pressure Two-Component Spray Foam, and Rigid PU OneComponent Foam Sealants1,2

Blowing Agents GWP ODP VOC Proposal

Rigid PU High-Pressure Two-Component Spray Foam

HFC-134a, HFC-245fa, and blends thereof; 

blends of HFC-365mfc with at least four 

percent HFC-245fa, and commercial blends of 

HFC-365mfc with seven to 13 percent HFC227ea and the remainder HFC-365mfc; and 

Formacel® TI

790 – 1,430 0 No Acceptable, 

subject to 

narrowed use 

limits2 or 

unacceptable

CO2; Ecomate; Formic Acid; HFC-152a; 

HFO-1234ze; trans-1-chloro-3,3,3-

trifluoroprop-1-ene (SolsticeTM 1233ze(E)) 1; 

Water

0-124 0-0.00034 No No change

Exxsol Blowing Agents; Formic Acid; HFO–

1336mzz(Z) 

>1-9 0 Yes No change

Rigid PU Low-Pressure Two-Component Spray Foam

HFC-134a, HFC-245fa, and blends thereof; 

blends of HFC-365mfc with at least four 

percent HFC-245fa, and commercial blends of 

HFC-365mfc with seven to 13 percent HFC227ea and the remainder HFC-365mfc; and 

Formacel® TI

794 – 1,430 0 No Acceptable, 

subject to 

narrowed use 

limits2 or 

unacceptable

CO2; Ecomate; HFC-152a; HFO-1234ze; 

trans-1-chloro-3,3,3-trifluoroprop-1-ene; 

Water

0-124 0-0.00034 No No change

Exxsol Blowing Agents; Formic Acid; HFO–

1336mzz(Z) 

>1-9 0 Yes No change

Rigid PU One-Component Foam Sealants

HFC-134a, HFC-245fa, and blends thereof; 

blends of HFC-365mfc with at least four 

percent HFC-245fa, and commercial blends of 

HFC-365mfc with seven to 13 percent HFC227ea and the remainder HFC-365mfc; and 

Formacel® TI

790 – 1,430 0 No Unacceptable

CO2; Ecomate; HFC-152a; HFO-1234ze; 

Methyl Formate; trans-1-chloro-3,3,3-

trifluoroprop-1-ene; Water

0-124 0-0.00034 No No change

Exxsol Blowing Agents; Formic Acid; HFO–

1336mzz(Z) ; Saturated Light Hydrocarbons 

C3-C6

>1-9 0 Yes No change

1The table does not include not-in-kind technologies listed as acceptable for the stated end-uses or additives 

combined with other acceptable blowing agents.
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2 For military or space- and aeronautics-related applications.

All of the HFCs and HFC blends for which we are proposing a change of status to 

unacceptable consist of compounds that are non-ozone-depleting. Of all of the alternatives in the 

three applications affected by the proposed change of status listed above, only trans-1-chloro3,3,3-trifluoroprop-1-ene contains chlorine and thus might have an ODP. Trans-1-chloro-3,3,3-

trifluoroprop-1-ene has an ODP of 0.00024 to 0.00034 and estimates of its maximum potential 

impact on the ozone layer indicate a statistically insignificant impact, comparable to that of other 

substitutes in the same end-use that are considered to be non-ozone-depleting.78,79

All of the HFCs and HFC blends for which we are proposing a change of status to 

unacceptable consist of compounds that are excluded from the definition of VOC under CAA 

regulations (see 40 CFR 51.100(s)) addressing the development of SIPs to attain and maintain 

the NAAQS. With the exception of light saturated HCs (for one-component foam sealants only), 

Exxsol blowing agents (for all spray foam applications) and HFO-1336mzz(Z) (for high-pressure 

two-component spray foam only), the other alternatives contain compounds that are not VOC 

(i.e., water) or are excluded from the definition of VOC under CAA regulations (see 40 CFR 

51.100(s)) addressing the development of SIPs to attain and maintain the NAAQS (e.g., CO2, 

component of ecomate, HFO-1234ze(E), trans-1-chloro-3,3,3,-trifluoroprop-1-ene). Based on 

the small anticipated usage of hydrocarbons and of Exxsol blowing agents, and due to existing 

state regulations affecting aerosol products that may include once-component foam sealants, we 

do not expect these alternative to have a significantly greater impact on local air quality than 

other available alternatives in these applications. The manufacturer of HFO-1336mzz(Z) has 

 

78 Wang D., Olsen S., Wuebbles D. 2011. “Preliminary Report: Analyses of tCFP’s Potential Impact on 

Atmospheric Ozone.” Department of Atmospheric Sciences. University of Illinois, Urbana, IL. September 26, 2011.

79 Patten and Wuebbles, 2010. “Atmospheric Lifetimes and Ozone Depletion Potentials of trans-1-chloro-3,3,3-

trichloropropylene and trans-1,2-dichloroethylene in a three-dimensional model.” Atmos. Chem. Phys., 10, 10867–

10874, 2010.
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petitioned EPA to exempt HFO-1336mzz(Z) from the definition of VOC under those regulations. 

As provided in our decisions listing these substitutes as acceptable, we determined that emissions 

of these alternatives in this end use would not pose a significantly greater risk than that posed by 

foam blowing agents that are not VOCs. 

ii. Flammability

All of the HFCs and HFC blends for which we are proposing a change of status are 

nonflammable. There has been use of blends of HFC-134a and HFC-152a, composition 

unspecified, in the past; those blends may be flammable depending on the exact composition.

HFO-1234ze(E), HFO-1336mzz(Z), and trans-1-chloro-3,3,3-trifluoroprop-1-ene are 

nonflammable blowing agents that have recently been listed as acceptable. The manufacturers of 

the flammable alternatives Exxsol blowing agents and ecomateTM have developed training to 

assist users of high-pressure two-component spray foam users in addressing the flammability 

hazards of these flammable foam blowing agents in this end-use and thereby minimize 

flammability risks.

80,81

Use of flammable blowing agents in spray foam can be an issue. Spray foam is frequently 

used in situ in commercial and residential buildings and it is not practical to make all electrical 

fixtures explosion proof or to add engineered ventilation when applying spray foam in place in 

many circumstances. As mentioned above, flammability is a major issue for high-pressure and 

low-pressure two-component spray foam. Thus, all acceptable substitutes in these applications 

either are nonflammable or else are flammable but information in EPA’s possession indicates 

 

80 UNEP, 2013. Report of the Technology and Economic Assessment Panel, Volume 2: Decision XXIV/7 Task 

Force Report, Additional Information on Alternatives to ODS. September, 2013.

81 UNEP, 2010. Report of the Rigid and Flexible Foams Technical Options Committee, 2010 Assessment. This 

document is accessible at: http://ozone.unep.org/Assessment_Panels/TEAP/Reports/FTOC/FTOC-2010-AssessmentReport.pdf.
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there are measures available to mitigate flammability risk. 

iii. Toxicity

Both the HFC substitutes for which we are proposing a change of status and other 

alternatives have workplace exposure limits, either as regulatory requirements (i.e., OSHA PEL) 

or as a recommendation (e.g., AIHA WEEL, ACGIH TLV or manufacturer recommended 

workplace exposure limits). Proper training, use of PPE, and use of ventilation should be adhered 

to when applying spray foam. As we determined at the time that we listed both the substitutes for 

which we are proposing a status change and the other available alternatives, they can be used 

consistent with the relevant workplace exposure limits in spray foam.

iv. Summary 

EPA is proposing to find HFC-134a, HFC-245fa, and blends thereof; commercial blends 

of HFC-365mfc and HFC-227ea, containing seven to 13 percent HFC-227ea and the remainder 

HFC-365mfc; blends of HFC-365mfc and at least four percent HFC-245fa; and Formacel TI 

unacceptable in spray foam because there are other available or potentially available alternatives 

that reduce risk overall compared to these foam blowing agents. EPA has listed as acceptable 

several alternatives that pose lower overall risk to human health and the environment than the 

blowing agents whose status we are proposing to change to unacceptable. The risks other than 

GWP are not significantly different for the alternatives than for the blowing agents we are 

proposing to list as unacceptable, and the GWPs for the blowing agents we are proposing to list 

as unacceptable are significantly higher and thus pose significantly greater risk. 

d. What narrowed use limits for military or space- and aeronauticsrelated applications is EPA proposing?

EPA is proposing an time-limited exception to the proposed unacceptability 
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determination for HFC and HFC blend foam blowing agents for military or space- and 

aeronautics-related applications when used in low pressure two-component and high pressure 

two-component spray foam. Specifically, EPA is proposing a narrowed use limit that would 

expire on January 1, 2022. As provided in section e below, the vast majority of applications for 

spray foams are anticipated to be able to transition to acceptable alternatives by January 1, 2020, 

for high-pressure two-component spray foam and as of January 1, 2021, for low-pressure twocomponent spray foam. However, for the military, there are several unique performance 

requirements related to weapon systems that require extensive testing and qualification prior to 

qualifying alternatives for HFC-containing foams. In addition, some of the lower-GWP 

alternatives may not be available by 2020 or 2021in certain specialty applications with unique 

military requirements such as undersea; aerospace; and chemical, biological, and radiological 

warfare systems. In the case of space- and aeronautics- related applications, past experience 

indicates that transitions away from the foam blowing agents in current use took several years 

due to the challenging operational environment and the lengthy requalification process 

associated with human-rated space flight systems. 

Users of a restricted agent within the narrowed use limits category must make a 

reasonable effort to ascertain that other substitutes or alternatives are not technically feasible. 

Users are expected to undertake a thorough technical investigation of alternatives to the 

otherwise restricted substitute. Although users are not required to report the results of their 

investigations to EPA, users must document these results, and retain them in their files for the 

purpose of demonstrating compliance. 

Users should include the following additional documentation to demonstrate compliance 

with the narrowed use applications. This information includes descriptions of: 
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• Process or product in which the substitute is needed; 

• Substitutes examined and rejected; 

• Reason for rejection of other alternatives, e.g., performance, technical or safety 

standards; and/or 

• Anticipated date other substitutes will be available and projected time for 

switching.

e. When would the status change? 

Except for the proposed narrow use condition addressed below, EPA is proposing to 

change the listings from acceptable to unacceptable (1) in high-pressure two-component spray 

foam and in one-component foam sealants as of January 1, 2020, and (2) in low-pressure twocomponent spray foam as of January 1, 2021. The change of status would apply to the following 

blowing agents: HFC-134a, HFC-245fa, and blends thereof; blends of HFC-365mfc with at least 

four percent HFC-245fa, and commercial blends of HFC-365mfc with seven to 13 percent HFC227ea and the remainder HFC-365mfc and Formacel TI. The Agency is aware of several 

companies transitioning between now and 2017.

82 However, a transition date of January 1, 2020,

is necessary for high-pressure two-component spray foam to allow sufficient opportunity for

affected entities to redesign to address the technical issues associated with using a different foam 

blowing agent, including the time required for reformulation (about one year), and the time 

required for testing and certification of the final commercial product (one to one and a half 

years). Similarly, a transition date of January 1, 2021, is necessary for low-pressure twocomponent to address the technical issues associated with using a different foam blowing agent. 

 

82 Public and private sector commitments made at the White House Roundtable on October 15, 2015 is available at: 

https://www.whitehouse.gov/the-press-office/2015/10/15/fact-sheet-obama-administration-and-private-sectorleaders-announce.
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Based on information from several companies developing low-pressure two-component spray 

foam products, the process of reformulation has been more difficult than for high-pressure twocomponent spray, because it must have a significantly longer shelf life and requires significant 

reformulation to achieve an acceptable shelf-life. These products are then sold to an end user 

many months after they are formulated. Thus, at least two years are expected to be needed for 

reformulation after issuance of a final rule and another one to one and a half years for testing for 

low-pressure two-component spray foam, resulting in a change of status date of January 1, 2021. 

For high-pressure two-component and low-pressure two-component spray foam a certain 

insulation value may be required to meet building code requirements. Some studies have 

indicated that CO2 may provide less insulation value to an insulation foam, pound for pound, 

than HFCs. Recent information on some of the newer fluorinated foam blowing agents with low 

GWPs, such as HFO-1234ze(E), HFO-1336mzz(Z), and trans-1-chloro-3,3,3-trifluoroprop-1-

ene, indicates these foam blowing agents provide comparable or greater insulation value than 

their HCFC and HFC predecessors. Part of the process of testing and certification for spray foam 

used for building insulation includes verifying sufficient insulation value to meet building code 

requirements. 

January 1, 2020, is the earliest date by which there will be sufficient supply of

alternatives for high-pressure two-component spray foam. Although alternatives are 

commercially available for this end-use (e.g., trans-1-chloro–trifluoroprop-1-ene, ecomateTM), 

there is already demand and concerns about sufficient supply from foam manufacturers in other 

end-uses (80 FR 42870, 42925-42930; July 20, 2015). An additional blowing agent, HFO1336mzz(Z), is expected to become commercially available in 2017,83 providing greater supply 

 

83 Cooling Post, “Chemours to build HFO-1336mzz plant.” November 17, 2015. This document is accessible online 

at: http://www.coolingpost.com/world-news/chemours-to-build-hfo-1336mzz-plant/.
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of alternative foam blowing agent, as well as providing an additional nonflammable, low GWP 

option with good insulation properties that could be especially useful in high-pressure twocomponent spray foam. 

For one-component foam sealants, we expect that the transition process for manufacturers 

of these products should be quicker than for manufacturers of low-pressure two-component spray 

foam because testing is required only for a final formulation in an aerosol can for one-component 

foam sealants, rather than testing both the formulation in separate containers (A- and B-side) and 

ensuring the long-term stability of the final blown foam once the two parts are mixed to blow the 

foam. Also, no certification testing would be required for the one-component foam sealant, 

unlike for high-pressure two-component foam. In Europe, one-component foam sealants have 

already converted away from using HFCs and predominantly use HCs or HFO-1234ze(E), which 

are available substitutes for this end-use under SNAP. Allowing for one year for reformulation 

and one to two years for testing of products and to allow existing stock of one-component foams 

to be purchased and used, we are proposing a change of status date of January 1, 2020, after 

which date, no more one-component foam sealants (cans) could be manufactured using the 

specified HFC blowing agents, but the end user could continue to use cans that had already been 

manufactured. In the July 20, 2015, final rule, EPA took such an approach for aerosol 

propellants, which are used in similar packages for consumer use as well as for manufacturing 

use, and similarly, may be in distribution for a year or more before they are purchased and 

eventually used by the end user. Under the proposed approach, we would limit the applicability 

of the use prohibition on closed cell foam products (discussed in section VI.C.3), so that it would 

not apply to closed cell foam products produced through the use of a one-component spray foam 

manufactured prior to the status change date.
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For low-pressure two-component spray foam, commenters on the August 6, 2014, 

proposal with a change of status date of January 1, 2017, expressed concern about the feasibility 

of alternatives by that date. Specifically, two manufacturers mentioned the heightened challenges 

of shelf-life and stability for a product using HFO-1234ze(E), and suggested change of status 

dates of January 1, 2020 or 2021 (Fomo, 2014; Clayton Corporation, 2014). One manufacturer of 

alternative foam blowing agents suggested that HFC-134a and Formacel® TI should remain 

listed as acceptable for use in low-pressure foam systems until multiple low-GWP alternatives 

with appropriate technical performance qualities would become commercially available (DuPont, 

2014), while another foam blowing agent manufacturer claimed that multiple options are 

available for this use but would require a couple of years to be optimized (Honeywell, 2014). 

Since that time, some of these same companies have provided additional information indicating

that many of the technical challenges with use of HFO-1234ze(E) have been worked through and 

that this is expected to be a viable option given sufficient time to address the technical challenges 

of a transition.

84 To allow sufficient time for manufacturers of low-pressure two-component 

spray foam kits to complete working through the technical challenges of alternatives, as well as 

time for existing kits to be distributed, purchased, and used by the end user, we are proposing, as 

our lead option, a change of status date of January 1, 2021. Alternatively, similar to an approach 

proposed above for one-component foam sealants, EPA proposing as an alternative option a 

change of status date of January 1, 2020, for low-pressure two-component spray foam kits, after 

which date no more kits could be manufactured using the specified HFC blowing agents, but the 

end user could continue to use kits that had already been manufactured. Although low-pressure 

 

84 Fomo, 2015. “The Use of Solstice® Gas Blowing Agent (GBA) in Low Pressure Spray Polyurethane Foam 

Applications”; Cline, Mojee and Bogdan, Mary; October, 2015. Polyurethane Industry Conference 2015.

Clayton Corporation, 2015. Clayton Corporation Meeting with EPA Stratospheric Protection Division, December 8, 

2015.
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two-part spray foam kits would typically be used by a professional (e.g., home improvement 

contractor) rather than by a consumer, there are similar issues with an extended chain 

manufacture, distribution, and use for these kits that are more similar to aerosol canisters and 

one-component spray foam sealants than to high-pressure two-component spray foam or other 

foam blowing end-uses (e.g., rigid PU appliance, rigid PU commercial refrigeration and 

sandwich panel). Under this alternative proposal, as under the proposed approach for onecomponent spray foams, we would limit the applicability of the use prohibition on closed cell 

foam products (discussed in section VI.C.3) so that it would not apply to closed cell foam 

products produced through the use of a low-pressure two-component spray foam kit

manufactured prior to the status change date. 

f. What is the relationship between this SNAP rule and other federal 

rules? 

Over the past several years, to address potential exposure to workers and consumers, the 

Federal Partnership and each of its member agencies, including EPA, CPSC, OSHA, and NIOSH 

have worked to reduce exposure to various chemicals emitted from spray foam. For example, 

EPA and its federal partners have continued to work with industry to develop best practices for 

application of spray foam, and EPA’s Office of Research and Development has been developing 

methods to measure emissions of chemicals from spray foam as part of the ASTM Indoor Air 

Subcommittee D.22.05 on Spray Polyurethane Foam Insulation. The list of proposed and final 

standards represents the issues raised by the committee and the range of compounds of interest 

includes isocyanates, blowing agents, amine catalysts, flame retardants, and aldehydes (Sleasman 

and Biggs, 2015). In addition to federal rules and guidance applying to the spray foam industry, 

insulation foam used in construction (e.g., high-pressure two-component spray foam) must meet 
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insulation value requirements in state and local building codes, as discussed above in section 

VI.C.1.d.

g. On which topics is EPA specifically requesting comment? 

EPA requests comments on all aspects of this proposed decision to change the listings of 

certain foam blowing agents in the three for spray foam end-uses. In particular, EPA is interested 

in whether there are specific applications for one-component spray foam sealants, low-pressure

two-component, and high-pressure two-component spray foam for which there are no 

alternatives available with lower overall risks to human health and the environment than the 

substitutes for which we are proposing a change of status: HFC-134a, HFC-245fa, and blends 

thereof; blends of HFC-365mfc with at least four percent HFC-245fa, and commercial blends of 

HFC-365mfc with seven to 13 percent HFC-227ea and the remainder HFC-365mfc; and 

Formacel TI, for reasons of fire safety or technical feasibility. EPA requests comment on 

whether the proposed change of status dates for one-component spray foam sealants, low 

pressure two-component, and high pressure two-component spray foam are appropriate in light 

of technical challenges and the supply of other alternatives. Where commenters indicate more 

time is needed due to supply or technical challenges, EPA is interested in information concerning 

what is limiting supply of substitutes and on the specific technical steps and time needed for each 

step in order to transition to alternatives. Additionally, EPA requests comment on whether the

change of status date for one component foam sealants and low-pressure two-component spray 

foam should be based upon the date the product may no longer be used or whether it should be 

based upon a date of manufacture of the product with no restriction on the use of products sold 

prior to the change of status date.

2. Proposed change of status for methylene chloride in flexible PU, integral skin 
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PU, and polyolefin foams

As provided in the following table, EPA is proposing to change the status methylene 

chloride from acceptable to unacceptable for multiple foam blowing end-uses.

Table 19. Proposed Change of Status Decisions for Flexible PU, Integral Skin PU, and Polyolefin Foam 

Blowing Agents

End-use Substitutes Proposed Decision

Flexible PU Methylene chloride. Unacceptable as of 30 days after publication of 

a final rule.

Integral Skin PU Methylene chloride. Unacceptable as of January 1, January 1, 2017.

Polyolefin Methylene chloride. Unacceptable as of January 1, 2020.

a. What are the affected end-uses?

EPA is proposing to change the status of methylene chloride from acceptable to 

unacceptable when used as a blowing agent in the production of flexible PU foam, integral skin 

PU foam, and polyolefin foam. Flexible PU includes foam in furniture, bedding, chair cushions, 

and shoe soles. Integral skin PU includes car steering wheels, dashboards, and shoe soles.

Polyolefin includes foam sheets and tubes.

Methylene chloride, also known as dichloromethane, has the chemical formula CH2Cl2

and the CAS Reg. No. 75-09-2. EPA initially listed this substitute as acceptable for flexible PU 

foam and integral skin PU foam acceptable in the initial SNAP rule (79 FR 13044; March 18, 

1994), and then listed it as acceptable for polyolefin foam on August 26, 1994 (79 FR 44240).

b. How does methylene chloride compare to other blowing agents for 

these end-uses with respect to SNAP criteria?

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks (e.g., 

flammability, exposure, and toxicity) are discussed below. In addition, a technical support 
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document that provides the Federal Register citations concerning data on the SNAP criteria (e.g., 

ODP, GWP, VOC, toxicity, flammability) for these alternatives may be found in the docket for 

this rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015x).

i. Flexible PU

(a) Environmental impacts

Methylene chloride contains chlorine and thus could have an ODP. We are unaware of a 

calculated ODP for methylene chloride in the peer-reviewed literature, but it has historically 

been considered negligibly small.

85 Recent research indicates that emissions of methylene 

chloride from multiple industrial sources have been increasing and could have a detectible 

impact on the ozone layer,86 despite the historical assumption of negligible ODP. For flexible 

polyurethane, available substitutes include acetone, Exxsol blowing agents, CO2, ecomateTM, 

HFC-152a, HFO-1336mzz(Z), methylal, saturated light HCs (C3-C6), trans-1-chloro-3,3,3-

trifluoroprop-1-ene, and water. Of the other available alternatives for flexible PU, only trans-1-

chloro-3,3,3-trifluoroprop-1ene contains chlorine and thus might have an ODP. Trans-1-chloro3,3,3-trifluoroprop-1-ene has an ODP of 0.00024 to 0.00034 and estimates of its maximum 

potential impact on the ozone layer indicate a statistically insignificant impact, comparable to 

that of other substitutes in the same end-use that are considered to be non-ozone-depleting.87,88

 

85 INCHEM, 1996. International Programme on Chemical Safety. Environmental Health Criteria 164. Methylene 

chloride, second edition. World Health Organization, 1996. This document is accessible online at 

http://www.inchem.org/documents/ehc/ehc/ehc164.htm.

86 Hossaini, et al., 2015. R. Hossaini, M. P. Chipperfield, S. A. Montzka, A. Rap, S. Dhomse, W. Feng. Efficiency 

of short-lived halogens at influencing climate through depletion of stratospheric ozone. Nature Geoscience, 2015; 

This document is accessible online at http://DOI: 10.1038/ngeo2363 and is reported in "New ozone-destroying 

gases on the rise; not controlled by treaty." ScienceDaily. 16 February 2015. This document is accessible online at 

http://www.sciencedaily.com/releases/2015/02/150216130241.htm.

87 Wang D., Olsen S., Wuebbles D. 2011. “Preliminary Report: Analyses of tCFP’s Potential Impact on 

Atmospheric Ozone.” Department of Atmospheric Sciences. University of Illinois, Urbana, IL. September 26, 2011.

88 Patten and Wuebbles, 2010. “Atmospheric Lifetimes and Ozone Depletion Potentials of trans-1-chloro-3,3,3-

trichloropropylene and trans-1,2-dichloroethylene in a three-dimensional model.” Atmos. Chem. Phys., 10, 10867–

10874, 2010.
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Methylene chloride has a GWP of approximately nine. As shown in Table 20, other 

acceptable alternatives have GWPs that are comparable or lower than methylene chloride’s GWP 

of nine except for HFC-152a, which has a GWP of 124.

Table 20: GWP, ODP, and VOC Status of Methylene Chloride Compared to Other Foam Blowing Agents 

in Flexible PU Foams, Integral Skin PU Foams, and Polyolefin Foams1

Blowing Agents GWP ODP VOC Proposal

Methylene Chloride 9 unknown No Proposed 

unacceptable

Flexible PU Foams

Acetone; CO2; Ecomate; HFC-152a; Methylal; 

trans -1-chloro-3,3,3-trifluoroprop-1-ene; 

Water

0-124 0-0.00034 No No change

AB Technology; Exxsol Blowing Agents; 

HFO–1336mzz(Z); Methylal; Saturated Light 

Hydrocarbons C3-C61

>1-9 0 Yes No change

Integral Skin PU Foams

Acetone; CO2; Ecomate; Formic Acid; HFO1234ze; HFO–1336mzz(Z) HFC-152a; Methyl 

Formate; trans -1-chloro-3,3,3-trifluoroprop-1-

ene 1; Water

0-124 0-0.00034 No No change

AB Technology; Exxsol Blowing Agents; 

Formic Acid; HFO–1336mzz(Z); Methylal; 

Saturated Light Hydrocarbons C3-C6 

>1-9 0 Yes No change

Polyolefin Foams

CO2; Ecomate; HFO-1234ze; HFC-152a; 

Water

0-124 0 No No change

Exxsol Blowing Agents; Formic Acid; HFO1234ze; HFC-152a/Saturated Light 

Hydrocarbon Blends; Saturated Light 

Hydrocarbons C3-C6

0-120 0 Yes No change

1The table does not include not-in-kind technologies listed as acceptable for the stated end-uses or additives 

combined with other acceptable blowing agents.

Methylene chloride is excluded from the definition of VOC under CAA regulations (see 

40 CFR 51.100(s)) addressing the development of SIPs to attain and maintain the NAAQS. With 

the exception of HCs, Exxsol blowing agents, HFO-1336mzz(Z), and methylal, the other

alternatives contain compounds that are excluded from the definition of VOC. The manufacturer 

of HFO-1336mzz(Z) has petitioned EPA to exempt HFO-1336mzz(Z) from the definition of 

VOC under those regulations. As provided in our decisions listing these substitutes as 

acceptable, we determined that emissions of these alternatives in this end use would not pose a 
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significantly greater risk than that posed by foam blowing agents that are not VOCs. 

(b) Flammability

Methylene chloride exhibits no flash point under standard testing conditions and thus is 

considered nonflammable, although it does exhibit lower and upper flammability limits of 13 

percent and 23 percent, respectively. Of the various alternatives, ecomateTM, Exxsol blowing 

agents, HFC-152a, HCs, and methylal are flammable, and the others are nonflammable. The 

flammability hazards of the flammable compounds in this end-use can be adequately addressed 

in the process of meeting OSHA regulations and fire codes.

(c) Toxicity

Health effects of concern with methylene chloride include cancer, liver, and kidney 

effects (longer-term exposure) and neurotoxic effects (acute exposure), in addition to irritation to 

the skin, eyes, and respiratory tract. Other alternatives for this end-use have potential health 

effects such as impacts on body weight, mononuclear infiltration of heart tissue, neurotoxic 

effects, and irritation to the skin, eyes, and respiratory tract; no other alternatives in this end-use 

have evidence of cancer as a health effect. Toxicity is not a significant concern in the workplace 

for methylene chloride or for the other available alternatives because they may be used for 

blowing flexible PU foam consistent with required or recommended workplace exposure limits. 

Workplace exposure limits for the other available alternatives range from 100 ppm to 5,000 ppm. 

Methylene chloride’s workplace exposure limits include a PEL of 25 pm (8-hr TWA) and 125 

ppm over a 15-minute period. Methylene chloride is regulated for its toxicity as a hazardous air 

pollutant under the CAA and potentially as a U-listed hazardous waste under RCRA (40 CFR 

261.33). None of the other alternative blowing agents are regulated as hazardous air pollutants or 

as U-listed hazardous wastes.
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In the initial SNAP rulemaking, EPA listed methylene chloride as acceptable in this enduse, citing the presence of the OSHA regulations as sufficient to address workplace risk. 

Information regarding general population risk was not available for methylene chloride or for 

any of the other alternatives at the time EPA listed them as acceptable for this end use.

Since EPA’s initial listing decision for methylene chloride in flexible PU foam, the 

Agency has separately issued a health-based residual risk standard under section 112 of the CAA 

for flexible PU foam production. (National Emission Standards for Hazardous Air Pollutants 

Residual Risk and Technology Review for Flexible Polyurethane Foam Production, (79 FR 

48073; August 15, 2014). In that regulation, EPA examined the risk to the general population 

and determined to prohibit the use of HAP-based blowing products, including methylene 

chloride, as auxiliary blowing agents in flexible PU slabstock foam production operations at 

major sources. Because EPA has separately determined in setting a risk-based standard that 

methylene chloride cannot be used as a blowing agent by major sources for production of

flexible PU slabstock foam, we are proposing to change the status of methylene chloride in this 

end-use on the basis that it poses significantly more risk than other available alternatives.

ii. Integral skin PU

(a) Environmental impacts

Methylene chloride contains chlorine and thus could have an ODP. We are unaware of a 

calculated ODP for methylene chloride in the peer-reviewed literature, but it has historically

been considered negligibly small.

89 Recent research indicates that emissions of methylene 

chloride from multiple industrial sources have been increasing and could have a detectible 

 

89 INCHEM, 1996.
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impact on the ozone layer,90 despite the historical assumption of negligible ODP. For integral 

skin PU, available alternatives include acetone, CO2, ecomateTM, Exxsol blowing agents, formic 

acid, HFC-152a, HFO-1234ze(E), HFO-1336mzz(Z), methylal, methyl formate, saturated light

HCs (C3-C6), trans-1-chloro-3,3,3-trifluoroprop-1-ene, and water. Of the other available 

alternatives for flexible PU, only trans-1-chloro-3,3,3-trifluoroprop-1ene contains chlorine and 

thus might have an ODP. Trans-1-chloro-3,3,3-trifluoroprop-1-ene has an ODP of 0.00024 to 

0.00034 and estimates of its maximum potential impact on the ozone layer indicate a statistically 

insignificant impact, comparable to that of other substitutes in the same end-use that are 

considered to be non-ozone-depleting.91,92

Methylene chloride has a GWP of approximately nine. As shown in Table 20, other 

acceptable alternatives have GWPs that are comparable or lower than methylene chloride’s GWP 

of nine except for HFC-152a, which has a GWP of 124.

Methylene chloride is excluded from the definition of VOC under CAA regulations (see 

40 CFR 51.100(s)) addressing the development of SIPs to attain and maintain the NAAQS. With 

the exception of HCs, Exxsol blowing agents, formic acid, HFO-1336mzz(Z), and methylal, the

other alternatives contain compounds that are exempt from the definition of VOC. The 

manufacturer of HFO-1336mzz(Z) has petitioned EPA to exempt HFO-1336mzz(Z) from the 

definition of VOC under those regulations. As provided in our decisions listing these alternatives 

 

90 Hossaini, et al., 2015. R. Hossaini, M. P. Chipperfield, S. A. Montzka, A. Rap, S. Dhomse, W. Feng. Efficiency of 

short-lived halogens at influencing climate through depletion of stratospheric ozone. Nature Geoscience, 2015. This 

document is accessible online at http://DOI: 10.1038/ngeo2363 and is reported in "New ozone-destroying gases on 

the rise; not controlled by treaty." ScienceDaily. 16 February 2015. This document is accessible online at

http://www.sciencedaily.com/releases/2015/02/150216130241.htm.

91 Wang D., Olsen S., Wuebbles D. 2011. “Preliminary Report: Analyses of tCFP’s Potential Impact on 

Atmospheric Ozone.” Department of Atmospheric Sciences. University of Illinois, Urbana, IL. September 26, 2011.

92 Patten and Wuebbles, 2010. “Atmospheric Lifetimes and Ozone Depletion Potentials of trans-1-chloro-3,3,3-

trichloropropylene and trans-1,2-dichloroethylene in a three-dimensional model.” Atmos. Chem. Phys., 10, 10867–

10874, 2010.
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as acceptable, we determined that emissions of these alternatives in this end-use would not pose 

a significantly greater risk than that posed by foam blowing agents that are not VOCs. 

(b) Flammability

Methylene chloride exhibits no flash point under standard testing conditions and thus is 

considered nonflammable, although it does exhibit lower and upper flammability limits of 13 

percent and 23 percent, respectively. Of the various alternatives, acetone, methyl formate, 

ecomateTM, Exxsol blowing agents, HFC-152a, HCs, and methylal are flammable, and CO2, 

formic acid, HFO-1234ze(E), HFO-1336mzz(Z), trans-1-chloro-3,3,3-trifluoroprop-1-ene, and 

water are nonflammable. The flammability hazards of the flammable compounds in this end-use 

can be adequately addressed in the process of meeting OSHA regulations and fire codes.

(c) Toxicity 

Health effects of concern with methylene chloride include cancer, liver, and kidney 

effects (longer-term exposure) and neurotoxic effects (acute exposure), in addition to irritation to 

the skin, eyes, and respiratory tract. Other alternatives for this end-use have potential health 

effects such as impacts on body weight, mononuclear infiltration of heart tissue, neurotoxic 

effects, and irritation to the skin, eyes, and respiratory tract; no other alternatives in this end-use 

have evidence of cancer as a health effect. Toxicity is not a significant concern in the workplace 

for methylene chloride or for the other available alternatives because they may be used for 

blowing integral skin PU consistent with required or recommended workplace exposure limits. 

Workplace exposure limits for the other available alternatives range from 100 ppm to 5,000 ppm. 

Methylene chloride’s workplace exposure limits include a PEL of 25 pm (8-hr TWA) and 125 

ppm over a 15-minute period. Methylene chloride is regulated for its toxicity as a hazardous air 

pollutant under the CAA and potentially as a U-listed hazardous waste under RCRA (40 CFR 
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261.33). None of the other alternative blowing agents are regulated as hazardous air pollutants or 

as U-listed hazardous wastes.

Methylene chloride is the only acceptable alternative in this end-use that is a carcinogen. 

On this basis, we are proposing that methylene chloride poses significantly greater toxicity risks 

than the other alternatives available for this end use. The risk posed by methylene chloride and 

the other alternatives based on the other SNAP review criteria are not significantly different.

Because of the significantly greater toxicity risk posed by methylene chloride, we believe it 

poses significantly greater overall risk than other available substitutes and we are proposing to 

change the status to unacceptable.

iii. Polyolefin foam

(a) Environmental impacts

Methylene chloride contains chlorine and thus could have an ODP. We are unaware of a 

calculated ODP for methylene chloride in the peer-reviewed literature, but it has historically

been considered negligibly small.

93 Recent research indicates that emissions of methylene 

chloride from multiple industrial sources have been increasing and could have a detectible 

impact on the ozone layer,94 despite the historical assumption of negligible ODP. In polyolefin 

foam, available alternatives include CO2, ecomateTM, Exxsol blowing agents, methyl formate, 

HFC-152a, blends of HFC-152a and saturated light HCs, HFO-1234ze(E), saturated light HCs 

(C3-C6), trans-1-chloro-3,3,3-trifluoroprop-1-ene, and water. Of the other available alternatives 

 

93 INCHEM, 1996.

94 Hossaini, et al., 2015. R. Hossaini, M. P. Chipperfield, S. A. Montzka, A. Rap, S. Dhomse, W. Feng. Efficiency 

of short-lived halogens at influencing climate through depletion of stratospheric ozone. Nature Geoscience, 2015; 

This document is accessible online at http://DOI: 10.1038/ngeo2363 and is reported in "New ozone-destroying 

gases on the rise; not controlled by treaty." ScienceDaily. 16 February 2015. This document is accessible online at 

http://www.sciencedaily.com/releases/2015/02/150216130241.htm.
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for flexible PU, only trans-1-chloro-3,3,3-trifluoroprop-1ene contains chlorine and thus might 

have an ODP. Trans-1-chloro-3,3,3-trifluoroprop-1-ene has an ODP of 0.00024 to 0.00034 and 

estimates of its maximum potential impact on the ozone layer indicate a statistically insignificant 

impact, comparable to that of other substitutes in the same end-use that are considered to be nonozone-depleting.95,96

Methylene chloride has a GWP of approximately nine. As shown in Table 20,The other 

acceptable substitutes have GWPs that are comparable or lower than methylene chloride’s GWP 

of nine except for HFC-152a, which has a GWP of 124.

Methylene chloride is excluded from the definition of VOC under CAA regulations (see 

40 CFR 51.100(s)) addressing the development of SIPs to attain and maintain the NAAQS. With 

the exception of HCs, HC blends, and Exxsol blowing agents, the other alternatives contain 

compounds that are exempted from the definition of VOC. The manufacturer of HFO1336mzz(Z) has petitioned EPA to exempt HFO-1336mzz(Z) from the definition of VOC under 

those regulations. As provided in our decisions listing these alternatives as acceptable, we 

determined that emissions of these alternatives in this end-use would not pose a significantly 

greater risk than that posed by foam blowing agents that are not VOCs.

(b) Flammability

Methylene chloride exhibits no flash point under standard testing conditions and thus is 

considered nonflammable, although it does exhibit lower and upper flammability limits of 13 

percent and 23 percent, respectively. Of the various alternatives, blends of HFC-152a and HCs, 

 

95 Wang D., Olsen S., Wuebbles D. 2011. “Preliminary Report: Analyses of tCFP’s Potential Impact on 

Atmospheric Ozone.” Department of Atmospheric Sciences. University of Illinois, Urbana, IL. September 26, 2011.

96 Patten and Wuebbles, 2010. “Atmospheric Lifetimes and Ozone Depletion Potentials of trans-1-chloro-3,3,3-

trichloropropylene and trans-1,2-dichloroethylene in a three-dimensional model.” Atmos. Chem. Phys., 10, 10867–

10874, 2010.
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ecomateTM, Exxsol blowing agents, HFC-152a, HCs, and methyl formate are flammable, and 

CO2, HFO-1234ze(E), trans-1-chloro-3,3,3-trifluoroprop-1-ene, and water are nonflammable. 

The flammability hazards of the flammable compounds in this end-use can be adequately 

addressed in the process of meeting OSHA regulations and fire codes. 

(c) Toxicity

Health effects of concern with methylene chloride include cancer, liver, and kidney 

effects (longer-term exposure) and neurotoxic effects (acute exposure), in addition to irritation to 

the skin, eyes, and respiratory tract. Other alternatives for this end-use have potential health 

effects such as impacts on body weight, mononuclear infiltration of heart tissue, neurotoxic 

effects, and irritation to the skin, eyes, and respiratory tract; no other alternatives in this end-use 

have evidence of cancer as a health effect. Toxicity is not a significant concern in the workplace 

for methylene chloride or for the other available alternatives because they may be used for 

blowing polyolefin foam consistent with required or recommended workplace exposure limits. 

Workplace exposure limits for the other available alternatives range from 100 ppm to 5,000 ppm. 

Methylene chloride’s workplace exposure limits include a PEL of 25 pm (8-hr TWA) and 125 

ppm over a 15-minute period. Methylene chloride is regulated for its toxicity as a hazardous air 

pollutant under the CAA and potentially as a U-listed hazardous waste under RCRA (40 CFR 

261.33). None of the other alternative blowing agents are regulated as hazardous air pollutants or 

as U-listed hazardous wastes.

Methylene chloride is the only acceptable alternative in this end-use that is a carcinogen. 

On this basis, we are proposing that methylene chloride poses significantly greater toxicity risks 

than the other alternatives available for this end use. The risk posed by methylene chloride and 

the other alternatives based on the other SNAP review criteria are not significantly different.
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Because of the significantly greater toxicity risk posed by methylene chloride, we believe it 

poses significantly greater overall risk than other available substitutes and we are proposing to 

change the status to unacceptable.

c. When would the status change?

EPA proposes to change the status of methylene chloride in flexible PU foam as of 30 

days after a final rule is published in the Federal Register. Because this blowing agent has 

already been prohibited in flexible PU foam manufacturing operations for major sources by 

EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) Residual Risk and 

Technology Review for Flexible Polyurethane Foam Production (79 FR 48073; August 15, 

2014), we expect that most businesses have already transitioned away from this substitute in that 

end-use. This rule does not apply to area sources.

For integral skin PU foam and polyolefin, we propose the respective change of status 

dates to be January 1, 2017, and January 1, 2020. These dates are consistent with the change of 

status dates we previously established for certain HFCs in these end-uses (80 FR 42870; July 20, 

2015). These dates were established considering factors such as the supply of alternatives, time 

required for testing of alternatives, and time required to prepare facilities for use of flammable 

foam blowing agents. By proposing to change the status of methylene chloride from acceptable 

to unacceptable, we expect that end-users will consider blowing agents other than methylene 

chloride as they plan their transition away from HFCs in these end-uses.

d. What is the relationship between this SNAP rule and other federal 

rules?

In a recent rulemaking, National Emission Standards for Hazardous Air Pollutants 

Residual Risk and Technology Review for Flexible Polyurethane Foam Production, EPA 
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prohibits the use of HAP, including methylene chloride, as auxiliary blowing agents in slabstock 

flexible PU foam production operations at major sources as of November 13, 2014 (79 FR 

48073; August 15, 2014). This action is consistent with that previously issued prohibition.

e. On which topics is EPA specifically requesting comment? 

EPA requests comment on all aspects of this proposal. In particular, we request comment 

on the proposed dates for a change of status for methylene chloride (30 days after publication of 

a final rule for flexible PU foam, January 1, 2017, for integral skin PU foam, and January 1, 

2020, for polyolefin foam). We request comments on, the extent to which methylene chloride is

currently being used in these end-uses in integral skin PU, in polyolefin, or by area sources that 

manufacture flexible PU foam and the technical challenges that exist for transitioning from 

methylene chloride to other available alternatives.

3. Proposed application of listings to foam products

EPA is proposing to apply the unacceptability determinations in this action for foam 

blowing agents to closed cell foam products and products containing closed cell foam. In 

addition, EPA is proposing to apply all listings for foam blowing agents codified in the 

appendices to 40 CFR part 82 subpart G to such products. This would mean that closed cell foam 

products and products containing closed cell foams manufactured abroad and imported could not 

be used in the United States if the foam blowing agent was listed as unacceptable. 

a. What are the affected end-uses?

The foam sector includes both closed cell and open cell foams. Closed cell foams are 

specifically designed to retain the foam blowing agent in the cells; in insulation foam products, 

the foam blowing agent continues to perform a function in providing thermal insulation, once the 

foam has already been blown. With open cell foams, the foam blowing agent completes its 
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function once the foam is blown; almost all of the foam blowing agent escapes from the open 

cells prior to import, and any vestigial amounts remaining do not perform a function.

Foam blowing end-uses that contain closed-cell foams include rigid PU spray foam (all 

three applications described in section VI.C.1); rigid PU commercial refrigeration and sandwich 

panels; rigid PU marine flotation foam; rigid PU appliance foam; rigid PU slabstock and other; 

rigid PU and polyisocyanurate laminated boardstock; polystyrene: extruded boardstock and 

billet; polystyrene: extruded sheet; polyolefin; and phenolic insulation board and bunstock. Foam 

blowing end-uses containing open cell foams include flexible PU and integral skin PU. Open cell 

phenolic, and some other open cell foams also exist within the SNAP foam blowing end-uses 

that include closed cell foams. Integral skin foam may include a rigid surface with an interior 

flexible core.

b. How would this proposal change the treatment of foam products 

under SNAP?

Currently, an unacceptable foam blowing agent may not be used to manufacture products 

in the United States, whether for domestic use or for export. However, products made abroad 

with unacceptable foam blowing agents may be imported and used in the United States. This is 

because EPA has historically interpreted the use prohibitions for this sector to apply to blowing 

foam with the foam blowing agent and not to the use of products made with foam. For example, 

commercial refrigerators containing appliance foam blown with an unacceptable blowing agent 

may be imported into and used in the United States, though commercial refrigerators 

manufactured in the United States may not be manufactured with foam blown with that same 

agent. 

If this proposal were to be finalized as proposed, use of closed cell foam products (e.g., 
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manufactured rigid PU insulation or XPS boardstock) or products that contain closed cell foam 

(e.g., household and commercial appliances, boats) manufactured with an unacceptable foam 

blowing agent on or after the specified date would be subject to the use prohibitions under 

SNAP. This would include, but would not be limited to, incorporating a closed cell foam blown 

with an unacceptable blowing agent into a subsequent product and installing a closed cell foam 

product or product containing closed cell foam. Products manufactured prior to the specified date 

would not be subject to the use prohibitions. In addition, under this proposal the use prohibitions 

would not apply to consumers once a product had been installed.

c. How do other stratospheric ozone protection requirements apply to 

foam products?

Several provisions of CAA Title VI and EPA’s implementing regulations are relevant to 

HCFC foam products. Under regulations implementing CAA section 611, EPA requires labeling 

of products that contain an ODS and those that are manufactured with an ODS. EPA determined

that open cell foams blown with an ODS must be labeled as a product manufactured with an 

ODS. (58 FR 8136, 8143-8150, February 11, 1993; 79 FR 64253, 64258-64259, October 28, 

2014) In contrast, closed cell foam products blown with an ODS must be labeled as a product 

containing an ODS for labeling purposes. (58 FR 8136, 8150-8151, February 11, 1993; 79 FR 

64253, 64258-64259, October 28, 2014) As of January 1, 2015, any product containing a closed 

cell foam blown with an HCFC must be labeled as a product containing an ozone-depleting 

substance under the regulations at 40 CFR 82.106 implementing CAA section 611.

Section 610 restricts sale and distribution and offers of sale and distribution of certain 

products containing or manufactured with CFCs and HCFCs.97 Section 610(d)(3)(A) explicitly 

 

97 Section 610 does not address products containing or manufactured with substitutes.
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provides an exception for foam insulation products containing HCFCs. EPA has implemented 

this restriction and the exception for HCFC foam insulation products through its Nonessential 

Products Ban regulations codified at 40 CFR part 82 subpart C. These regulations define “foam 

insulation product” as: 

...a product containing or consisting of the following types of foam: 

(1) Closed cell rigid polyurethane foam; 

(2) Closed cell rigid polystyrene boardstock foam; 

(3) Closed cell rigid phenolic foam; and 

(4) Closed cell rigid polyethylene foam when such foam is suitable in shape, thickness 

and design to be used as a product that provides thermal insulation around pipes used in 

heating, plumbing, refrigeration, or industrial process systems. 

CAA section 605(a) prohibits the introduction into interstate commerce or use of any 

class II substance effective January 1, 2015, unless such substance—

(1) has been used, recovered, and recycled;

(2) is used and entirely consumed (except for trace quantities) in the production of other 

chemicals;

(3) is used as a refrigerant in appliances manufactured prior to January 1, 2020; or

(4) is listed as acceptable for use as a fire suppression agent for nonresidential 

applications in accordance with section 612(c).

The section 605(a) implementing regulations codified at 40 CFR part 82, subpart A 

restrict the use of virgin HCFCs to air conditioning, refrigeration, and fire suppression 

applications, with minor exceptions. Thus, while the Nonessential Products Ban does not apply

to HCFC insulating foams, section 605(a) and its implementing regulations prohibit the use of 
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HCFCs for blowing foam in the United States. The combined effect of the Nonessential Products 

Ban and the section 605(a) implementing regulations is that HCFC foam insulation products may 

be imported, sold, and distributed in the United States but cannot be manufactured in the United 

States.

In the preamble to a July 11, 2000, SNAP proposed rule, EPA reviewed its authority 

under CAA section 610 and noted that HCFC insulating foams were exempt from regulation 

under that section of the statute. EPA stated that “Title VI of the Act thus does not provide EPA 

with the authority to prevent imports of products containing those foams” (65 FR 42653, 42656). 

EPA did not, however, base this statement on a full examination of the various authorities under 

Title VI. In taking final action on that proposal, EPA noted that while under section 610 it could 

not ban the sale of HCFC foam insulation products, section 610 “does not address EPA’s ability 

to regulate the transition from use of ODS to alternatives in the manufacturing of products such 

as foam.” EPA further noted: “Section 612 can restrict the use of a substitute in a product 

regardless of whether or not that product is considered nonessential under Section 610” (69 FR 

58275, September 30, 2004).

d. How is EPA reexamining treatment of foam products under SNAP?

In the August 6, 2014, NPRM (79 FR 46126; 46154), EPA proposed to consider use of a 

foam blowing agent to include use of closed cell foam products or products containing closed 

cell foam. In response to that proposal, some commenters supported applying the unacceptability 

determinations to the use of closed cell foam products or products containing closed cell foam 

with unacceptable foam blowing agents, on the basis that it would maintain a “level playing 

field” for domestically manufactured products made with lower-GWP foam blowing agents that 

were going to compete with imported products. Some commenters also supported extending such 
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a prohibition to open cell foams, stating that there was still some foam blowing agent left in the 

foam and citing the negative impacts of allowing cheaper imported products containing 

unacceptable foam blowing agents.

Other commenters opposed applying unacceptability determinations to anything other 

than the act of blowing foam in the United States. These commenters stated that this would be a 

significant departure from the Agency’s previous interpretation and suggested that EPA needed 

to explain the basis for such a change. For example, one commenter stated that “without any 

legal rationale, EPA has proposed to reverse its long-standing interpretation of the Clean Air Act 

with respect to the import of products containing HCFC-141b as a foam-blowing agent.” In 

addition, some commenters pointed out that the proposal only allowed 60 days before this 

change in interpretation would apply to HCFC-141b, which they viewed as insufficient time to 

adjust. EPA did not take final action in the July 20, 2015, final rule (80 FR 42870) but instead 

elected to continue assessing the merits of the change. 

In this action, EPA is again proposing to apply listings and prohibitions for foam blowing 

agents to use of closed cell foam products and products containing closed cell foam. To the 

extent EPA’s earlier statements regarding Title VI reflect an interpretation that the agency could 

not address imported closed cell foam products or products containing closed cell foam under 

any provision of Title VI, EPA is proposing to change that interpretation.

Section 612 requires EPA to promulgate regulations prohibiting the replacement of ODS 

with certain substitutes and to publish lists of the substitutes prohibited for specific uses as well 

as those found acceptable for those uses. EPA’s implementing regulations at 40 CFR 82.174 

state, in part: “No person may use a substitute after the effective date of any rulemaking adding 

such substitute to the list of unacceptable substitutes” (40 CFR 82.174(d)). The SNAP 
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regulations define “use” of a substitute as including, but not being limited to, “use in a 

manufacturing process or product, in consumption by the end-user, or in intermediate uses, such 

as formulation or packaging for other subsequent uses.” (§82.172) 

EPA currently treats use of foam blowing agents in the manufacture of a foam product as 

covered by the use prohibition. In this action, EPA is proposing to apply the use prohibition more

broadly in the case of closed cell foam products. With respect to other sectors, EPA has treated

use of a product manufactured with or containing a substance as constituting use of the substance 

where the product holds some amount of the substance, the substance continues to perform its 

intended function, and the substance is likely to be emitted in the United States either during use 

of the product or at the time of its disposal. For example, an aerosol can is manufactured to 

contain a substance as a propellant, and then that propellant leaks, is released by the end user 

during use of the aerosol can’s contents, or is emitted at the time of disposal if it has not already 

been used up. In the July 20, 2015 SNAP rule, in changing the status of certain substances with 

respect to aerosols, EPA prohibited use of aerosol products containing those substances, while 

stating that products manufactured prior to the change of status date could still be used after that 

date (80 FR 42883). By analogy, we are proposing that “use” of a foam blowing agent includes

use of a closed cell foam product manufactured after the specified date. For such products, the 

foam blowing agent remains in the cells and continues to be used for the purpose of insulation 

during the lifetime of the product. Furthermore, emissions of the foam blowing agent occur at the 

time of disposal of the closed cell foam product. Thus, emissions from a closed cell product used 

in the United States can be expected to occur in the United States regardless of whether the 

product was manufactured domestically or abroad. This proposed action would ensure that

products manufactured abroad and subsequently imported would be treated the same as products 
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manufactured domestically. 

EPA does not propose to treat use of an open cell foam product as constituting use of the 

foam blowing agent. The foam blowing agent in an open cell foam product does not continue to 

perform its intended function during the lifetime of the product. Except for insignificant amounts 

remaining in the cells, emissions of the foam blowing agent would occur at the time and place of 

manufacture. Therefore, we are proposing to differentiate between closed cell and open cell foam 

products for this purpose. This would be consistent with the different treatment of closed and 

open cell foam products under the section 611 labeling regulations.

e. When would use of closed cell foam products with unacceptable 

blowing agents be unacceptable?

For changes of status proposed in this rule (section VI.C.1 and VI.C.2), we are proposing 

that the unacceptability determination would apply to use of closed cell foam products and 

products that contain closed cell foam where the products are manufactured on or after the 

change of status date. As noted in the July 15, 2015 SNAP rule with respect to MVAC and standalone refrigeration equipment (80 FR 42884), it is reasonable to allow use of products 

manufactured before the change of status date to avoid market disruption, creation of stranded 

inventory, and perverse incentives for releasing these substances to the environment. 

For alternatives that have already been listed as unacceptable with a change of status date 

of January 1, 2017,98 or earlier—namely, HCFC blowing agents listed as unacceptable in 

appendices K, M, Q, and U to 40 CFR part 82 subpart G, and HFC blowing agents listed as 

unacceptable for rigid PU and PIR boardstock, extruded polystyrene sheet, and phenolic foams 

in appendix U to 40 CFR part 82 subpart G—we are proposing that the unacceptability 

 

98 There will also be a change of status on January 1, 2017 for flexible PU and integral skin PU, but these are open 

cell foams and are not part of this proposal for closed cell foams.
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determination would apply to use of closed cell foam products and products that contain closed 

cell foam manufactured on or after the date one year after the date of publication of a final rule. 

This timing is intended to allow importers and international manufacturers of such products time 

to adjust their manufacture and import plans. For substitutes that have already been listed as 

unacceptable with a change of status date after January 1, 2017—namely, HFC blowing agents 

listed as unacceptable in rigid PU slabstock and other; rigid PU appliance foam; rigid PU 

commercial refrigeration and sandwich panels; rigid PU marine flotation foam; polyolefin; and 

polystyrene extruded boardstock and billet- we are proposing that the unacceptability 

determination would apply to use of closed cell foam products and products that contain closed 

cell foam manufactured on or after the change of status date for each end-use (January 1 of 2019, 

2020, or 2021). For the substitutes already listed as unacceptable, we are proposing to add 

language regarding use of products to the relevant tables. We do not intend to re-open the listing 

of those substitutes as unacceptable or the change of status dates for those substitutes.

f. On which topics is EPA specifically requesting comment? 

EPA requests comment on all aspects of this proposal. In particular, we request comment 

on our proposal to revise our previous interpretation and to consider use of the foam blowing 

agent to include use of closed cell foam products and products containing closed cell foam. We 

are also taking comment on whether use of an open cell foam product should constitute use of 

the foam blowing agent. Finally, we request comment on the amount of time provided after 

which closed cell foam products and products containing closed cell foams manufactured on or 

after the specified dates would be subject to the use prohibitions. 

D. Fire suppression and explosion protection
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1. Proposed listing of 2-bromo-3,3,3-trifluoropropene (2-BTP) as acceptable, 

subject to use conditions, for total flooding and streaming

EPA is proposing to list 2-bromo-3,3,3-trifluoropropene (hereinafter referred to as 2-

BTP) as acceptable, subject to use conditions, for use on engine nacelles and APUs on aircraft in 

total flooding fire suppression systems. In addition, EPA proposes to list 2-BTP as acceptable, 

subject to use conditions, for use in aircraft as a streaming agent. EPA is reviewing additional 

potential fire suppression applications for 2-BTP but is not taking action on those other uses in 

this proposed rule.

a. What are the affected end-uses? 

The fire suppression and explosion protection end-uses addressed in this action are total 

flooding and streaming. Total flooding systems, which historically employed halon 1301 as a fire 

suppression agent, are used in both normally occupied and unoccupied areas. In the United 

States, approximately 90 percent of installed total flooding systems protect anticipated hazards 

from ordinary combustibles (i.e., Class A fires), while the remaining 10 percent protect against 

applications involving flammable liquids and gases (i.e., Class B fires).99 It is also estimated that 

approximately 75 percent of total flooding systems protect electronics (e.g., computers, 

telecommunications, process control areas) while the remaining 25 percent protect other 

applications, primarily in civil aviation (e.g., engine nacelles/APUs, cargo compartments, 

lavatory trash receptacles), military weapons systems (e.g., combat vehicles, machinery spaces 

on ships, aircraft engines and tanks), oil/gas and manufacturing industries (e.g., gas/oil pumping, 

compressor stations), and maritime (e.g., machinery space, cargo pump rooms). Streaming 

applications, which have historically used halon 1211 as an extinguishing agent, include portable 

 

99 Wickham, 2002.
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fire extinguishers designed to protect against specific hazards. 

b. How does 2-BTP compare to other fire suppressants for these enduses with respect to SNAP criteria? 

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; and ecosystem effects, particularly 

from negative impacts on aquatic life. These and other environmental and health risks are 

discussed below. In addition, a technical support document that provides the Federal Register 

citations concerning data on the SNAP criteria (e.g., ODP, GWP, VOC, toxicity, flammability) 

for acceptable alternatives in the relevant end-uses may be found in the docket for this 

rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015x).

i. Total flooding 

(a) Environmental impacts

In addition to halon 1301, the current market for total flooding systems also includes 

HCFCs, HFCs, inert gases, and a variety of NIK extinguishing agents (e.g., powdered aerosols, 

foams, water). 2-BTP has a GWP of 0.23-0.26 and a lower climate impact compared to other 

alternatives (e.g., HFC-227ea)100 used as total flooding and streaming agents. As shown in Table 

21, the GWPs of other total flooding alternatives range from<1 to 3,500.

Table 21: GWP, ODP, and VOC Status of 2-BTP Compared to Other Total Flooding and Streaming 

Agents

Fire Suppressants GWP ODP VOC Proposal

2-BTP 0.23 – 0.261 0.0028 Yes Acceptable, 

subject to use 

conditions

Total flooding

FK-5-1-12mmy2 (C6 

Perfluoroketone)

<1 0 Yes No change

CF3I 0.4 0.008 Yes No change

 

100 AR4
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CO2 1 0 No No change

HCFC Blend A2 1,546 0.048 No No change

HFC-227ea 3,220 0 No No change

HFC-125 3,500 0 No No change

Water, Inert gases, 

Powdered aerosols A-E

0 0 No No change

Streaming

HCFC Blend B3 77 0.00098 No No change

HFC-227ea 3,220 0 No No change

HFC-236fa 9,810 0 No No change

FK-5-1-12mmy2 (C6 

Perfluoroketone)

<1 0 Yes No change

CF3I 0.4 0.008 Yes No change

CO2 1 0 No No change

Water 0 0 No No change

H Galden HFPEs 2,790–6,230 0 No No change

1 GWP range represents GWPs for 30°N to 60°N and 60°S to 60°N emissions scenarios for a 100-year time horizon. 

A tropospherically well-mixed approximation of the GWP is equal to 0.59. (Patten et al. 2012)

2 HCFC Blend A is a blend consisting of HCFC-123 (4.75%), HCFC-22 (82%), HCFC-124 (9.5%), and D-limonene 

(3.75%).

3 HCFC Blend B is a proprietary blend consisting largely of HCFC-123.

In addition to global impacts on the atmosphere, EPA evaluated potential impacts of 

emissions of 2-BTP on local air quality. 2-BTP is a VOC and is not excluded from that definition 

under CAA regulations (see 40 CFR 51.100(s)) addressing the development of SIPs to attain and 

maintain the NAAQS. EPA compared the annual VOC emissions from the use of 2-BTP as a 

total flooding agent to other anthropogenic sources of VOC emissions considering both worst 

case and more realistic scenarios. Under either scenario, emissions are a small fraction of a 

percentage (5.6 x 10-5percent to 2.1 x 10-3percent) of all anthropogenic VOC emissions in the 

United States in 2014 (ICF, 2016x).101 Given this emission level, we determined it was not 

necessary to perform an assessment of the effect of these emissions on ambient ozone levels; any 

effect would be insignificant. This is particularly true since most releases of 2-BTP are expected 

to be at altitude, not in the lower troposphere. Other acceptable fire suppression agents currently 

in use in this end-use are also VOC (e.g., C6-perfluoroketone), and thus, use of 2-BTP would not 

 

101 Based on the 2014 annual total VOC emissions for the United States (i.e., approximately 17.13x106 MT) as 

reported in the National Emissions Inventory (EPA 2015).
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pose more risk than use of other alternatives. 

(b) Flammability

2-BTP is nonflammable, as are all other available total flooding agents. 

(c) Toxicity 

When identifying potential alternatives, toxicity is an important characteristic to consider 

for manufacturing personnel, service technicians, and end users. Typical concerns include 

residual oxygen concentration in the protected space after discharge and cardiac effects as a 

consequence of absorption of the agent into the bloodstream.

EPA has evaluated the risks associated with potential exposures to 2-BTP during 

production operations and the filling of fire extinguishers as well as in the case of an inadvertent 

discharge of the system during maintenance activities on the fire extinguishing system. EPA’s 

review of the human health impacts of 2-BTP, including the summary of available toxicity 

studies, and EPA’s review of the human health impacts of 2-BTP is in the docket for this 

rulemaking (EPA-HQ-OAR-2015-0663). 

According to the MSDS, exposure to 2-BTP through ocular or dermal absorption, 

inhalation, or ingestion may be harmful. However, the most likely pathway of exposure is 

through inhalation, which may cause central nervous system effects, such as dizziness, 

confusion, physical incoordination, drowsiness, anesthesia, or unconsciousness. EPA uses the 

NOAEL value as the basis to ensure protection to the worker population. The cardiotoxic 

Lowest-Observed-Adverse-Effect-Level (LOAEL) for this agent is 1.0 percent (10,000 ppm), at 

which level exposure may cause increased sensitivity of the heart to adrenaline, which might 

cause irregular heartbeats and possibly ventricular fibrillation or death; the cardiotoxic NOAEL 

for this agent is 0.5 percent (5,000 ppm).
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2-BTP vapors are heavier than air and may reduce oxygen available for breathing, 

causing asphyxiation in high concentrations. Such vapors pose a potential hazard if large 

volumes are trapped in enclosed or low places. In addition, as noted above, if person(s) are 

exposed to high concentrations, the person(s) may experience central nervous system effects, 

such as drowsiness and dizziness, which may result in the person(s) not realizing that he/she is 

suffocating. These health effects after exposure are similar for other common fire suppressants.

Employees responsible for manufacturing the systems should wear the appropriate PPE, 

such as protective gloves, tightly sealed goggles, protective work clothing, and suitable 

respiratory protection in case of accidental release or insufficient ventilation. Use of respirators is 

recommended during activities in which exposure to the proposed substitute cannot be controlled 

through other means. When handling a leak in a storage container, protective clothing is 

recommended as well as vapor-in air detection systems. Gloves (i.e., neoprene, polyvinyl 

chloride, or polyvinyl alcohol) should be worn when handling equipment containing the 

proposed substitute for prolonged periods.

For operations requiring regular handling of 2-BTP, engineering controls should include 

adequate ventilation systems and enclosed or confined operations to ensure exposure levels to 

the proposed substitute are below the occupational AEL. 2-BTP is not expected to pose a risk to 

workers when the engineering controls and PPE recommendations referenced in the MSDS for 

this proposed substitute are followed.

Exposure to 2-BTP is not likely during installation or servicing of 2-BTP total flooding 

systems for engines and APUs on aircraft. These are both considered to be unoccupiable areas, 

meaning personnel cannot physically occupy these spaces, thus reducing the risk from exposure 

to an inadvertent discharge. The risk of accidental activation of the fire extinguishing system 
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while personnel are present near the protected space is highly unlikely if proper procedures, 

including those of the 2-BTP system manufacturer as well as the aircraft manufacturer, are 

followed. Instructions on system installation and servicing included in manuals for the 2-BTP 

systems should be adhered to. In the case of an inadvertent discharge of the system during 

maintenance activities on the fire extinguishing system or surrounding equipment, the cowl 

doors that would be open to allow access to the area will allow personnel to immediately egress 

and avoid exposure. Protective gloves and tightly sealed goggles should be worn for installation 

and servicing activities, to protect workers in any event of potential discharge of the proposed 

substitute, accidental or otherwise. Filling or servicing operations should be performed in wellventilated areas.

2-BTP is not expected to cause a significant risk to human health in the general 

population when used as a total flooding fire extinguishing agent. Disposal of 2-BTP total 

flooding systems is subject to local, state, and federal regulations, which ensure that 2-BTP and 

water contaminated with 2-BTP are not be dumped into sewers, on the ground, or into any body 

of water, but rather taken to a wastewater treatment facility or disposed of properly. 2-BTP is not 

considered to be hazardous waste under EPA regulations implementing RCRA. 

EPA’s evaluation indicates that the use of 2-BTP is not expected to pose a significant 

toxicity risk to personnel or the general population. 2-BTP is not expected to cause a significant 

risk to human health in the general population when used as a total flooding fire extinguishing 

agent in systems designed specifically for engines and APUs on aircraft. Exposure to 2-BTP is 

not likely for technicians during installation or servicing of 2-BTP total flooding systems for 

engines and APUs. As indicated by the submitter, the risk of accidental activation of the fire 

extinguishing system while personnel are present near the protected space is highly unlikely if 
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proper procedures are followed. Proper instructions on system installation and servicing included 

in manuals for the 2-BTP systems should be adhered to. The locations of the 2-BTP bottles in the 

engine and APU compartments will vary by airplane model. The engine bottles could be 

installed inside or outside the pressurized volume, but they are connected through piping to the 

engines. APU bottles are typically installed forward of the APU firewall, outside of the 

pressurized volume of the plane. The bottles are hermetically sealed and the piping system is 

pressure tested, mitigating the potential for any leak of 2-BTP from the system. According to the 

submitter, in the case of an inadvertent discharge of the system during maintenance activities on 

the fire extinguishing system or surrounding equipment, the cowl doors that would be open to 

allow access to the area will allow service personnel to immediately egress and avoid exposure. 

Furthermore, aircraft maintenance procedures provide specific instruction to prevent accidental 

discharge of 2-BTP systems. It is expected that procedures identified in the MSDS for 2-BTP 

and good manufacturing practices will be adhered to, and that the appropriate safety and PPE

(e.g., protective gloves, tightly sealed goggles, protective work clothing, and suitable respiratory 

protection in case of accidental release or insufficient ventilation) consistent with OSHA 

guidelines will be used, as applicable, during manufacture and disposal of 2-BTP total flooding 

systems.

The toxicity risks can be minimized through the use conditions specified in section VI.D.c 

below. The risks after exposure are common to many total flooding agents, including those 

already listed as acceptable under SNAP for this same end-use such as C6-perfluoroketone. EPA 

is proposing to find 2-BTP acceptable, subject to use conditions, as a total flooding agent for use 

on engine nacelles and APUs on aircraft because the overall environmental and human health risk 

posed by the substitute is lower than or comparable to the overall risk posed by other alternatives
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listed as acceptable in the same end-use.

ii. Streaming uses

(a) Environmental impacts

In addition to halon 1211, the current market for streaming applications also includes 

HCFCs, HFCs, and a variety of other agents (e.g., dry chemical, CO2, water). Specific 

alternatives used for streaming uses include HCFC Blend B (with an ODP of roughly 0.01 and a 

GWP of roughly 80), HFC-227ea (with an ODP of zero and a GWP of 3,220), and C7 

Fluoroketone (with an ODP of zero and a GWP of approximately one). The ODP, GWP, and 

atmospheric lifetime of 2-BTP and other alternatives that are also used as total flooding agents 

are described above under total flooding applications. 2-BTP has a lower climate impact a 

shorter atmospheric lifetime compared to other alternatives in this end-use.

Regarding local air quality impacts, EPA compared the annual VOC emissions from the 

use of 2-BTP as a streaming agent to other anthropogenic sources of VOC emissions 

considering both worst case and more realistic scenarios. Under either scenario, emissions are a 

small fraction of a percentage (7.4 x 10-5percent to 2.1 x 10-3percent) of all anthropogenic 

VOC emissions in the United States in 2014 (ICF, 2016x).Given this emission level, we 

determined it was not necessary to perform an assessment of the effect of these emissions on 

ambient ozone levels; any effect would be insignificant. This is particularly true since most 

releases of 2-BTP are expected to be at altitude, not in the lower troposphere. Other acceptable 

fire suppression agents currently in use in this end-use are also VOC (e.g., C6-perfluoroketone, 

C7-fluoroketone), and thus, use of 2-BTP would not pose more risk than use of other 

alternatives. 

(b) Flammability
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2-BTP is nonflammable, as are all other available streaming agents. 

(c) Toxicity

EPA evaluated occupational and general population exposure at manufacture and at enduse to ensure that the use of 2-BTP as a streaming agent will not pose unacceptable risks to

workers or the general public. EPA has evaluated the risks associated with potential exposures 

to 2-BTP during production operations and the filling of fire extinguishers as well as in the 

case of an inadvertent discharge of the fire extinguisher during maintenance activities. 

2-BTP is not expected to pose a risk to workers during manufacture when the 

engineering controls and PPE requirements as also referenced in the MSDS for this proposed 

substitute are followed as described below in section VI.D.1.c.i. The combination of 

appropriate engineering controls and the use of PPE will ensure exposure levels to the 

proposed substitute are below the occupational AEL. Exposure to 2-BTP is not likely during 

installation or servicing of 2-BTP fire extinguishers. As indicated by the submitter, the risk of 

accidental activation of the fire extinguisher while personnel are present in the protected space 

is highly unlikely if proper procedures are followed. Proper instructions on system installation 

and servicing included in manuals for the 2-BTP systems should be adhered to. 

EPA also assessed potential end-use exposure scenario, 15-minute and 30-minute TWA 

exposures for 2-BTP following potential release of agent from the handheld extinguisher onboard aircraft. These exposures were then compared to the cardiotoxic LOAEL for 2-BTP. The 

modeled 15-minute and 30-minute exposures for varying ventilation rates were significantly 

lower than the LOAEL of 10,000 ppm for 2-BTP, as well as below the NOAEL of 5,000 ppm. 

2-BTP handheld extinguishers must follow required minimum room volumes established by 

UL 2129, Halocarbon Clean Agent Fire Extinguishers, when discharged into a confined space. 
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This standard prohibits the exceedance of the cardiotoxic LOAEL for any fire suppressant (i.e., 

10,000 ppm or 1.0% for 2-BTP). (American Pacific 2014a) Therefore, per UL 2129, labels for 

2-BTP extinguishers will contain the statement, “Do not use in confined spaces less than 896 

cubic feet per extinguisher.” Based on the above results, 2-BTP is not expected to pose 

significant risk to end users when used as a streaming fire extinguishing agent in aircraft.

There are various precautions described above, but the actual use conditions are 

described below. The general population risks during release or disposal of the agent are 

described in section VI.D.1.b above. The risks after exposure are common to many streaming

agents, including those already listed as acceptable under SNAP for this same end-use, such as 

C6-perfluoroketone. EPA is proposing to find 2-BTP acceptable, subject to use conditions, as a 

streaming agent on aircraft because the overall environmental and human health risk posed by 

the substitute is lower than or comparable to the overall risk posed by other alternatives listed as

acceptable in the same end-use.

c. What are the proposed use conditions? 

i. Engine nacelles and APU fire suppression systems on aircraft only

EPA is proposing to add 2-BTP to the list of acceptable total flooding substitutes, subject 

to use conditions. For the total flooding end-use, the proposed use conditions would require that 

2-BTP be used only for engine nacelles and APU on aircraft. 

ii. Handheld extinguishers in aircraft only

For the streaming end-use, the use condition would require that 2-BTP be used only for 

handheld extinguishers in aircraft. 

d. What further information is EPA providing in the acceptable subject 

to use conditions listing for 2-BTP?
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In the “Further Information” column of the regulatory listing, EPA is providing the 

following additional information for establishments manufacturing, installing and maintaining 

total flooding systems using this agent:

 This agent should be used in accordance with the safety guidelines in the latest 

edition of the National Fire Protection Association (NFPA) 2001 Standard for Clean 

Agent Fire Extinguishing Systems;

 In the case that 2-BTP is inhaled, person(s) should be immediately removed and 

exposed to fresh air; if breathing is difficult, person(s) should seek medical attention;

 In case of ocular exposure, person(s) should immediately flush the eyes, including 

under the eyelids, with fresh water and move to a non-contaminated area, and medical 

attention should be sought if irritation develops or persists;

 Eye wash and quick drench facilities should be available. In case of ocular exposure, 

person(s) should immediately flush the eyes, including under the eyelids, with fresh 

water and move to a non-contaminated area; Exposed persons should remove all 

contaminated clothing and footwear to avoid irritation; and medical attention should 

be sought if irritation develops or persists;

 Although unlikely, in case of ingestion of 2-BTP, the person(s) should consult a 

physician immediately;

 Manufacturing space should be equipped with specialized engineering controls and 

well ventilated with a local exhaust system and low-lying source ventilation to 

effectively mitigate potential occupational exposure; regular testing and monitoring 

of the workplace atmosphere should be conducted;
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 Employees responsible for chemical processing should wear the appropriate PPE, 

such as protective gloves, tightly sealed goggles, protective work clothing, and 

suitable respiratory protection in case of accidental release or insufficient ventilation;

 All spills should be cleaned up immediately in accordance with good industrial 

hygiene practices; and

 Training for safe handling procedures should be provided to all employees that would 

be likely to handle containers of the agent or extinguishing units filled with the agent.

 Safety features that are typical of total flooding systems such as pre-discharge alarms, 

time delays, and system abort switches should be provided, as directed by applicable 

OSHA regulations and NFPA standards. Use of this agent should also conform to 

relevant OSHA requirements, including 29 CFR 1910, subpart L, sections 1910.160 and 

1910.162. 

In the “Further Information” column of the regulatory listing, EPA is providing the 

following additional information for establishments manufacturing, installing and maintaining 

streaming agents: 

 This agent should be used in accordance with the latest edition of NFPA Standard 

10 for Portable Fire Extinguishers;

 In the case that 2-BTP is inhaled, person(s) should be immediately removed and 

exposed to fresh air; if breathing is difficult, person(s) should seek medical 

attention;

 Eye wash and quick drench facilities should be available. In case of ocular 

exposure, person(s) should immediately flush the eyes, including under the eyelids, 

with fresh water and move to a non-contaminated area. Exposed person(s) should 
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remove all contaminated clothing and footwear to avoid irritation, and medical 

attention should be sought if irritation develops or persists;

 Although unlikely, in case of ingestion of 2-BTP, the person(s) should consult a 

physician immediately;

 Manufacturing space should be equipped with specialized engineering controls and 

well ventilated with a local exhaust system and low-lying source ventilation to 

effectively mitigate potential occupational exposure; regular testing and monitoring 

of the workplace atmosphere should be conducted;

 Employees responsible for chemical processing should wear the appropriate PPE, 

such as protective gloves, tightly sealed goggles, protective work clothing, and 

suitable respiratory protection in case of accidental release or insufficient 

ventilation;

 All spills should be cleaned up immediately in accordance with good industrial 

hygiene practices;

 Training for safe handling procedures should be provided to all employees that 

would be likely to handle containers of the agent or extinguishing units filled with 

the agent; 

 2-BTP use as a streaming fire extinguishing agent in handheld extinguishers on 

aircraft should be in accordance with UL 711, Rating and Testing of Fire 

Extinguishers and the Federal Aviation Administration (FAA) Minimum 

Performance Standard for Hand-Held Extinguishers (DOT/FAA/AR-01/37), with 

regard to the size and number of extinguishers depending on the size of aircraft. 2-

BTP handheld extinguishers should also follow required minimum room volumes 
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established by UL 2129, Halocarbon Clean Agent Fire Extinguishers, when 

discharged into a confined space. This standard prohibits the exceedance of the 

cardiotoxic LOAEL for any fire suppressant (i.e., 10,000 ppm or 1.0 percent for 2-

BTP). 

e. When would the listing apply?

EPA proposes that this listing would apply 30 days after the date of publication of a final 

rule. This date, the same as the proposed effective date of this regulation, allows for the safe use 

of this substitute at the earliest opportunity.

f. What is the relationship between this SNAP rule and other federal 

rules?

As required for a new chemical, the manufacturer of this agent submitted a Toxic 

Substance Control Act (TSCA) Premanufacture Notice (PMN) for review by EPA. The PMN, 

designated as P-14-260, has completed EPA review and the manufacturer is presently subject to 

requirements contained in a TSCA section 5(e) Consent Order. Other future manufacturers and 

processors will be subject to a TSCA section 5(a)(2) Significant New Use Rule (SNUR) that is 

expected to be promulgated in 2016. The requirements of the consent order and SNUR would 

apply to all commercial manufacturing, processing, distribution in commerce, use and disposal 

of 2-BTP, unless exempted. Consistent with today’s proposed listing, the consent order and 

SNUR will require use of 2-BTP for aircraft either 1) as a total flooding agent in engine nacelles 

and APUs on aircraft or 2) as a streaming agent in handheld extinguishers in aircraft. As noted 

above in section VI.D.1.d, FAA has issued guidance on the use of hand-held fire extinguishers 

on aircraft that is relevant to the streaming uses proposed in this rule.

g. On which topics is EPA specifically requesting comment?
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EPA is requesting comment on all aspects of the proposed listing decision, including the 

proposed use conditions. 

2. Proposed change of status for certain perfluorocarbons 

EPA is proposing to change the listings from acceptable to unacceptable for C3F8 (PFC218) and C4F10 (PFC-410) in total flooding systems. We note that these changes of status apply 

to the manufacture of new equipment using these agents. Existing equipment that contains these 

agents may continue to be used for the remaining lifetime of the equipment.

a. What is the affected end-use? 

The fire suppression and explosion protection end-uses addressed in this action is total 

flooding. The fire suppression industry has historically used halons, a class of halogenated 

chemicals containing bromine, as clean extinguishing agents (i.e., those that do not leave residue 

following system discharge) in many different applications. Halon 1301 has been used in fixed 

total flooding systems. 

Halons have a unique combination of characteristics including being electrically nonconductive, dissipating rapidly without residue (i.e., clean), efficiently extinguishing most types 

of fires, and low toxicity. These agents are extremely effective on ordinary combustibles, 

flammable liquids and gases, and electrical fires (i.e., Class A, Class B, and Class C fires, 

respectively). These characteristics allowed halon systems to be widely used to effectively 

protect valuable and sensitive assets in locations such as computer and control rooms, electronic 

data processing facilities, museums, military equipment, shipboard machinery, space, aircraft, 

and oil and gas industry facilities. 

Halons have very high ODPs because they contain bromine, which has a higher reactivity 

with ozone than chlorine. Specifically, the ODP of halon 1301 is 15.9 (WMO, 2011). EPA 
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banned the production and import of newly produced halons beginning January 1, 1994 (58 FR 

65018; December 10, 1993) consistent with the requirements of the CAA and the Montreal 

Protocol. In addition, EPA issued regulations codified at 40 CFR part 82 subpart H to reduce 

emissions of halon through technician training and proper disposal. The U.S. fire suppression 

industry supported the phase out of halon production by working to find effective substitutes and 

to reduce unnecessary emissions of halon. Recycled halon is relied on for continuing uses of 

halons. 

In response to the early 1994 phaseout of halon production, industry took early actions to 

find alternatives including less ozone-depleting HCFCs, non-ozone-depleting HFCs, as well as a 

variety of lower-GWP or no-GWP alternatives (e.g., inert gases, CO2, powdered aerosols, 

foams, water). Industry also took actions to minimize emissions and halon recycling emerged as 

an important initiative to both reduce unnecessary emissions, and to ensure supplies of halons 

during the transition. Other efforts included changes to national and international fire codes and 

standards to discourage the use of halons for testing and training while supporting the adoption 

of the alternatives listed as acceptable in fire suppression and explosion protection by EPA’s 

SNAP program.

b. Which fire suppressants is EPA proposing to list as unacceptable? 

EPA is proposing to list C4F10 (PFC-410) and C3F8 (PFC-218) as unacceptable in certain 

uses for which they are currently listed as acceptable subject to narrowed use limits. 

c. How do the proposed unacceptable fire suppressants compare to 

other fire suppressants for this end-use with respect to SNAP criteria? 

The SNAP program considers a number of environmental criteria when evaluating 

substitutes: ODP; climate effects, primarily based on GWP; local air quality impacts, particularly 

potential impacts on smog formation from emissions of VOC; and ecosystem effects, particularly 
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from negative impacts on aquatic life. These and other environmental and health risks are 

discussed below. In addition, a technical support document that provides the Federal Register 

citations concerning data on the SNAP criteria (e.g., ODP, GWP, VOC, toxicity, flammability) 

for acceptable alternatives in the relevant end-uses may be found in the docket for this 

rulemaking (EPA-HQ-OAR-2015-0663) (EPA, 2015x).

(a) Environmental impacts

PFCs are fully fluorinated compounds, unlike CFCs, HCFCs, or HFCs. These chemicals 

have an ODP of zero, are excluded from the definition of VOC under CAA regulations (see 40 

CFR 51.100(s)) addressing the development of SIPs to attain and maintain the NAAQS, and 

have high GWPs (5,000-10,000 times greater than CO2). Although the actual contributions to 

global warming depend upon the quantities emitted, because of their long atmospheric lifetimes, 

the warming effects of PFCs are essentially irreversible. As discussed in Section III above and in 

EPA’s Endangerment Finding (74 FR 66496; December 7, 2009), EPA determined that PFCs are 

one of the six key well-mixed greenhouse gases in the atmosphere — in addition to CO2, CH4, 

N2O, HFCs, and SF6 — whose current and projected concentrations were found to threaten the

public health and welfare of current and future generations.

Table 22: GWP, ODP, and VOC Status of C3F8, and C4F10 Compared to Other Total Flooding Agents

Fire Suppressants GWP ODP VOC Proposal

Total Flooding

C3F8, C4F10 8,830 - 8,860 0 No Unacceptable

CF3I 0.4 0.008 Yes No change

FK-5-1-12mmy2 <1 0 No No change

HCFC-124, HCFC Blend A 610-1,550 0.048-0.22 No No change

Halotron II, HFC-125, HFC-227ea 1,600 - 3,500 0 No No change

HFC-236fa 9,810 0 No No change

HFC-23 14,800 0 No No change

Water, Inert gases, Powdered aerosols A-E 0 0 No No change

Streaming

C6F14 9,300 0 No Unacceptable

CO2 1 0 No No change

C7 fluoroketone, FK-5-1-12mmy2 <1 0 No No change

HCFC Blend B, HCFC-123, HCFC-124 77-1,546 0.00098-

0.048

No No change
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HFC-227ea, HFC-236fa 3,220-9,810 0 No No change

H Galden HFPEs 2,790–6,230 0 No No change

Water 0 0 No No change

As shown in Table 22, C3F8 has a GWP of 8,830. EPA found the substitute acceptable 

only in those limited instances where no other alternative is technically feasible due to 

performance or safety requirements (60 FR 31092; July 13, 1995). C4F10 has a GWP of 8,860. 

Because of similar concerns including the GWPs, EPA listed these as substitutes that would be 

used as a last resort. Other commonly-used alternatives for total flooding applications have lower 

GWPs including HFC-227ea (with GWP of 3,220), HFC-125 (with a GWP of 3,500), and C6

Fluoroketone (with a GWP of approximately one). 

(b) Flammability

C3F8 and C4F10 are non-flammable, like all other fire suppression agents listed as 

acceptable under SNAP.

(c) Toxicity

In evaluating the toxicity concerns with fire suppression agents, we evaluate consumer 

and worker exposures to discharges of substitutes during fire emergencies and accidental 

discharges. In these acute, episodic exposures to the substitutes, cardiac sensitization is of 

particular interest. The term cardiac sensitization refers to an increased susceptibility of the heart 

to adrenaline (or other catecholamines) which may result in potentially fatal heart arrhythmias. 

Human heart arrhythmias and sudden deaths resulting from overexposure to CFCs, halons, and 

other halogenated hydrocarbons have been documented in workplace settings. 

The determination of the toxicity risk to either workers or the general population from an 

accidental discharge of either a flooding or streaming agent substitute is also dependent on a 

number of other related factors. For total flood systems, the magnitude of exposure will depend 

on the design concentration of the flooding agent (as determined by the substitute's extinguishing 
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concentration plus a safety factor, as specified by NFPA guidelines) and the length of time it 

takes a person to evacuate the area in which the agent is released. Because total flood systems are 

designed to achieve a uniform concentration of agent within a space, the magnitude of exposure 

is independent of the size of space, size of fire, or proximity of person to the fire. In assessing 

exposure the design concentration of a total flood substitute is compared to its cardiotoxic 

NOAEL and LOAEL levels. Generally, for occupied areas, if the design concentration is higher 

than the agent's NOAEL level, conditions are placed on the use of the agent to ensure human 

safety (e.g., lower time allowed for safe egress). 

Compared to other substitutes in the same total flooding end-use, these PFCs have lower 

toxicity profiles. The cardiotoxic NOAEL for C4F10 is 40 percent which is well above its 

demonstrated extinguishing concentration of 5.5 percent in total flood applications, indicating its 

safe use in occupied areas. The cardiotoxic NOAEL for C3F8 is 30 percent which is also well 

above its demonstrated extinguishing concentration of 7.3 percent with cup burner tests in 

heptane (with a resulting design concentration of 8.8 percent), also indicating its safe use in 

occupied areas. In comparison, HFC-227ea has a cardiotoxic NOAEL of nine percent and an 

extinguishing concentration of 5.2 percent (minimum extinguishing concentration for Class A 

fires) and C6-perfluoroketone has a cardiotoxic NOAEL of ten percent and an extinguishing 

concentration of 3.5 percent (minimum extinguishing concentration for Class A fires). For HFC227ea and C6-perfluoroketone, the concentrations needed to extinguish typical Class A fires are 

below the NOAEL. In addition, NFPA 2001 Standard for Clean Agent Extinguishing Systems

contains the times for safe human exposure at specific concentrations for both HFC-227ea and 

C6-pefluoroketone in order to allow safe egress of personnel from the protected space in the 

event of a system discharge. Current industry practices include additional safeguards for these 
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systems such as pre-discharge alarms and time-delays. While C4F10 and C3F8 have lower toxicity 

profiles, the greater toxicity risks of the other alternatives for the same end-uses are mitigated by 

requirements as established in NFPA 2001, which requires that the alternative have first been 

reviewed in a process equivalent to that used by SNAP and then provides the minimum 

requirements for the safe design, installation, maintenance, and operation of total flooding 

systems using clean agent alternatives such as HFC-227ea and C6-perfluoroketone.

In comparing the environmental and health risks of C3F8 and C4F10 with other alternatives 

in the same total flooding end-use, C3F8 and C4F10 both have higher GWPs. While C3F8 and C4F10

have lower toxicity profiles, the greater toxicity of other alternatives in the same end-use are 

mitigated by the fact that requirements for safe use of these alternatives are contained in fire 

protection industry standards (e.g., NFPA 2001). Other criteria are comparable to many agents 

already listed as acceptable under SNAP for this end-use. Because the GWPs for C3F8 and C4F10

are significantly higher and thus pose significantly greater risk than other alternatives in the same 

end-use, we are proposing to list C3F8 and C4F10 as unacceptable for total flooding applications.

(d) Summary

EPA has listed as acceptable several substitutes that pose lower overall risk to human 

health and the environment than the two fire suppression alternatives, C3F8 and C4F10, whose 

status we are proposing to change to unacceptable. The risks other than GWP are not 

significantly different for the other available alternatives in the same total flooding end-use than 

for the fire suppression agents we are proposing to list as unacceptable. Neither the substitutes 

we are proposing to list as unacceptable nor the other available alternatives pose a significantly 

greater risk based on toxicity because all may be used consistent with NFPA 2001. However, the 

GWPs for the fire suppression agents, C3F8 and C4F10, which we are proposing to list as 
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unacceptable, are significantly higher and thus pose significantly greater risk. Because the GWPs 

for C3F8 and C4F10 are significantly higher than other available alternatives in this end-use and 

there is no significant difference in risk based on the other evaluation criteria, we are proposing 

to list C3F8 and C4F10 as unacceptable for total flooding applications.

d. When would the status change?

Today, the demand in the fire suppression total flooding end-use is being met through the 

availability of clean agents and not-in-kind (NIK) substitutes (i.e., non-gaseous agents, including 

powdered aerosols, foam, and water mist). (ICF, 2015x). The current market for the total 

flooding end-use consists of commercially available and proven alternatives including HCFCs, 

HFCs, inert gases, and a variety of NIK extinguishing agents (e.g., powdered aerosols, foams 

water) and technologies. National and international standards currently cover the requirements, 

specifications, and recommendations for design, installation, testing, maintenance, and safety 

factors for many of these alternatives in the total flooding end- use. 

Considering the above, and the current suite of other available substitutes in the fire 

suppression total flooding end uses EPA is proposing to change the listings from acceptable to 

unacceptable for C3F8 and C4F10 in total flooding systems as of one year after publication of a 

final rule. Based on the information available to EPA today on the total flooding agent markets 

as discussed above, including through various discussions with industry representatives, users 

have other available alternatives with lower overall risks to human health and the environment. 

Given the broad commercial availability of the alternative systems already and coverage by 

national and international standards of many of the alternatives, one year provides a reasonable 

timeframe for the change in status for C3F8 and C4F10 in total flooding systems.

e. What is the relationship between this SNAP rule and other federal
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rules?

EPA is not aware of other federal rules applying to these two fire suppression agents in 

the total flooding end-use.

f. On which topics is EPA specifically requesting comment? 

EPA requests comments on all aspects of these proposed changes. EPA specifically 

requests updated information with regard to the use of these PFCs in total flooding applications 

as well as the availability of other substitutes for this end-use. EPA is also interested in advance 

comments on whether to take similar action with respect to certain additional fire suppression 

agents. Specifically, EPA requests advance comments and updated information on total flooding 

uses of SF6,HFC-23, and HFC-125, and on both total flooding and streaming uses of HFC-227ea. 

SF6 is listed as acceptable subject to narrowed use limits for use as a discharge test agent in 

military uses and civilian aircraft uses only (60 FR 31092; July 13, 1995). SF6 is a 

nonflammable, nontoxic gas which is colorless and odorless. SF6 is relatively inert, and has an 

atmospheric lifetime of 3,200 years, with a GWP of 22,800. SF6 is the most potent GHG the 

IPCC has evaluated. The U.S. Navy has used SF6 as a test gas simulant in place of halon in new 

halon total flooding systems on ships which have been under construction prior to identification 

and qualification of substitute agents. Halon systems are no longer included in designs for new 

ships. Similarly, the airline industry had an interest in using SF6 as a discharge test agent 

simulating halon 1301 in aircraft system certification testing to ensure aircraft in-flight fire 

safety. The amount of SF6 released in developing and certifying these critical systems for 

commercial aircraft was estimated to be approximately 1,000 pounds per year or less for this 

development period, however airlines continue to build new aircraft with halon systems. EPA is 

not aware of SF6 use in other commercial sector testing regimes, and EPA imposed a narrowed 
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use limit on SF6 as a discharge test agent to ensure that emissions of this agent remain minimal.

The NFPA 12a and NFPA 2001 standards recommend that halon or other total flooding gases 

not be used in discharge testing, but that alternative methods of ensuring enclosure and piping 

integrity and system functioning be used. Alternative methods can often be used, such as the 

``door fan'' test for enclosure integrity, UL 1058 testing to ensure system functioning, pneumatic 

test of installed piping, and a ``puff'' test to ensure against internal blockages in the piping 

network. These stringent design and testing requirements have largely obviated the need to 

perform a discharge test for total flood systems containing either halon 1301 or a substitute agent 

outside of military and civil aircraft uses.

EPA requests comment and updated information on whether there is current or 

continuing use of SF6 in this end-use and the availability of substitutes or alternative 

technologies or processes that would obviate its continued use.

HFC-23 is listed as acceptable as a total flooding substitute. In the SNAP final rule of 

March 18, 1994 (59 FR 13044), EPA decided not to adopt the proposed narrowed use limits on 

HFC-23 in response to comments that its cardiotoxicity profile was favorable compared to its 

design or inerting concentration and in some cases it was the only acceptable alternative in 

particular applications such as: (a) where temperatures are likely to go below zero degrees, (b) 

where pre-inerting is required for occupied areas, and (c) where occupied areas can suffer 

considerable variation in fire volume. HFC-23 is used as a total flooding agent in occupied areas 

because of its favorable cardiotoxicity profile with values of 30 percent for the NOAEL and 50 

percent for the LOAEL, compared to a design concentration of 14.4 percent, based on cup burner 

tests in heptane. Compared to an inerting concentration in methane of 20.5 percent and an 

inerting design concentration of 22.6 percent in methane, the agent made for an excellent 
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candidate for use in explosion inertion. Nevertheless, it is also a potent greenhouse gas with a 

GWP of 14,800. 

In its 2014 Assessment, the UNEP TEAP HTOC reported on the status of the use of 

halons and alternatives in the various sector of use including in pipelines and the oil and gas 

industry. Halon 1301 is used for maintaining legacy systems used to prevent explosions and to 

suppress fires in inhospitable locations such as the Alaskan North Slope in the United States. 

This situation remains the same today since “existing facilities were designed and constructed 

with halon 1301 fixed systems as an integral part of the safety system design as well as the 

physical layout of the facility.” New facilities adopt inherently safe design approaches that 

eliminate the potential flammable or explosive hazards. New technologies such as advanced 

detection systems also reduce reliance on need to close and inert the space. However, where an 

inerting agent is still required in occupied spaces, halon 1301 has been replaced by HFC-23 or 

C6-perfluoroketone, if temperatures permit. Currently, HFC-23 is the only alternative 

determined to meet both the requirement to mitigate inerting high-GWP gas release, such as 

methane, and perform its function in fully enclosed spaces in very cold climatic conditions. 

EPA requests comment and updated information on the continuing use of HFC-23 in this and 

potentially other applications in this end-use and the availability of substitutes or alternative 

technologies or processes that would obviate its continued use. 

With significant progress made by the U.S. total flooding systems industry in adopting a 

variety of suppression agent alternatives, EPA understands that, as a result, a mix of agents are in 

use today with high-GWP HFCs occupying a substantial portion of the products on the market. 

Currently, HFCs account for approximately 23 percent of the alternatives used to replace halon 

1301, while HFC-227ea constitutes a majority of that total, with some use of other HFCs such as 
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HFC-23 and HFC-125 (EPA 2014a). EPA, therefore, also requests comment and updated 

information on the continuing use of HFC-125 and HFC-227ea in fire protection and explosion 

protection. HFC-227ea is an acceptable alternative for both total flooding (59 FR 12044; March 

18, 1994) and streaming (64 FR 22987; April 28, 1999) applications; HFC-125 is an acceptable 

alternative for total flooding uses (59 FR 12044; March 18, 1994). The extinguishing 

concentration for HFC-227ea for typical Class A fires in heptane is below its NOAEL making it 

appropriate it for use as a total flooding agent in normally occupied spaces, while the 

extinguishing concentration for HFC-125 is above its cardiotoxic NOAEL making it appropriate 

for use in spaces that are not normally occupied. EPA is requesting comment and updated 

information on the continuing use of these alternatives and the availability of substitutes or 

alternative technologies or processes that would obviate their continued use.

3. Proposed removal of Powdered Aerosol D in total flooding from the list of 

substitutes acceptable for use subject to use conditions

Powdered Aerosol D is a pyrotechnic particulate aerosol and explosion suppressant that 

also is marketed under the trade names of Aero-K

® and Stat-X®. This fire suppressant is supplied 

to users as a solid housed in a double-walled hermetically-sealed steel container. When the unit 

is triggered by heat (300 °C), the product is pyrotechnically activated to produce gases and 

aerosol particles from a mixture of chemicals. EPA listed Powdered Aerosol D as acceptable 

subject to use conditions as a total flooding agent (71 FR 56359; September 7, 2006). The use 

conditions required that Powdered Aerosol D be used only in areas that are not normally 

occupied, because the Agency did not have sufficient information at that time supporting its safe 

use in areas that are normally occupied. Based on a review of additional information from the 

submitter to support the safe use of Powdered Aerosol D in normally occupied spaces, EPA 
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subsequently determined that Powdered Aerosol D is also acceptable for use in total flooding 

systems for normally occupied spaces (79 FR 62863; October 21, 2014). The listing provides 

that Powdered Aerosol D is acceptable for total flooding uses, which includes both unoccupied 

and occupied spaces. In the October 2014 listing action, EPA noted that in a subsequent 

rulemaking, the Agency would remove the previous listing of acceptable subject to use 

conditions. Today, EPA is proposing to remove this listing for Powdered Aerosol D.

VII. Statutory and Executive Orders Reviews

Additional information about these statutes and Executive Orders can be found at 

http://www2.epa.gov/laws-regulations/laws-and-executive-orders. 

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

This action is a significant regulatory action that was submitted to the Office of 

Management and Budget (OMB) for review. It raises novel legal or policy issues arising out of 

legal mandates, the President’s priorities, or the principles set forth in the Executive Order. Any 

changes made in response to OMB recommendations have been documented in the docket. EPA 

prepared an analysis of the potential costs and benefits associated with this action. These are 

available in the docket under the titles, “Climate Benefits of the Proposed SNAP Program Status 

Change Rule” and “Preliminary Cost Analysis for Regulatory Changes to the Listing Status of 

High-GWP Alternatives used in Refrigeration and Air Conditioning, Foams, and Fire 

Suppression.”

B. Paperwork Reduction Act (PRA)

This action does not impose any new information collection burden under the PRA. OMB 

has previously approved the information collection requirements contained in the existing 
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regulations and has assigned OMB control number 2060–0226. This proposed rule contains no 

new requirements for reporting or recordkeeping.

C. Regulatory Flexibility Act

I certify that this action will not have a significant economic impact on a substantial 

number of small entities under the RFA. The small entities subject to the requirements of this 

action are small businesses. For purposes of assessing the impacts of this rule on small entities, 

EPA evaluated small businesses as defined by the Small Business Administration’s (SBA) 

regulations at 13 CFR 121.201. The Agency has determined that about 1,500 small businesses 

could be subject to the rulemaking, although more than 97 percent of small businesses subject to 

this proposed rulemaking would be expected to experience compliance costs of less than one 

percent of annual sales revenue. Details of this analysis are presented in the document entitled, 

“Draft Economic Impact Screening Analysis for Regulatory Changes to the Listing Status of 

High-GWP Alternatives used in Refrigeration and Air Conditioning, Motor Vehicle Air 

Conditioners, Foams, and Fire Suppression.” Today’s action allows equipment manufacturers the 

additional options of using propane, HFO-1234yf, and 2-BTP in the specified end-uses but does 

not mandate such use. Because these substitutes are not yet being used in the United States for 

the end-uses (with the exception of limited test-marketing), no change in business practice would 

be required to meet the use conditions, resulting in no adverse impact compared to the absence of 

this rule. Provisions that allow venting of hydrocarbon refrigerants in the uses of propane 

addressed by this rule would reduce regulatory burden. We have therefore concluded that this 

action would relieve regulatory burden for all small entities that choose to use propane as a 

refrigerant in the end-uses in this proposed listing. The use conditions of this rule apply to 

manufacturers of commercial ice machines, water coolers, and very low temperature 
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refrigeration equipment that choose to use propane. 

The requirements of this proposed rule with respect to HFCs, if finalized as proposed, 

would impact small businesses that manufacture food processing and dispensing equipment, 

household refrigerators and freezers, cold storage refrigeration systems, and polyurethane foams; 

operators of cold storage refrigeration systems, including refrigerated warehouses, wholesalers, 

and food manufacturers; and manufacture and use cold storage warehouses, and small businesses 

that import products containing closed cell phenolic, polyisocyanurate, polyolefin, PU, and 

polystyrene foams manufactured with HFC or HCFC foam blowing agents. The proposal to 

prohibit use of methylene chloride as a foam blowing agent is not anticipated to impact small 

businesses because this substance is not expected to be used currently as a blowing agent.This 

rule’s provisions do not create enforceable requirements for refrigeration and AC technicians, 

but they would indirectly affect technicians servicing motor vehicle AC systems, certain types of 

retail food refrigeration equipment, cold storage warehouses, and commercial AC equipment

where the technician, rather than the refrigeration or AC equipment owner, purchases servicing 

equipment for different refrigerants. EPA expects these indirect impacts on technicians are 

minimal, because the transitions to different refrigerants required by this rule are already 

occurring due to corporate social responsibility initiatives (e.g., Consumer Goods Forum pledge 

concerning HFC refrigerants), and because many of the still-acceptable alternatives are already 

used for these refrigeration or AC equipment types. Further, most acceptable HFC refrigerant 

blends can be recovered and serviced using equipment that service technicians already own. In 

some uses, there is no significant impact of the proposed rule because the substitutes proposed to 

be prohibited are not widely used (e.g., use of perfluorocarbons for fire suppression, use of 

methylene chloride as a foam blowing agent in various types of foam). A significant portion of 
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the businesses regulated under this rule are not small businesses (e.g., commercial AC 

manufacturers). We have therefore concluded that this action will not have a significant impact 

on a significant number of small entities.

D. Unfunded Mandates Reform Act (UMRA)

This action does not contain any unfunded mandate as described in UMRA, 2 U.S.C. 

1531–1538, and does not significantly or uniquely affect small governments. The action imposes 

no enforceable duty on any state, local or tribal governments or the private sector.

E. Executive Order 13132: Federalism

This action does not have federalism implications. It will not have substantial direct 

effects on the states, on the relationship between the national government and the states, or on 

the distribution of power and responsibilities among the various levels of government.

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments

This action does not have tribal implications as specified in Executive Order 13175. It 

will not have substantial direct effects on tribal governments, on the relationship between the 

Federal government and Indian tribes, or on the distribution of power and responsibilities 

between the Federal government and Indian tribes, as specified in Executive Order 13175. Thus, 

Executive Order 13175 does not apply to this action. EPA specifically solicits additional 

comment on this proposed action from tribal officials. 

G. Executive Order 13045: Protection of Children from Environmental Health and Safety 

Risks

This action is not subject to Executive Order 13045 because it is not economically 

significant as defined in Executive Order 12866, and because EPA does not believe the 

environmental health or safety risks addressed by this action present a disproportionate risk to 
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children. This proposed rule restricts the use of certain substitutes that have greater overall risks 

for human health and the environment, primarily due to their high global warming potential. The 

reduction in GHG emissions would provide climate benefits for all people, including benefits for 

children and future generations. The public is invited to submit comments or identify peerreviewed studies and data that assess effects of early life exposure to the alternatives addressed 

in the comparisons of toxicity for the various substitutes, as well as risk screens for the 

substitutes that are proposed to be listed as acceptable, subject to use conditions, or are newly 

listed as unacceptable (ICF, 2015e,f,g,h,i,j,k,l). The risk screens are in the docket for this 

rulemaking.

H. Executive Order 13211: Actions Concerning Regulations That Significantly Affect 

Energy Supply, Distribution, or Use 

This action is not a “significant energy action” because it is not likely to have a 

significant adverse effect on the supply, distribution or use of energy. For the end-uses that are 

related to energy effects such as refrigeration and AC, a number of alternatives are available to 

replace those refrigerants that are proposed as unacceptable in this action; many of the 

alternatives are as energy efficient or more energy efficient than the substitutes being proposed 

unacceptable. Thus, we have concluded that this rule is not likely to have any adverse energy 

effects.

I. National Technology Transfer and Advancement Act (NTTTAA)

This action includes technical standards. EPA is proposing to use standards from UL in 

the use conditions for propane. EPA is incorporating by reference portions of current editions of 

the UL Standards 471, “Commercial Refrigerators and Freezers” (10th Edition, November 24,

2010), UL 563 “Ice Machines” (8th Edition, July 31, 2009; and UL 399, “Water Coolers” (7th 
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Edition, August 22, 2008). These use conditions would ensure that these new substitutes for very 

low temperature refrigeration equipment, commercial ice machines, and water coolers, do not 

present significantly greater risk to human health or the environment than other alternatives. 

These standards may be purchased by mail at: COMM 2000; 151 Eastern Avenue; Bensenville, 

IL 60106; Email: orders@comm-2000.com; Telephone: 1-888-853-3503 in the U.S. or Canada

(other countries dial +1-415-352-2168); Internet address: http://ulstandardsinfonet.ul.com/ or 

www.comm-2000.com.

In addition, EPA is incorporating by reference the list of refrigerants that ASHRAE 

designates as flammability Class 3 according to ASHRAE Standard 34–2010 in the 

unacceptability listing for certain highly flammable refrigerants for use in existing residential and 

light commercial split AC systems. This standard may be purchased by mail at: ____________;

by telephone: 1-800-527-4723 in the U.S. or Canada; Internet address:

http://www.techstreet.com/ashrae/ashrae_standards.html?ashrae_auth_token=

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

The human health or environmental risk addressed by this action will not have potential 

disproportionately high and adverse human health or environmental effects on minority, lowincome or indigenous populations. The results of this evaluation are contained in This action’s 

health and risk assessments are contained in the comparisons of toxicity for the various 

substitutes, as well as risk screens for the substitutes that are proposed to be listed as acceptable, 

subject to use conditions, or are newly listed as unacceptable (ICF, 2015e,f,g,h,i,j,k,l). The risk 

screens are in the docket for this rulemaking.
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VIII. References

A.S. Trust & Holdings, 2007. Submission of SNAP Information Notice and Associated 

Documents for Proposed New Hydrocarbon Refrigerant HCR-188C for use in White 

Goods Systems. June 5, 2007.

A.S. Trust & Holdings, 2008. Fault-Tree Analysis of the Use of HCR-188C, A Safe Alternative 

Hydrocarbon Refrigerant, in Residential Combination Refrigerators/Freezers and 

WindowAir Conditioning Units. Addendum to SNAP Application. Authors: Whitmyre 

and Whitmyre. Sponsor: A.S. Trust & Holdings. July 31, 2008.

A.S. Trust & Holdings, 2010. Risk Assessment and Fault-Tree Analysis for the Use of the 

Alternative Hydrocarbon Refrigerant HCR-188C1 in New MVAC Systems.

A.S. Trust & Holdings, 2011. Submission of SNAP Information Notice and Associated 

Documents for Proposed New Hydrocarbon Refrigerant HCR-188C1/R-441A for use in 

New Vending Machines. September 26, 2011.

A.S. Trust & Holdings, 2014. Re: Submission of Addendum to SNAP Application dated 5 June 

7, 2007 to add proposed use of R-443A in New Household Window Air Conditioners.

AHRI, 2014. Guideline N-2014 for Assignment of Refrigerant Container Colors. This document 

is accessible online at 

http://www.ahrinet.org/App_Content/ahri/files/Guidelines/AHRI_Guideline_N_2014.pdf.

AHRI, 2015. AHRI Will Reinforce Refrigerant R&D Commitment at White House Event. 

October 15, 2015. This document is accessible at: 

http://www.ahrinet.org/site/A__1112/295/Modules/AHRI/Articles.

AIRAH, 2013. Australian Institute of Refrigeration, Air Conditioning and Heating. Safety 

Guide: Flammable Refrigerants. 2013. This document is accessible at: 

http://www.unep.fr/ozonaction/information/mmcfiles/7681-eFlammableRefrigerantsGuideAIRAH.pdf.

Airgas, 2015. Safety Data Sheet for Propylene.

Akerman, 2013. Hydrofluorocarbons and Climate Change: Summaries of Recent Scientific and 

Papers. 2013.

American Pacific, 2014. Document discussing probability of handheld fire extinguisher 

discharges onboard commercial airplanes.

ASHRAE, 2007. ANSI/ASHRAE Standard 15–2007: Safety Standard for Refrigeration Systems. 

ASHRAE, 2013. ANSI/ASHRAE Standard 34–2013: Designation and Safety Classification of 

Refrigerants. 

Commented [A12]: Please incorporate the references as 

footnotes in the section of the preamble where referenced. Including 

the references in the appropriate section/sentence/table makes it 

easier for the public to refer to the papers as they read through the 

preamble. 
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ASHRAE, 2014. 2014 Handbook--Refrigeration. The American Society of Heating, 

Refrigerating, and Air-conditioning Engineers, Inc. Atlanta, Georgia, USA. ISBN 978-1-

936504-71-8; ISSN 1930-7195.

Blackwell et al., 2005. Risk Analysis for Alternative Refrigerant in Motor Vehicle Air 

Conditioning.

Blupura, 2015. SNAP Information Notice for R-290 in Water Coolers. October, 2015.

Chemours, 2015. Comment re: EPA proposed Rule: Greenhouse Gas Emissions and Fuel 

Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles; Phase 2. 

Submitted by Chemours. Oct 8, 2015. Docket number EPA-HQ-OAR-2014-0827-1279. 

Clayton Corporation, 2014. Re: Proposed SNAP Program Status Change Rule Docket ID No. 

EPA-HQ-OAR-2014 -0198, comment submitted by Clayton Corporation. October 20, 

2014. Docket number EPA-HQ-OAR-2014-0198-0133.

Clayton Corporation, 2015. Clayton Corporation Meeting with EPA Stratospheric Protection 

Division, December 8, 2015.

Colton & Poet, 2013. Document describing impacts of inadvertent discharges of 2-BTP.

Cooling Post, 2014. Trane first with 1233zd chiller, June 30, 2014. This document is accessible 

at www.coolingpost.com/world-news/trane-first-with-1233zd-chiller/.

Cooling Post, 2015. “Chemours to build HFO-1336mzz plant,” November 17, 2015. This 

document is accessible online at: http://www.coolingpost.com/world-news/chemours-tobuild-hfo-1336mzz-plant/.

DOE, 2014. Building Energy Codes Program. Energy Efficiency Standards for Federal 

Buildings. Available at: https://www.energycodes.gov/regulations/federal-buildingstandards. Last updated February 13, 2014.

DuPont, 2010. HFO-1234yf Low GWP Refrigerant - Information for Manufacturing and Service 

Facilities. Presented by Mary Koban, DuPont at the 2010 EAAC Conference. 

DuPont, 2014. Re: Protection of Stratospheric Ozone: Change of Listing Status for Certain 

Substitutes under the Significant New Alternatives Policy Program. Submitted by 

Michael Parr and Mack McFarland, DuPont. October 17, 2014. Docket number EPAHQ-OAR-2014-0198-0077.

Ecomall, 2015. Greenfreeze: A Revolution in Domestic Refrigeration. Accessible at: 

http://www.ecomall.com/greenshopping/greenfreeze.htm.

EIA, 2015. Petition requesting EPA to modify the status under the Significant New Alternatives 
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Page 256 of 289

Policy Program, of certain high-GWP chemicals in various end-uses. Submitted Oct. 6, 

2015. 

EPA, 2000. Halon Management Strategy of the United States of America, prepared in response 

to Decision X/7 that was taken at the Tenth Meeting of the Parties to the Montreal 

Protocol. July, 2000. 

EPA, 2009a. Technical Support Document for Endangerment and Cause or Contribute Findings 

for Greenhouse Gases under Section 202(a) of the Clean Air Act. December, 2009. This 

document is accessible at: 

http://www3.epa.gov/climatechange/Downloads/endangerment/Endangerment_TSD.pdf.

EPA, 2009b. Risk Assessment: PMN 07-0601. Available at: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0664-0036. 

EPA, 2013. Finding of Violation, issued to Enviro-Safe Refrigerants, Inc. June, 2013. This 

document is accessible at: http://www2.epa.gov/sites/production/files/2015-

07/documents/mailfov_envirosafe_06112013.pdf. 

EPA, 2015a. Technical support document that provides the Federal Register citations concerning 

data on the SNAP criteria for acceptable alternatives in the relevant end-uses.

EPA, 2015b. Draft Regulatory Impact Analysis: Proposed Rulemaking for Greenhouse Gas 

Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and 

Vehicles–Phase 2. EPA-420-D-15-900. June 2015. Available at 

http://www3.epa.gov/otaq/climate/documents/420d15900.pdf.

EPA, 2016a. Climate Benefits of the SNAP Program Proposed New Listings of Substitutes, 

Changes of Listing Status, and Reinterpretation of Unacceptability, 2016. 

EPA, 2016b. Table of Alternatives for End-Uses Considered in Proposed New Listings of 

Substitutes; Changes of Listing Status, and Reinterpretation of Unacceptability under the 

Significant New Alternatives Policy Program.

Eppendorf, 2015. SNAP Information Notice for R-170 and R-290 in Very Low Temperature 

Refrigeration. May, 2015.

EU, 2014. Regulation (EU) No 517/2014 of the European Parliament and of the Council of 16 

April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006. 

Available online at: http://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=uriserv:OJ.L_.2014.150.01.0195.01.ENG.

FAA, 2002. Federal Aviation Administration (FAA) Minimum Performance Standard for HandHeld Extinguishers. This document is accessible at: http://www.fire.tc.faa.gov/pdf/01-

37.pdf.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

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FAA, 2004. Advisory Circular 120-80: In-flight Fires. This document is accessible at: 

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/ed51f168

1e9d8c5e86256e4a00744607/$FILE/AC120-80.pdf.

FAA, 2011. Advisory Circular 20-42D, Hand Fire Extinguishers for Use in Aircraft. This 

document is accessible at: 

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC%2020-42D.pdf.

FAA, 2015. Halon Replacement Aviation Rulemaking Committee Final Report, 2015. 

Fomo, 2014. Comment Re: Proposed SNAP Program Status Change Rule Docket ID No. EPAHQ-OAR-2014 -0198, submitted by Dr. Thomas Fishback, Vice President, Research and 

Development, Fomo Products, Inc. October 16, 2014. Docket number EPA-HQ-OAR2014-0198-0139.

Fomo, 2015. “The Use of Solstice® Gas Blowing Agent (GBA) in Low-Pressure Spray 

Polyurethane Foam Applications,” Cline, Mojee and Bogdan, Mary, October, 2015. 

Polyurethane Industry Conference 2015.

FTOC, 2011. 2010 Report of the Rigid and Flexible Foams Technical Options Committee. This 

document is accessible at: 

http://ozone.unep.org/Assessment_Panels/TEAP/Reports/FTOC/FTOC-2010-AssessmentReport.pdf.

Gradient, 2008. Risk Assessment of Alternative Refrigerant HFO-1234yf, Prepared by Gradient 

for SAE International Cooperative Research Program 1234. December 12, 2008. 

Gradient, 2009. Risk Assessment for Alternative Refrigerants HFO-1234yf and R-744 (CO2) 

Phase III. Prepared by Gradient for SAE International Cooperative Research Program 

1234. December 17, 2009.

Gradient, 2013. Additional Risk Assessment of Alternative Refrigerant R-1234yf. Prepared by 

Gradient for SAE International Cooperative Research Program 1234-4. July 24, 2013. 

The Executive Summary of this document is accessible at: 

http://www.sae.org/standardsdev/tsb/cooperative/executivesummary.pdf. 

Honeywell & DuPont, 2008. HFO-1234yf: Low GWP Refrigerant Update. Mark Spatz, 

Honeywell and Barbara Minor, DuPont. Presentation at the International Refrigeration 

and Air Conditioning Conference at Purdue, July 14-17, 2008.

Honeywell, 2014. Comments on Proposed Rule: Protection of Stratospheric Ozone: Change of 

Listing Status for Certain Substitutes under the Significant New Alternatives Policy 

Program (Docket no. EPA–HQ–OAR–2014– 0198). October 20, 2014. Docket number 

EPA-HQ-OAR-2014-0198-0170.

Honeywell, 2015. Comment re: EPA proposed Rule: Greenhouse Gas Emissions and Fuel 
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Page 258 of 289

Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles; Phase 2. 

Submitted by George Koutsaftes, Honeywell. Oct 13, 2015. Docket number EPA-HQOAR-2014-0827-1279. 

Hossaini, et al., 2015. R. Hossaini, M. P. Chipperfield, S. A. Montzka, A. Rap, S. Dhomse, W. 

Feng. Efficiency of short-lived halogens at influencing climate through depletion of 

stratospheric ozone. Nature Geoscience, February 16, 2015. This document is accessible 

online at http://DOI: 10.1038/ngeo2363.

ICCT, 2015. International Council on Clean Transportation: Regulatory Considerations for 

Advancing Commercial Pickup and Van Efficiency Technology in the United States. 

Available online at: http://www.theicct.org/us-commercial-pickups-vans-efficiencytechnology. 

ICF, 2008. Air-Conditioning Refrigerant Charge Size to Passenger Compartment Volume Ratio 

Analysis. Confidential Memorandum Prepared for the U.S. Environmental Protection 

Agency. 2008.

ICF, 2009a. Revised Final Draft Assessment of the Potential Impacts of HFO–1234yf and the 

Associated Production of TFA on Aquatic Communities and Local Air Quality. 

ICF, 2009b. Risk Screen on Substitutes for CFC-12 in Motor Vehicle Air Conditioning: 

Substitute: HFO-1234yf. This document is accessible at: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0664-0038. 

ICF, 2010a. Summary of HFO–1234yf Emissions Assumptions. 

ICF, 2010b. Summary of Updates to the Vintaging Model that Impacted HFO–1234yf Emissions 

Estimates.

ICF, 2010c. Revised Assessment of the Potential Impacts of HFO–1234yf and the Associated 

Production of TFA on Aquatic Communities, Soil and Plants, and Local Air Quality. 

ICF, 2010d. Sensitivity Analysis CMAQ results on projected maximum TFA rainwater 

concentrations and maximum 8-hr ozone concentrations. 

ICF, 2014a. Assessment of the Potential Impact of Hydrocarbon Refrigerants on Ground Level 

Ozone Concentrations. February, 2014.

ICF, 2014b. Risk Screen on Substitutes for HCFC-22 in Residential and Light Commercial Air 

Conditioning and Heat Pumps; Substitute: Propane (R-290). 

ICF, 2014c. Risk Screen on Substitutes for HCFC-22 in Residential and Light Commercial Air 

Conditioning and Heat Pumps; Substitute: R-441A.

ICF, 2015a. Preliminary Cost Analysis for Regulatory Changes to the Listing Status of High-
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

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Page 259 of 289

GWP Alternatives used in Refrigeration and Air Conditioning, Foams, and Fire 

Suppression. 

ICF, 2015b. Draft Economic Impact Screening Analysis for Regulatory Changes to the Listing 

Status of High-GWP Alternatives used in Refrigeration and Air Conditioning, Foams, 

and Fire Suppression. 

ICF, 2015c. Significant New Alternatives Policy Program: Refrigeration and Air Conditioning 

Sector Risk Screen on Substitutes in Water Coolers Substitute: Propane (R-290).

ICF, 2015d. Significant New Alternatives Policy Program: Refrigeration and Air Conditioning 

Sector Risk Screen on Substitutes in Very Low Temperature Refrigeration Substitute: 

Propane (R-290) and Ethane (R-170). 

ICF, 2015e. Significant New Alternatives Policy Program: Refrigeration and Air Conditioning 

Sector Risk Screen on Substitutes in Commercial Ice Machines Substitute: Propane (R290).

ICF, 2015f. Significant New Alternatives Policy Program. Refrigeration and Air Conditioning 

Sector Risk Screen on Substitutes in Residential and Light Commercial Air Conditioning 

and Heat Pumps. Substitute: R-443A.

ICF, 2015g. Significant New Alternatives Policy Program. Refrigeration and Air Conditioning 

Sector Risk Screen on Substitutes in Cold Storage. Substitute: R-443A.

ICF, 2015h. Significant New Alternatives Policy Program. Refrigeration and Air Conditioning 

Sector Risk Screen on Substitutes in Commercial Comfort AC equipment. Substitute: R443A.

ICF, 2015i. Market Characterization for Fire Suppression, Comfort Cooling, Cold Storage, and 

Household Refrigeration Industries in the United States. Prepared for the U.S. 

Environmental Protection Agency. October 2015.

ICF, 2015j. Market Characterization of the U.S. Motor Vehicle Air Conditioning Industry, U.S. 

Foams Industry, U.S. Aerosols Industry, and U.S. Commercial Refrigeration Industry. 

July, 2015.

ICF, 2015k. Technical Support Document for Acceptability Listing of HFO-1234yf for Motor 

Vehicle Air Conditioning in Limited Heavy-Duty Applications.

ICF, 2015x. Significant New Alternatives Policy Program. Refrigeration and Air Conditioning 

Sector Risk Screen on Substitutes in Chillers and Cold Storage Warehouses. Substitute: 

Propylene (R-1270)

ICF, 2016a. Analysis of annual VOC emissions from the use of 2-BTP.
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ICF, 2016b. Significant New Alternatives Policy Program. Fire Extinguishing and Explosion 

Prevention Sector. Risk Screen on Substitutes as a Streaming Agent in Civil Aviation 

Applications. Substitute: 2-bromo-3,3,3-trifluoropropene (2-BTP). 

ICF, 2016c. Significant New Alternatives Policy Program. Fire Extinguishing and Explosion 

Prevention Sector. Risk Screen on Substitutes for Total Flooding Systems in Unoccupied 

Spaces. Substitute: 2-bromo-3,3,3-trifluoropropene (2-BTP).

INCHEM, 1996. International Programme on Chemical Safety. Environmental Health Criteria 

164. Methylene chloride, second edition. World Health Organization, 1996. This 

document is accessible online at: http://www.inchem.org/documents/ehc/ehc/ehc164.htm.

IPCC, 2007. Climate Change 2007: The Physical Science Basis. Contribution of Working Group 

I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. 

Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and 

H.L. Miller (eds.). Cambridge University Press, Cambridge, United Kingdom and New 

York, NY, USA. This document is accessible at: 

www.ipcc.ch/publications_and_data/ar4/wg1/en/contents.html. 

IPCC, 2013: Annex II: Climate System Scenario Tables [Prather, M., G. Flato, P. Friedlingstein, 

C. Jones, J.-F. Lamarque, H. Liao and P. Rasch (eds.)]. In: Climate Change 2013: The 

Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report 

of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, G.-K. Plattner, 

M. Tignor, S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. 

Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. 

This document is accessible at: http://www.ipcc.ch/report/ar5/wg1/.

IPCC/TEAP, 2005. Special Report: Safeguarding the Ozone Layer and the Global Climate 

System: Issues Related to Hydrofluorocarbons and Perfluorocarbons. Cambridge Univ 

Press, New York. This document is accessible at: https://www.ipcc.ch/pdf/specialreports/sroc/sroc_full.pdf.

JARN, 2015a. First Carrier AquaForce Chillers using HFO-1234ze, July 30, 2015. This 

document is accessible at: http://www.ejarn.com/news.aspx?ID=35619.

JARN, 2015b. Trane Exhibits First Air-cooled Chiller with Climate-friendly Refrigerant DR-55, 

September 21, 2015. This document is accessible at: 

www.ejarn.com/news.aspx?ID=36282. 

Kazil et al., 2014. Deposition and rainwater concentrations of trifluoroacetic acid in the United 

States from the use of HFO-1234yf. JGR-Atmospheres, 2014.

Luecken et al., 2009. Ozone and TFA impacts in North America from degradation of 2, 3, 3, 3-

tetrafluoropropene (HFO-1234yf), a potential greenhouse gas replacement. 

Environmental Science & Technology 2009. The document is accessible at: 

http://www.researchgate.net/profile/Robert_Waterland/publication/40481734_Ozone_an
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d_TFA_impacts_in_North_America_from_degradation_of_2333-

Tetrafluoropropene_(HFO1234yf)_a_potential_greenhouse_gas_replacement/links/00b7d514ca9595bf5e000000.pd

f.

Manitowoc, 2015. SNAP Information Notice, September, 2013. EPA SNAP Submittal -

Revision to Extend R-290 Use to Commercial Ice Machines, Manitowoc Ice, Inc. 

October, 2015.

Montzka, 2012. HFCs in the Atmosphere: Concentrations, Emissions and Impacts. 

ASHRAE/NIST Conference 2012. This document is accessible at: 

ftp://ftp.cmdl.noaa.gov/hats/papers/montzka/2012_pubs/Montzka_ASHRAE_2012.pdf.

NFPA, 2013. NFPA 10: Standard for Portable Fire Extinguisher (2013 edition). 

NFPA, 2015a. NFPA 2001: Standard on Clean agent Fire Extinguishing Systems (2015 edition). 

NFPA, 2015b. NFPA 12a: Standard on Halon 1301 Fire Extinguishing Systems (2015 edition). 

NRDC/IGSD, 2015. Petition for Change of Status of HFCs under Clean Air Act Section 612 

(Significant New Alternatives Policy). Submitted Oct. 6, 2015.

ORNL, 2015. ORNL’s JUMP Challenge: JUMP in to Advance Tech Innovation! Presented by 

Brian Fricke, Oak Ridge National Laboratory. November 17, 2015.

Patten and Wuebbles, 2010. “Atmospheric Lifetimes and Ozone Depletion Potentials of trans-1-

chloro-3,3,3-trichloropropylene and trans-1,2-dichloroethylene in a three-dimensional 

model.” Atmos. Chem. Phys., 10, 10867–10874, 2010.

Patten et al., 2012. Correction to “OH reaction rate constant, IR absorption spectrum, ozone 

depletion potentials and global warming potentials of 2-bromo-3,3,3-trifluoropropene,” J. 

Geophys. Res., 117, D22301, doi:10.1029/2012JD019051.

RTOC, 2015. 2014 Report of the Refrigeration, Air-Conditioning and Heat Pumps Technical 

Options Committee. 

This document is accessible at: http://ozone.unep.org/sites/ozone/files/documents/RTOCAssessment-Report-2014.pdf. 

SAE, 2013. SAE International Cooperative Research Project CRP1234-4 on R-1234yf Safety, 

Finishes Work and Presents Conclusions. This document is accessible at: 

http://www.sae.org/servlets/pressRoom?OBJECT_TYPE=PressReleases&PAGE=showR

elease&RELEASE_ID=2146.

Sleasman, K. and Biggs, M., 2015. Lessons learned from the Federal Partners Workgroup on 

Spray Polyurethane Foam (SPF), presented at the Center for the Polyurethanes Industry 

Technical Conference, October, 2015.
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TEAP, 2013. Report of the Technology and Economic Assessment Panel, Volume 2: Decision 

XXIV/7 Task Force Report, Additional Information on Alternatives to ODS. September, 

2013. This document is accessible at: 

http://ozone.unep.org/Assessment_Panels/TEAP/Reports/TEAP_Reports/TEAP_TaskForc

e%20XXIV-7-September2013.pdf.

TEAP, 2015. 2014 Assessment Report of the Technology and Economic Assessment Panel. This 

document is accessible at: http://conf.montreal-protocol.org/meeting/oewg/oewg36/presession/Background%20Documents%20are%20available%20in%20English%20o

nly/TEAP_Assessment_report_2014.pdf.

TEAP/HTOC, 2015. 2014 Report of the Halons Technical Options Committee (Vol. 1). This 

document is accessible at: 

http://ozone.unep.org/en/Assessment_Panels/TEAP/Reports/HTOC/HTOC%202014%20

Assessment%20Report.pdf.

TEAP/RTOC, 2015. 2014 Report of the Refrigeration, Air-Conditioning and Heat Pumps 

Technical Options Committee. 

This document is accessible at: http://ozone.unep.org/sites/ozone/files/documents/RTOCAssessment-Report-2014.pdf. 

The White House, 2013. President's Climate Action Plan. This document is accessible at: 

https://www.whitehouse.gov/sites/default/files/image/president27sclimateactionplan.pdf.

The White House, 2015. Fact Sheet: Obama Administration and Private-Sector Leaders 

Announce Ambitious Commitments and Robust Progress to Address Potent Greenhouse 

Gases, October 15, 2015. Accessible at https://www.whitehouse.gov/the-pressoffice/2015/10/15/fact-sheet-obama-administration-and-private-sector-leadersannounce.

Trane, 2015. Trane® SintesisTM Air-cooled Chillers. This document is accessible at: 

http://www.trane.com/content/dam/Trane/Commercial/global/productssystems/equipment/chillers/air-cooled/TRANE_Sintesis_Brochure.pdf. 

U.S. DOE, 2014. Building Energy Codes Program. Energy Efficiency Standards for Federal 

Buildings. This document is accessible at: 

https://www.energycodes.gov/regulations/federal-building-standards. Last updated 

February 13, 2014. 

UL, 2004. Standard 711 - Rating and Testing of Fire Extinguishers. This document is accessible 

at: http://ulstandards.ul.com/standard/?id=711_7.

UL, 2005. Standard 2129 - Halocarbon Clean Agent Fire Extinguishers. This document is 

accessible at: http://ulstandards.ul.com/standard/?id=2129_2. 
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UL, 2008. Standard 399 - Standard for Drinking-Water Coolers. A summary of this document is 

accessible at: http://ulstandards.ul.com/standard/?id=399_7.

UL, 2009. Standard 563 - Standard for Ice Makers. A summary of this document is accessible at: 

http://ulstandards.ul.com/standard/?id=563.

UL, 2010. Standard 471 - Standard for Commercial Refrigerators and Freezers. A summary of 

this document is accessible at: http://ulstandards.ul.com/standard/?id=471_10.

UNEP, 2011. HFCs: A Critical Link in Protecting Climate and the Ozone Layer, A UNEP 

Synthesis Report. November, 2011. This document is accessible at: 

www.unep.org/dewa/portals/67/pdf/HFC_report.pdf.

VASA, 2014. Two injured in Perth HC refrigerant explosion. May 24, 2014. This document is 

accessible at: http://www.vasa.org.au/two-injured-in-perth-hc-refrigerant-explosion/.

Velders, G. J. M., D. W. Fahey, J. S. Daniel, M. McFarland, S. O. Andersen (2009). “The large 

contribution of projected HFC emissions to future climate forcing.” Proceedings of the 

National Academy of Sciences USA 106: 10949–10954. 

Wang D., Olsen S., Wuebbles D. 2011. “Preliminary Report: Analyses of tCFP’s Potential 

Impact on Atmospheric Ozone.” Department of Atmospheric Sciences. University of 

Illinois, Urbana, IL. September 26, 2011. 

Wickham, 2002. Status of Industry Efforts to Replace Halon Fire Extinguishing Agents. March, 

2002.

WMO, 2007. Scientific Assessment of Ozone Depletion: 2006, Global Ozone Research and 

Monitoring Project. Geneva, Switzerland, 2007. This document is accessible at: 

http://www.esrl.noaa.gov/csd/assessments/ozone/2006/report.html.

WMO, 2011. Scientific Assessment of Ozone Depletion: 2010, Global Ozone Research and 

Monitoring Project. Geneva, Switzerland, 2011. This document is accessible at: 

http://www.esrl.noaa.gov/csd/assessments/ozone/2010/report.html.
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List of Subjects in 40 CFR Part 82

Environmental protection, Administrative practice and procedure, Air pollution control, 

Incorporation by reference, Recycling, Reporting and recordkeeping requirements, Stratospheric 

ozone layer.

Dated: 

Gina McCarthy,

Administrator.
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For the reasons set forth in the preamble, EPA proposes to amend 40 CFR part 82 as follows:

PART 82—PROTECTION OF STRATOSPHERIC OZONE

1. The authority citation for part 82 continues to read as follows:

Authority: 42 U.S.C. 7414, 7601, 7671 - 7671q.

Subpart G – Significant New Alternatives Policy Program

2. Appendix B to subpart G of part 82 is amended by adding three new entries at the end of the 

table titled “Refrigerants—Acceptable Subject to Use Conditions.” The additions read as

follows:

APPENDIX B TO SUBPART G OF PART 82—SUBSTITUTES SUBJECT TO USE 

RESTRICTIONS AND UNACCEPTABLE SUBSTITUTES

REFRIGERANTS—ACCEPTABLE SUBJECT TO USE CONDITIONS

Application Substitute Decision Conditions Comments

* * * * * * *

Motor vehicle 

air conditioning 

(newly 

manufactured 

medium-duty 

passenger 

vehicles)

HFO-1234yf Acceptable 

subject to 

use 

conditions

As of [insert 30 days after 

publication of final rule]:

(1) HFO-1234yf MVAC systems 

must adhere to all of the safety 

requirements of SAE J639 (adopted 

2011), including requirements for a 

flammable refrigerant warning label, 

high-pressure compressor cutoff 

switch and pressure relief devices, 

and unique fittings. For connections 

with refrigerant containers for use in 

professional servicing, use fittings 

must be consistent with SAE J2844 

(revised October 2011).

(2) Manufacturers must conduct 

Failure Mode and Effect Analysis 

(FMEA) as provided in SAE J1739 

(adopted 2009). Manufacturers must 

keep the FMEA on file for at least 

three years from the date of creation.

Additional training for 

service technicians 

recommended.

HFO-1234yf is also 

known as 2,3,3,3-

tetrafluoro-prop-1-ene 

(CAS. Reg. No. 754-

12-1). 

Motor vehicle 

air conditioning 

(newly 

manufactured 

heavy-duty 

HFO-1234yf Acceptable 

subject to 

use 

conditions

As of [insert 30 days after 

publication of final rule]:

(1) HFO-1234yf MVAC systems 

must adhere to all of the safety 

requirements of SAE J639 (adopted 

Additional training for 

service technicians 

recommended.

HFO-1234yf is also 

known as 2,3,3,3-
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pickup trucks) 2011), including requirements for a 

flammable refrigerant warning label, 

high-pressure compressor cutoff 

switch and pressure relief devices, 

and unique fittings. For connections 

with refrigerant containers for use in 

professional servicing, use fittings 

must be consistent with SAE J2844 

(revised October 2011).

(2) Manufacturers must conduct 

Failure Mode and Effect Analysis 

(FMEA) as provided in SAE J1739 

(adopted 2009). Manufacturers must 

keep the FMEA on file for at least 

three years from the date of creation.

tetrafluoro-prop-1-ene 

(CAS No 754-12-1). 

Motor vehicle 

air conditioning 

(newly 

manufactured 

complete 

heavy-duty vans 

only)

HFO-1234yf Acceptable 

subject to 

use 

conditions

As of [insert 30 days after 

publication of final rule]:

(1) HFO-1234yf MVAC systems 

must adhere to all of the safety 

requirements of SAE J639 (adopted 

2011), including requirements for a

flammable refrigerant warning label, 

high-pressure compressor cutoff 

switch and pressure relief devices, 

and unique fittings. For connections 

with refrigerant containers for use in 

professional servicing, use fittings 

must be consistent with SAE J2844 

(revised October 2011).

(2) Manufacturers must conduct 

Failure Mode and Effect Analysis 

(FMEA) as provided in SAE J1739 

(adopted 2009). Manufacturers must 

keep the FMEA on file for at least 

three years from the date of creation.

Additional training for 

service technicians 

recommended.

HFO-1234yf is also 

known as 2,3,3,3-

tetrafluoro-prop-1-ene 

(CAS No 754-12-1). 

HFO-1234yf is 

acceptable for complete 

heavy-duty vans. 

Complete heavy-duty 

vans are not altered by a 

secondary or tertiary 

manufacturer.

* * * * *

3. Appendix K to subpart G of part 82 is amended by revising the text in the table titled “FoamBlowing Unacceptable Substitutes”, in the column titled “Decision” to read as follows:

APPENDIX K TO SUBPART G OF PART 82--SUBSTITUTES SUBJECT TO USE RESTRICTIONS AND 

UNACCEPTABLE SUBSTITUTES LISTED IN THE JULY 22, 2002, FINAL RULE EFFECTIVE AUGUST 

21, 2002
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FOAM BLOWING--UNACCEPTABLE SUBSTITUTES

End-use Substitute Decision Comments

Replacements for HCFC-141b 

in the following rigid 

polyurethane/ 

polyisocyanurate applications:

- Boardstock

- Appliance

- Spray

HCFC-22, HCFC142b and blends 

thereof

Unacceptable

Closed cell foam 

products and 

products containing 

closed cell foams 

manufactured with 

these substitutes on 

or before [INSERT 

DATE ONE YEAR 

AFTER 

PUBLICATION OF 

FINAL RULE] may 

be used after that 

date.

Alternatives exist with lower or 

zero-ODP. 

All foam end-uses HCFC-124 Unacceptable

Closed cell foam 

products and 

products containing 

closed cell foams 

manufactured with 

this substitute on or 

before [INSERT 

DATE ONE YEAR 

AFTER 

PUBLICATION OF 

FINAL RULE] may 

be used after that 

date.

Alternatives exist with lower or 

zero-ODP.

4. Appendix M to subpart G of part 82 is amended by revising the text in the table titled “Foam 

Blowing--Unacceptable Substitutes”, in the column titled “Decision” to read as follows:

APPENDIX M TO SUBPART G - UNACCEPTABLE SUBSTITUTES LISTED IN THE SEPTEMBER 30, 2004

FINAL RULE, EFFECTIVE NOVEMBER 29, 2004.

FOAM BLOWING--UNACCEPTABLE SUBSTITUTES

End-use Substitute Decision Comments

All foam end-uses:

-rigid polyurethane and 

HCFC-141b Unacceptable

Closed cell foam 

Alternatives exist with lower or 

zero-ODP.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 268 of 289

polyisocyanurate laminated 

boardstock

-rigid polyurethane appliance

-rigid polyurethane spray and 

commercial refrigeration, and 

sandwich panels

-rigid polyurethane slabstock and 

other foams

-polystyrene extruded insulation 

boardstock and billet

-phenolic insulation board and 

bunstock

-flexible polyurethane

-polystyrene extruded sheet

Except for:

-space vehicle

-nuclear 

-defense

-research and development for foreign 

customers

products and 

products 

containing closed 

cell foams 

manufactured 

with this 

substitute on or 

before [INSERT 

DATE ONE 

YEAR AFTER 

PUBLICATION 

OF FINAL 

RULE] may be 

used after that 

date.

1Exemptions for specific applications are identified in the list of acceptable substitutes.

5. Appendix Q to subpart G of part 82 is amended by revising the text in the table titled “Foam 

Blowing--Unacceptable Substitutes”, in the column titled “Decision” to read as follows:

APPENDIX Q TO SUBPART G OF PART 82 - UNACCEPTABLE SUBSTITUTES LISTED IN 

THE MARCH 28, 2007 FINAL RULE, EFFECTIVE MAY 29, 2007.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 269 of 289

FOAM BLOWING UNACCEPTABLE SUBSTITUTES

End use Substitute Decision Further Information

- Rigid polyurethane commercial 

refrigeration

- Rigid polyurethane sandwich panels

- Rigid polyurethane slabstock and other 

foams

HCFC-22,

HCFC-142b as 

substitutes for 

HCFC-141b

Unacceptable1

Closed cell foam 

products and 

products 

containing closed 

cell foams 

manufactured with 

these substitutes

on or 

before [INSERT 

DATE ONE 

YEAR AFTER 

PUBLICATION 

OF FINAL 

RULE] may be 

used after that 

date.

Alternatives exist with lower 

or zero-ODP.

-Rigid polyurethane and 

polyisocyanurate laminated boardstock

-Rigid polyurethane appliance

-Rigid polyurethane spray and 

commercial refrigeration, and sandwich 

panels

-Rigid polyurethane slabstock and other 

foams

-Polystyrene extruded insulation 

boardstock and billet

-Phenolic insulation board and bunstock

-Flexible polyurethane

-Polystyrene extruded sheet

HCFC-22,

HCFC-142b as 

substitutes for 

CFCs

Unacceptable2

Closed cell foam 

products and 

products 

containing closed 

cell foams 

manufactured with 

these substitutes

on or 

before [INSERT 

DATE ONE 

YEAR AFTER 

PUBLICATION 

OF FINAL 

RULE] may be 

used after that 

date.

Alternatives exist with lower 

or zero-ODP.

1For existing users of HCFC-22 and HCFC-142b as of November 4, 2005 other than in marine applications, the 

unacceptability determination is effective on March 1, 2008; for existing users of HCFC-22 and HCFC-142b as of 

November 4, 2005 in marine applications, including marine flotation foam, the unacceptability determination is 

effective on September 1, 2009. For an existing user of HCFC-22 or HCFC-142b that currently operates in only one 

facility that it does not own, and is scheduled to transition to a non-ODS, flammable alternative to coincide with a 

move to a new facility and installation of new process equipment that cannot be completed by March 1, 2008, the 

unacceptability determination is effective January 1, 2010. 

2 For existing users of HCFC-22 and HCFC-142b in polystyrene extruded insulation boardstock and billet and the 

other foam end uses, as of November 4, 2005, the unacceptability determination is effective on January 1, 2010. 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 270 of 289

6. Appendix U to subpart G of part 82 is amended by revising the text in the column titled 

“Decision” in the fifth table to read as follows:

APPENDIX U TO SUBPART G OF PART 82-UNACCEPTABLE SUBSTITUTES AND SUBSTITUTES 

SUBJECT TO USE RESTRICTIONS LISTED IN THE JULY 20, 2015 FINAL RULE, EFFECTIVE SEPTEMBER 

18, 2015

* * * * *

UNACCEPTABLE SUBSTITUTES

End-use Substitute Decision Further Information

All Foam 

Blowing End-uses

HCFC-141b and 

blends thereof

Unacceptable effective September 

18, 2015Closed cell foam products 

and products containing closed cell 

foams manufactured with these

substitutes on or before [INSERT 

DATE ONE YEAR AFTER 

PUBLICATION OF FINAL 

RULE] may be used after that date.

HCFC-141b has an ozone 

depletion potential of 0.11 under 

the Montreal Protocol. EPA 

previously found HCFC-141b 

unacceptable in all foam blowing 

end-uses (appendix M to subpart 

G of 40 CFR part 82). HCFC141b has an ozone depletion 

potential (ODP) of 0.11. 

All Foam 

Blowing end-uses

HCFC-22, HCFC142b, and blends 

thereof

Unacceptable effective September 

18, 2015 . Closed cell foam products 

and products containing closed cell 

foams manufactured with these

substitutes on or before [INSERT 

DATE ONE YEAR AFTER 

PUBLICATION OF FINAL 

RULE] may be used after that date.

Use or introduction into 

interstate commerce of virgin 

HCFC-22 and HCFC-142b for 

foam blowing is prohibited after 

January 1, 2010 under EPA’s 

regulations at 40 CFR part 82 

subpart A unless used, recovered, 

and recycled. These compounds 

have ODPs of 0.055 and 0.065,

respectively. 

Flexible 

Polyurethane

HFC-134a, HFC245fa, HFC-365mfc, 

and blends thereof

Unacceptable as of January 1, 2017 

except where allowed under a 

narrowed use limit.

These foam blowing agents have 

global warming potentials 

(GWPs) ranging from 725 to 

1,430. Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Polystyrene: 

Extruded Sheet

HFC-134a, HFC245fa, HFC-365mfc, 

and blends thereof;

Formacel TI, and 

Formacel Z-6

Unacceptable as of January 1, 2017 

except where allowed under a 

narrowed use limit.

Closed cell foam products and 

products containing closed cell 

foams manufactured with these

substitutes on or before [INSERT 

DATE ONE YEAR AFTER 

PUBLICATION OF FINAL 

RULE] may be used after that date.

These foam blowing agents have 

GWPs ranging from higher than 

370 to approximately 1,500. 

Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Phenolic 

Insulation Board 

HFC-143a, HFC134a, HFC-245fa, Unacceptable as of January 1, 2017 

except where allowed under a 

These foam blowing agents have 

GWPs ranging from 725 to 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 271 of 289

and Bunstock HFC-365mfc, and 

blends thereof

narrowed use limit. 

Closed cell foam products and 

products containing closed cell 

foams manufactured with these

substitutes on or before [INSERT 

DATE ONE YEAR AFTER 

PUBLICATION OF FINAL 

RULE] may be used after that date.

4,470. Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Integral Skin 

Polyurethane

HFC-134a, HFC245fa, HFC-365mfc, 

and blends thereof;

Formacel TI, and 

Formacel Z-6

Unacceptable as of January 1, 2017

except where allowed under a 

narrowed use limit.

Closed cell foam products and 

products containing closed cell 

foams manufactured with these

substitutes on or before [INSERT 

DATE ONE YEAR AFTER 

PUBLICATION OF FINAL 

RULE] may be used after that date.

These foam blowing agents have 

GWPs ranging from higher than 

370 to approximately 1,500. 

Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Rigid 

Polyurethane: 

Slabstock and 

Other

HFC-134a, HFC245fa, HFC-365mfc 

and blends thereof; 

Formacel TI, and 

Formacel Z-6

Unacceptable as of January 1, 2019

except where allowed under a 

narrowed use limit.

Closed cell foam products and 

products containing closed cell 

foams manufactured with these

substitutes on or before January 1, 

2019 may be used after that date.

These foam blowing agents have 

GWPs ranging from higher than 

370 to approximately 1,500. 

Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Rigid 

Polyurethane and 

Polyisocyanurate 

Laminated 

Boardstock

HFC-134a, HFC245fa, HFC-365mfc 

and blends thereof 

Unacceptable as of January 1, 2017

except where allowed under a 

narrowed use limit.

Closed cell foam products and

products containing closed cell 

foams manufactured with these

substitutes on or before [INSERT 

DATE ONE YEAR AFTER 

PUBLICATION OF FINAL 

RULE] may be used after that date.

These foam blowing agents have 

GWPs ranging from 725 to 

1,430. Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Rigid 

Polyurethane: 

Marine Flotation 

Foam

HFC-134a, HFC245fa, HFC-365mfc 

and blends thereof; 

Formacel TI, and 

Formacel Z-6

Unacceptable as of January 1, 2020 

except where allowed under a 

narrowed use limit.

Closed cell foam products and 

products containing closed cell 

foams manufactured with these

substitutes on or before January 1, 

2020 may be used after that date.

These foam blowing agents have 

GWPs ranging from higher than 

370 to approximately 1,500. 

Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Rigid 

Polyurethane: 

Commercial 

Refrigeration and 

Sandwich Panels

HFC-134a, HFC245fa, HFC-365mfc, 

and blends thereof;

Formacel TI, and 

Formacel Z-6

Unacceptable as of January 1, 2020

except where allowed under a 

narrowed use limit.

Closed cell foam products and 

products containing closed cell 

foams manufactured with these

substitutes on or before January 1, 

2020 may be used after that date.

These foam blowing agents have 

GWPs ranging from higher than 

370 to approximately 1,500. 

Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Rigid 

Polyurethane: 

HFC-134a, HFC245fa, HFC-365mfc Unacceptable as of January 1, 2020 

except where allowed under a 

These foam blowing agents have 

GWPs ranging from higher than 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 272 of 289

* * * * *

7. Subpart G of part 82 is amended by adding Appendix V, to read as follows:

Appendix V to Subpart G of Part 82—Substitutes Subject to Use Restrictions and Unacceptable 

Substitutes Listed in the [INSERT DATE OF PUBLICATION OF FINAL RULE IN THE 

FEDERAL REGISTER] Final Rule

REFRIGERANTS—ACCEPTABLE SUBJECT TO USE CONDITIONS

End-use Substitute Decision Use Conditions Further Information

Commercial 

ice machines 

(selfcontained) 

(new only)

Propane (R290)Acceptable, 

subject to 

use 

conditions

As of [insert 30 days after 

publication of final rule]:

This refrigerant may be used only in 

new equipment designed 

specifically and clearly identified 

for the refrigerant--i.e., this 

refrigerant may not be used as a 

conversion or “retrofit” refrigerant 

for existing equipment.

This refrigerant may be used only in 

self-contained commercial ice 

machines that meet all requirements 

listed in Supplement SA to the 8th 

edition of Underwriters 

Laboratories (UL) Standard 563, 

Applicable OSHA requirements 

at 29 CFR part 1910 must be 

followed, including those at 29 

CFR 1910.106 (flammable and 

combustible liquids), 1910.110 

(storage and handling of 

liquefied petroleum gases), 

1910.157 (portable fire 

extinguishers), and 1910.1000 

(toxic and hazardous 

substances).

Proper ventilation should be 

maintained at all times during 

the manufacture and storage of 

equipment containing 

hydrocarbon refrigerants 

through adherence to good 

Appliance and blends thereof; 

Formacel TI, and 

Formacel Z-6

narrowed use limit. 

Closed cell foam products and 

products containing closed cell 

foams manufactured with these

substitutes on or before January 1, 

2020 may be used after that date.

370 to approximately 1,500. 

Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Polystyrene: 

Extruded 

Boardstock and 

Billet

HFC-134a, HFC245fa, HFC-365mfc, 

and blends thereof;

Formacel TI, 

Formacel B, and 

Formacel Z-6

Unacceptable as of January 1, 2021

except where allowed under a 

narrowed use limit.

Closed cell foam products and 

products containing closed cell 

foams manufactured with these

substitutes on or before January 1, 

2021 may be used after that date.

These foam blowing agents have 

GWPs ranging from higher than 

140 to approximately 1,500. 

Other substitutes will be

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.

Polyolefin HFC-134a, HFC245fa, HFC-365mfc, 

and blends thereof; 

Formacel TI, and 

Formacel Z-6

Unacceptable as of January 1, 2020 

except where allowed under a 

narrowed use limit.

Closed cell foam products and 

products containing closed cell 

foams manufactured with these 

substitutes on or before January 1, 

2020 may be used after that date.

These foam blowing agents have 

GWPs ranging from higher than 

370 to approximately 1,500. 

Other substitutes will be 

available for this end-use with 

lower overall risk to human 

health and the environment by 

the status change date.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 273 of 289

dated July 31, 2009. In cases where 

this rule includes requirements 

more stringent than those of the 8th 

edition of UL 563, the equipment 

must meet the requirements of the 

final rule in place of the 

requirements in the UL Standard.

The charge size must not exceed 

150 g (5.29 oz) in each refrigerant 

circuit of a commercial ice 

machine. 

As provided in clauses SA6.1.1 and 

SA6.1.2 of UL Standard 563, 8th

edition, the following markings 

must be attached at the locations 

provided and must be permanent: 

(a) “DANGER—Risk of Fire or 

Explosion. Flammable 

Refrigerant Used. Do Not Use 

Mechanical Devices To Defrost 

Refrigerator. Do Not Puncture 

Refrigerant Tubing.” This 

marking must be provided on or 

near any evaporators that can be 

contacted by the consumer.

(b) “DANGER—Risk of Fire or 

Explosion. Flammable 

Refrigerant Used. To Be 

Repaired Only By Trained 

Service Personnel. Do Not 

Puncture Refrigerant Tubing.” 

This marking must be located 

near the machine compartment.

(c) “CAUTION—Risk of Fire or 

Explosion. Flammable 

Refrigerant Used. Consult 

Repair Manual/Owner’s Guide 

Before Attempting To Service 

This Product. All Safety 

Precautions Must be Followed.” 

This marking must be located 

near the machine compartment.

(d) “CAUTION—Risk of Fire or 

Explosion. Dispose of Properly 

In Accordance With Federal Or 

Local Regulations. Flammable 

Refrigerant Used.” This marking 

must be provided on the exterior 

of the refrigeration equipment.

(e) “CAUTION—Risk of Fire or 

Explosion Due To Puncture Of 

Refrigerant Tubing; Follow 

Handling Instructions Carefully. 

manufacturing practices as per 

29 CFR 1910.106. If refrigerant 

levels in the air surrounding the 

equipment rise above one-fourth 

of the lower flammability limit, 

the space should be evacuated 

and re-entry should occur only 

after the space has been 

properly ventilated.

Technicians and equipment 

manufacturers should wear 

appropriate personal protective 

equipment, including chemical 

goggles and protective gloves, 

when handling these 

refrigerants. Special care should 

be taken to avoid contact with 

the skin since these refrigerants, 

like many refrigerants, can 

cause freeze burns on the skin. 

A Class B dry powder type fire 

extinguisher should be kept 

nearby.

Technicians should only use 

spark-proof tools when working 

on refrigerators and freezers 

with these refrigerants.

Any recovery equipment used 

should be designed for 

flammable refrigerants. 

Any refrigerant releases should 

be in a well-ventilated area, 

such as outside of a building.

Only technicians specifically 

trained in handling flammable 

refrigerants should service 

refrigerators and freezers 

containing these refrigerants. 

Technicians should gain an 

understanding of minimizing 

the risk of fire and the steps to 

use flammable refrigerants 

safely.

Room occupants should 

evacuate the space immediately 

following the accidental release 

of this refrigerant.

If a service port is added then 

retail food refrigerators and 

freezers using these refrigerants 

should have service aperture 

fittings that differ from fittings 

used in equipment or containers 

using non-flammable 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 274 of 289

Flammable Refrigerant Used.” 

This marking must be provided 

near all exposed refrigerant 

tubing.

All of these markings must be in 

letters no less than 6.4 mm (1/4 

inch) high. 

The equipment must have red 

Pantone Matching System (PMS) 

#185 marked pipes, hoses, or other 

devices through which the 

refrigerant passes, to indicate the 

use of a flammable refrigerant. This 

color must be applied at all service 

ports and other parts of the system 

where service puncturing or other 

actions creating an opening from 

the refrigerant circuit to the 

atmosphere might be expected and 

must extend a minimum of one (1) 

inch in both directions from such 

locations.

refrigerant. “Differ” means that 

either the diameter differs by at 

least 1/16 inch or the thread 

direction is reversed (i.e., righthanded vs. left-handed). These 

different fittings should be 

permanently affixed to the unit 

at the point of service and 

maintained until the end-of-life 

of the unit, and should not be 

accessed with an adaptor.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 275 of 289

Very low 

temperature 

refrigeration 

equipment 

(new only)

Propane (R290)Acceptable, 

subject to 

use 

conditions

As of [insert 30 days after 

publication of final rule]:

This refrigerant may be used only in 

new equipment designed 

specifically and clearly identified 

for the refrigerant--i.e., this 

refrigerant may not be used as a 

conversion or “retrofit” refrigerant 

for existing equipment.

This refrigerant may only be used in 

equipment that meets all 

requirements in Supplement SB to 

the 10th edition of the Underwriters 

Laboratories (UL) Standard for 

Commercial Refrigerators and 

Freezers, UL 471, dated November 

24, 2010. In cases where the final 

rule includes requirements more 

stringent than those of the 10th

edition of UL 471, the appliance 

must meet the requirements of the 

final rule in place of the 

requirements in the UL Standard.

The charge size for the equipment 

must not exceed 150 grams (5.29 

ounces) in each refrigerant circuit 

of the very low temperature 

refrigeration equipment.

As provided in clauses SB6.1.2 to 

SB6.1.5 of UL Standard 471, 10th

edition, the following markings 

must be attached at the locations 

provided and must be permanent:

(a) “DANGER—Risk of Fire or 

Explosion. Flammable 

Refrigerant Used. Do Not Use 

Mechanical Devices To Defrost 

Refrigerator. Do Not Puncture 

Refrigerant Tubing.” This 

marking must be provided on 

or near any evaporators that can 

be contacted by the consumer.

(b) “DANGER—Risk of Fire or 

Explosion. Flammable 

Refrigerant Used. To Be 

Repaired Only By Trained 

Service Personnel. Do Not 

Puncture Refrigerant Tubing.” 

This marking must be located 

near the machine compartment.

(c) “CAUTION—Risk of Fire or 

Explosion. Flammable 

Applicable OSHA requirements 

at 29 CFR part 1910 must be 

followed, including those at 29 

CFR 1910.94 (ventilation) and 

1910.106 (flammable and 

combustible liquids), 1910.110 

(storage and handling of 

liquefied petroleum gases), 

1910.157 (portable fire 

extinguishers), and 1910.1000 

(toxic and hazardous 

substances).

Proper ventilation should be 

maintained at all times during 

the manufacture and storage of 

equipment containing 

hydrocarbon refrigerants 

through adherence to good 

manufacturing practices as per 

29 CFR 1910.106. If refrigerant 

levels in the air surrounding the 

equipment rise above one-fourth 

of the lower flammability limit, 

the space should be evacuated 

and re-entry should occur only 

after the space has been 

properly ventilated.

Technicians and equipment 

manufacturers should wear 

appropriate personal protective 

equipment, including chemical 

goggles and protective gloves, 

when handling ethane. Special 

care should be taken to avoid 

contact with the skin since 

ethane, like many refrigerants, 

can cause freeze burns on the 

skin. 

A Class B dry powder type fire 

extinguisher should be kept 

nearby.

Technicians should only use 

spark-proof tools when working 

on equipment with flammable 

refrigerants.

Any recovery equipment used 

should be designed for 

flammable refrigerants. 

Any refrigerant releases should 

be in a well-ventilated area, 

such as outside of a building.

Only technicians specifically 

trained in handling flammable 

refrigerants should service 

equipment containing ethane. 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 276 of 289

Refrigerant Used. Consult 

Repair Manual/Owner’s Guide 

Before Attempting To Service 

This Product. All Safety 

Precautions Must be 

Followed.” This marking must 

be located near the machine 

compartment.

(d) “CAUTION—Risk of Fire or 

Explosion. Dispose of Properly 

In Accordance With Federal Or 

Local Regulations. Flammable 

Refrigerant Used.” This 

marking must be provided on 

the exterior of the refrigeration 

equipment.

(e) “CAUTION—Risk of Fire or 

Explosion Due To Puncture Of 

Refrigerant Tubing; Follow 

Handling Instructions 

Carefully. Flammable 

Refrigerant Used.” This 

marking must be provided near 

all exposed refrigerant tubing.

All of these markings must be in 

letters no less than 6.4 mm (1/4 

inch) high. 

The equipment must have red PMS 

#185 marked pipes, hoses, or other 

devices through which the 

refrigerant passes, to indicate the 

use of a flammable refrigerant. This 

color must be applied at all service 

ports and other parts of the system 

where service puncturing or other 

actions creating an opening from 

the refrigerant circuit to the 

atmosphere might be expected and 

must extend a minimum of one (1) 

inch in both directions from such 

locations.

Technicians should gain an 

understanding of minimizing 

the risk of fire and the steps to 

use flammable refrigerants 

safely

Room occupants should 

evacuate the space immediately 

following the accidental release 

of this refrigerant.

If a service port is added then 

retail food refrigerators and 

freezers using these refrigerants 

should have service aperture 

fittings that differ from fittings 

used in equipment or containers 

using non-flammable 

refrigerant. “Differ” means that 

either the diameter differs by at 

least 1/16 inch or the thread 

direction is reversed (i.e., righthanded vs. left-handed). These 

different fittings should be 

permanently affixed to the unit 

at the point of service and 

maintained until the end-of-life 

of the unit, and should not be 

accessed with an adaptor.

Very low temperature 

equipment using propane may 

also use another acceptable 

refrigerant substitute in a 

separate refrigerant circuit or 

stage (e.g., one temperature 

stage with propane and a second 

stage with ethane).

Water 

coolers (new 

only)

Propane (R290)Acceptable, 

subject to 

use 

conditions

As of [insert 30 days after 

publication of final rule]:

This refrigerant may be used only in 

new equipment designed 

specifically and clearly identified 

for the refrigerant--i.e., this 

refrigerant may not be used as a 

conversion or “retrofit” refrigerant 

for existing equipment. 

This refrigerant may be used only in 

water coolers that meet all 

Applicable OSHA requirements 

at 29 CFR part 1910 must be 

followed, including those at 29 

CFR 1910.94 (ventilation) and 

1910.106 (flammable and 

combustible liquids), 1910.110 

(storage and handling of 

liquefied petroleum gases), 

1910.157 (portable fire 

extinguishers), and 1910.1000 

(toxic and hazardous 

substances).
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 277 of 289

requirements listed in Supplement 

SB to the 7th edition of UL 

Standard 399, dated August 22, 

2008. In cases where the rule 

includes requirements more 

stringent than those of the 7th 

edition of UL Standard 399, the

appliance must meet the 

requirements of the final rule in 

place of the requirements in the UL 

Standard.

The charge size must not exceed 

150 grams (5.29 ounces) per 

refrigerant circuit in the water 

cooler.

The equipment must have red PMS 

#185 marked pipes, hoses, or other 

devices through which the 

refrigerant passes, to indicate the 

use of a flammable refrigerant. This 

color must be applied at all service 

ports and other parts of the system 

where service puncturing or other 

actions creating an opening from 

the refrigerant circuit to the 

atmosphere might be expected and 

must extend a minimum of one (1) 

inch in both directions from such 

locations. 

As provided in clauses SB6.1.2 to 

SB6.1.5 of UL Standard 399, 7th

edition, the following markings 

must be attached at the locations 

provided and must be permanent:

:

(a) “DANGER—Risk of Fire or 

Explosion. Flammable 

Refrigerant Used. Do Not Use 

Mechanical Devices To Defrost 

Refrigerator. Do Not Puncture 

Refrigerant Tubing.” This 

marking must be provided on 

or near any evaporators that can 

be contacted by the consumer.

(b) “DANGER—Risk of Fire or 

Explosion. Flammable 

Refrigerant Used. To Be 

Repaired Only By Trained 

Service Personnel. Do Not 

Puncture Refrigerant Tubing.” 

This marking must be located 

near the machine compartment.

(c) “CAUTION—Risk of Fire or 

Explosion. Flammable 

Proper ventilation should be 

maintained at all times during 

the manufacture and storage of 

equipment containing 

hydrocarbon refrigerants 

through adherence to good 

manufacturing practices as per 

29 CFR 1910.106. If refrigerant 

levels in the air surrounding the 

equipment rise above one-fourth 

of the lower flammability limit,

the space should be evacuated 

and re-entry should occur only 

after the space has been 

properly ventilated.

Technicians and equipment 

manufacturers should wear 

appropriate personal protective 

equipment, including chemical 

goggles and protective gloves, 

when handling ethane. Special 

care should be taken to avoid 

contact with the skin since 

ethane, like many refrigerants, 

can cause freeze burns on the 

skin. 

A Class B dry powder type fire 

extinguisher should be kept 

nearby.

Technicians should only use 

spark-proof tools when working 

on equipment with flammable 

refrigerants.

Any recovery equipment used 

should be designed for 

flammable refrigerants. 

Any refrigerant releases should 

be in a well-ventilated area, 

such as outside of a building.

Only technicians specifically 

trained in handling flammable 

refrigerants should service 

equipment containing ethane. 

Technicians should gain an 

understanding of minimizing 

the risk of fire and the steps to 

use flammable refrigerants 

safely.

Room occupants should 

evacuate the space immediately 

following the accidental release 

of this refrigerant.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 278 of 289

Refrigerant Used. Consult 

Repair Manual/Owner’s Guide 

Before Attempting To Service 

This Product. All Safety 

Precautions Must be 

Followed.” This marking must 

be located near the machine 

compartment.

(d) “CAUTION—Risk of Fire or 

Explosion. Dispose of Properly 

In Accordance With Federal Or 

Local Regulations. Flammable 

Refrigerant Used.” This 

marking must be provided on 

the exterior of the refrigeration 

equipment.

(e) “CAUTION—Risk of Fire or 

Explosion Due To Puncture Of 

Refrigerant Tubing; Follow 

Handling Instructions 

Carefully. Flammable 

Refrigerant Used.” This 

marking must be provided near 

all exposed refrigerant tubing.

If a service port is added then 

retail food refrigerators and 

freezers using these refrigerants 

should have service aperture 

fittings that differ from fittings 

used in equipment or containers 

using non-flammable 

refrigerant. “Differ” means that 

either the diameter differs by at 

least 1/16 inch or the thread 

direction is reversed (i.e., righthanded vs. left-handed). These 

different fittings should be 

permanently affixed to the unit 

at the point of service and 

maintained until the end-of-life 

of the unit, and should not be 

accessed with an adaptor.

REFRIGERANTS—SUBSTITUTES ACCEPTABLE SUBJECT TO NARROWED USE LIMITS

End-use Substitutes Decision Narrowed Use Limits Further Information

Centrifugal 

chillers (new 

only)

HFC-134a Acceptable 

subject to 

narrowed 

use limits

Acceptable after January 1, 2022, 

only in military applications where 

reasonable efforts have been made 

to ascertain that other alternatives 

are not technically feasible due to 

performance or safety requirements 

or are still awaiting final military 

qualifications.

Users are required to document 

and retain the results of their 

technical investigation of 

alternatives for the purpose of 

demonstrating compliance. 

Information should include 

descriptions of: 

 Application in which 

the substitute is 

needed; 

 Substitutes examined 

and rejected; 

 Reason for rejection of 

other alternatives, e.g., 

performance, technical 

or safety standards; 

and/or 

 Anticipated date other 

substitutes will be 

available and qualified

Commented [A13]: Unlike with last year's SNAP rule, it could 

take significantly longer than the 3 additional years for the 

commenting agency to determine if lower-GWP alternatives are 

feasible in military mission-critical applications and then redesign 

and qualify the agency’s equipment. In addition, the commenting 

agency has certain specialty applications that have much more 

stringent requirements and limitations, like submarines, where none 

of the proposed alternatives may prove to be feasible. If that is the 

case, the commenting agency will need to continue to use R-134a in 

those applications for the foreseeable future. This is one of the 

reasons why the agency has worked closely with Department of 

State and EPA over the last several years to ensure that the proposed 

Montreal Protocol HFC Amendment is a phase-down and not a 

phase-out. The proposed narrowed use limits would allow use of 

HFC-134a in military applications beyond January 1, 2022 where 

reasonable efforts have been made to ascertain that other alternatives 

are not technically feasible due to performance or safety 

requirements, or are still awaiting final military qualifications. 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 279 of 289

REFRIGERANTS—UNACCEPTABLE SUBSTITUTES

End-use Substitutes Decision Further 

Information

and projected time for

switching.

Positive 

displacemen

t chillers 

(new only)

HFC-134a Acceptable 

subject to 

narrowed 

use limits

Acceptable after January 1, 2022, 

only in military applications where 

reasonable efforts have been made 

to ascertain that other alternatives 

are not technically feasible due to 

performance or safety requirements 

or are still awaiting final military 

qualifications.

Users are required to document 

and retain the results of their 

technical investigation of 

alternatives for the purpose of 

demonstrating compliance. 

Information should include 

descriptions of: 

 Application in which 

the substitute is 

needed; 

 Substitutes examined 

and rejected; 

 Reason for rejection of 

other alternatives, e.g., 

performance, technical 

or safety standards; 

and/or 

 Anticipated date other 

substitutes will be 

available and qualified

and projected time for

switching.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 280 of 289

Centrifugal chillers (new only) FOR12A, FOR12B, HFC134a, HFC-227ea, HFC-236fa, 

HFC-245fa, R-125/134a/600a 

(28.1/70/1.9), R125/290/134a/600a

(55.0/1.0/42.5/1.5), R-404A, 

R-407C, R-410A, R-410B, R417A, R-421A, R-422B, R422C, R-422D, R-423A, R424A, R-434A, R-438A, R507A, RS-44 (2003 

composition), and THR-03

Unacceptable as of 

January 1, 2022 except 

where allowed for HFC134a under a narrowed

use limit.

These 

refrigerants have 

GWPs ranging 

from 

approximately 

900 to 9,810. 

Other 

alternatives will 

be available for 

this end-use with 

lower overall 

risk to human 

health and the 

environment by 

the status change 

date.

Centrifugal chillers (new only) Propylene (R–1270) and R443AUnacceptable as of

[insert date 30 days 

after publication of 

final rule]

These 

refrigerants are 

highly 

photochemically 

reactive in the 

lower 

atmosphere and 

may deteriorate 

local air quality 

(that is, may 

increase ground 

level ozone). 

Other 

alternatives are 

available for this 

end-use with 

lower overall 

risk to human 

health and the 

environment.

Cold storage warehouses (new 

only)

HFC-227ea, R125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, 

R-407A, R-407B, R-410A, R410B, R-417A, R-421A, R421B, R-422A, R-422B, R422C, R-422D, R-423A, R424A, R-428A, R-434A, R438A, R-507A, and RS-44 

(2003 composition)

Unacceptable as of 

January 1, 2023

These 

refrigerants have 

GWPs ranging 

from 

approximately 

2,090 to 3,990. 

Other 

alternatives will 

be available for 

this end-use with 

lower overall 

risk to human 

health and the 

environment by 

the status change 

date.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 281 of 289

Cold storage warehouses (new 

only)

Propylene (R–1270) and R443AUnacceptable as of 

[insert date 30 days 

after publication of 

final rule]

These 

refrigerants are 

highly 

photochemically 

reactive in the 

lower 

atmosphere and 

may deteriorate 

local air quality 

(that is, may 

increase ground 

level ozone). 

Other 

alternatives are 

available for this 

end-use with 

lower overall 

risk to human 

health and the 

environment.

Household refrigerators and 

freezers (new only)

FOR12A, FOR12B, HFC134a, KDD6, R125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, 

R-407C, R-407F, R-410A, R410B, R-417A, R-421A, R421B, R-422A, R-422B, R422C, R-422D, R-424A, R426A, R-428A, R-434A, R437A, R-438A, R-507A, RS24 (2002 formulation), RS-44 

(2003 formulation), SP34E, 

and THR-03

Unacceptable as of 

January 1, 2021

These 

refrigerants have 

GWPs ranging 

from 

approximately 

900 to 3,985. 

Other 

alternatives will 

be available for 

this end-use with 

lower overall 

risk to human 

health and the 

environment by 

the status change 

date.

Positive displacement chillers 

(new only)

FOR12A, FOR12B, HFC134a, HFC-227ea, KDD6, R125/134a/600a (28.1/70/1.9), 

R-125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, 

R-407C, R-410A, R-410B, R417A, R-421A, R-422B, R422C, R-422D, R-424A, R434A, R-437A, R-438A, R507A, RS-44 (2003 

composition), SP34E, and 

THR-03

Unacceptable as of 

January 1, 2022 except 

where allowed for HFC134a under a narrowed 

use limit.

These 

refrigerants have 

GWPs ranging 

from 

approximately 

900 to 3,985. 

Other 

alternatives will 

be available for 

this end-use with 

lower overall 

risk to human 

health and the 

environment by 

the status change 

date.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 282 of 289

Positive displacement chillers 

(new only)

Propylene (R–1270) and R443AUnacceptable as of 

[insert date 30 days 

after publication of 

final rule]

These 

refrigerants are 

highly 

photochemically 

reactive in the 

lower 

atmosphere and 

may deteriorate 

local air quality 

(that is, may 

increase ground 

level ozone). 

Other 

alternatives are 

available for this 

end-use with 

lower overall 

risk to human 

health and the 

environment.

Residential and light commercial 

air conditioning and heat pumps 

(new only)

Propylene (R–1270) and R443AUnacceptable as of 

[insert date 30 days 

after publication of a 

final rule]

These 

refrigerants are 

highly 

photochemically 

reactive in the 

lower 

atmosphere and 

may deteriorate 

local air quality 

(that is, may 

increase ground 

level ozone). 

Other 

alternatives are 

available for this 

end-use with 

lower overall 

risk to human 

health and the 

environment.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 283 of 289

Residential and light commercial 

air conditioning–unitary split AC 

systems and heat pumps (retrofit 

only)

All refrigerants identified as 

flammability Class 3 in 

ANSI/ASHRAE Standard 34–

2013.

All refrigerants meeting the 

criteria for flammability Class 

3 in ANSI/ASHRAE Standard 

34–2013. This includes, but is 

not limited to, refrigerant 

products sold under the 

namesR-22a, 22a, Blue Sky 

22a refrigerant, Coolant 

Express 22a, DURACOOL22a, EC-22, Ecofreeeze EF22a, EF-22a, Envirosafe 22a, 

ES-22a, Frost 22a, HC-22a, 

Maxi-Fridge, MX-22a, OzChill 22a, Priority Cool, and 

RED TEK 22a

Unacceptable as of 

[insert date 30 days 

after publication of 

final rule]

These 

refrigerants are 

highly 

flammable and 

present a 

flammability risk 

when used in 

equipment 

designed for 

nonflammable 

refrigerants. 

Other 

alternatives are 

available for this 

end-use with 

lower overall 

risk to human 

health and the 

environment.

Retail food refrigeration 

(refrigerated food processing and 

dispensing equipment) (new 

only)

HFC-227ea, KDD6, R125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, 

R-407A, R-407B, R-407C, R407F, R-410A, R-410B, R417A, R-421A, R-421B, R422A, R-422B, R-422C, R422D, R-424A, R-428A, R434A, R-437A, R-438A, R507A, RS-44 (2003 

formulation)

Unacceptable as of 

January 1, 2021

These 

refrigerants have 

GWPs ranging 

from 

approximately 

1,770 to 3,990. 

Other 

alternatives will 

be available for 

this end-use with 

lower overall 

risk to human 

health and the 

environment by 

the status change 

date.

FOAM BLOWING AGENTS—SUBSTITUTES ACCEPTABLE SUBJECT TO NARROWED USE LIMITS

End-use Substitutes Decision Narrowed Use Limits Further Information

Rigid PU: 

Spray 

foam—highpressure 

twocomponent

HFC-134a, HFC245fa, and blends 

thereof; blends of 

HFC-365mfc 

with at least four 

percent HFC245fa, and 

commercial 

blends of HFC365mfc with 

seven to 13 

percent HFCAcceptable subject to 

narrowed use limits

Acceptable from 

January 1, 2020, until 

January 1, 2022, only in 

military or space- and 

aeronautics-related 

applications where 

reasonable efforts have 

been made to ascertain 

that other alternatives 

are not technically 

feasible due to 

performance or safety 

Users are required to 

document and retain the 

results of their technical 

investigation of 

alternatives for the 

purpose of 

demonstrating 

compliance. 

Information should 

include descriptions of: 

• Process or product in 

which the substitute is 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 284 of 289

FOAM BLOWING AGENTS—UNACCEPTABLE SUBSTITUTES

End-use Substitutes Decision Further Information

Flexible PU Methylene chloride Unacceptable as of [insert 30 

days after publication of final 

rule]

Methylene chloride is a 

carcinogen and may present a 

toxicity risk. Other alternatives

are available for this end-use 

with lower overall risk to 

human health and the 

environment.

227ea and the 

remainder HFC365mfc; and 

Formacel TI 

requirements.

Closed cell foam 

products and products 

containing closed cell 

foams manufactured 

with these substitutes 

on or before January 1, 

2022, may be used after 

that date.

needed; 

• Substitutes examined 

and rejected; 

• Reason for rejection 

of other alternatives, 

e.g., performance, 

technical or safety 

standards; and/or 

• Anticipated date other 

substitutes will be 

available and projected 

time for switching.

Rigid PU: 

Spray 

foam—lowpressure 

twocomponent

HFC-134a, HFC245fa, and blends 

thereof; blends of 

HFC-365mfc 

with at least four 

percent HFC245fa, and 

commercial 

blends of HFC365mfc with 

seven to 13 

percent HFC227ea and the 

remainder HFC365mfc; and 

Formacel TI 

Acceptable subject to 

narrowed use limits

Acceptable from 

January 1, 2021, until

January 1, 2022, only in 

military or space- and 

aeronautics-related 

applications where 

reasonable efforts have 

been made to ascertain 

that other alternatives 

are not technically 

feasible due to 

performance or safety 

requirements.

Closed cell foam 

products and products 

containing closed cell 

foams manufactured 

with these substitutes 

on or before January 1, 

2022, may be used after 

that date.

Users are required to 

document and retain the 

results of their technical 

investigation of 

alternatives for the 

purpose of 

demonstrating 

compliance. 

Information should 

include descriptions of: 

• Process or product in 

which the substitute is 

needed; 

• Substitutes examined 

and rejected; 

• Reason for rejection 

of other alternatives, 

e.g., performance, 

technical or safety 

standards; and/or 

• Anticipated date other 

substitutes will be 

available and projected 

time for switching.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 285 of 289

Integral Skin PU Methylene chloride Unacceptable as of January 1, 

2017

Closed cell foam products and 

products containing closed cell 

foams manufactured with this 

substitute on or before January 

1, 2020, may be used after that 

date.

Methylene chloride is a 

carcinogen and may present a 

toxicity risk. Other alternatives

are available for this end-use 

with lower overall risk to 

human health and the 

environment.

Polyolefin Methylene chloride Unacceptable as of January 1, 

2020

Closed cell foam products and 

products containing closed cell 

foams manufactured with this 

substitute on or before January 

1, 2020, may be used after that 

date.

Methylene chloride is a 

carcinogen and may present a 

toxicity risk. Other alternatives

are available for this end-use 

with lower overall risk to 

human health and the 

environment.

Rigid PU: Spray 

foam—one 

component foam 

sealants

HFC-134a, HFC-245fa, 

and blends thereof; 

blends of HFC-365mfc 

with at least four 

percent HFC-245fa, and 

commercial blends of 

HFC-365mfc with 

seven to 13 percent 

HFC-227ea and the 

remainder HFC365mfc; and Formacel 

TI

Unacceptable as of January 1, 

2020.

Closed cell foam products and 

products containing closed cell 

foams manufactured with these 

substitutes on or before January 

1, 2020, may be used after that 

date.

These foam blowing agents 

have GWPs ranging from 

higher than 730 to 

approximately 1,500. Other 

alternatives will be available for 

this end-use with lower overall 

risk to human health and the 

environment by the status 

change date.

Rigid PU: Spray 

foam—highpressure twocomponent

HFC-134a, HFC-245fa, 

and blends thereof; 

blends of HFC-365mfc 

with at least four 

percent HFC-245fa, and 

commercial blends of 

HFC-365mfc with 

seven to 13 percent 

HFC-227ea and the 

remainder HFC365mfc; and Formacel 

TI 

Unacceptable as of January 1, 

2020, except where allowed 

under a narrowed use limit. 

Closed cell foam products and 

products containing closed cell 

foams manufactured with these 

substitutes on or before January 

1, 2020, may be used after that 

date.

These foam blowing agents 

have GWPs ranging from 

higher than 730 to 

approximately 1,500. Other 

alternatives will be available for 

this end-use with lower overall 

risk to human health and the 

environment by the status 

change date.

Rigid PU: Spray 

foam—lowpressure twocomponent

HFC-134a, HFC-245fa, 

and blends thereof; 

blends of HFC-365mfc 

with at least four 

percent HFC-245fa, and 

commercial blends of 

HFC-365mfc with 

seven to 13 percent 

HFC-227ea and the 

remainder HFC365mfc; and Formacel 

TI 

Unacceptable as of January 1, 

2021, except where allowed 

under a narrowed use limit.

Closed cell foam products and 

products containing closed cell 

foams manufactured with these 

substitutes on or before January 

1, 2020, may be used after that 

date.

These foam blowing agents 

have GWPs ranging from 

higher than 730 to 

approximately 1,500. Other 

alternatives will be available for 

this end-use with lower overall 

risk to human health and the 

environment by the status 

change date.
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 286 of 289

FIRE SUPPRESSION AND EXPLOSION PROTECTION AGENTS— ACCEPTABLE SUBJECT TO USE 

CONDITIONS

End-use Substitute Decision Use Conditions Further Information

Streaming 2-BTP Acceptable, 

subject to use 

conditions

As of [insert date 30 days 

after publication of final 

rule], acceptable only for 

use in handheld 

extinguishers in aircraft.

This fire suppressant has a relatively low 

GWP of 0.23-0.26 and a short atmospheric 

lifetime of approximately seven days. 

This agent is subject to requirements 

contained in a Toxic Substance Control Act 

(TSCA) section 5(e) Consent Order and any 

subsequent TSCA section 5(a)(2) Significant 

New Use Rule (SNUR).

For establishments manufacturing, installing 

and maintaining handheld extinguishers

using this agent:

(1) Use of this agent should be used in 

accordance with the latest edition of 

NFPA Standard 10 for Portable Fire 

Extinguishers;

(2) In the case that 2-BTP is inhaled, 

person(s) should be immediately 

removed and exposed to fresh air; if 

breathing is difficult, person(s) should 

seek medical attention;

(3) Eye wash and quick drench facilities 

should be available. In case of ocular 

exposure, person(s) should immediately 

flush the eyes, including under the 

eyelids, with fresh water and move to a 

non-contaminated area.

Exposed person(s) should remove all 

contaminated clothing and footwear to 

avoid irritation, and medical attention 

should be sought if irritation develops or 

persists;

(4) Although unlikely, in case of ingestion 

of 2-BTP, the person(s) should consult a 

physician immediately;

(5) Manufacturing space should be equipped 

with specialized engineering controls and 

well ventilated with a local exhaust 

system and low-lying source ventilation 

to effectively mitigate potential 

occupational exposure; regular testing 

and monitoring of the workplace 

atmosphere should be conducted;

(6) Employees responsible for chemical 

processing should wear the appropriate 

PPE, such as protective gloves, tightly 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 287 of 289

sealed goggles, protective work clothing, 

and suitable respiratory protection in 

case of accidental release or insufficient 

ventilation;

(7) All spills should be cleaned up 

immediately in accordance with good 

industrial hygiene practices; and

(8) Training for safe handling procedures 

should be provided to all employees that 

would be likely to handle containers of 

the agent or extinguishing units filled 

with the agent.

(9) 2-BTP use as a streaming fire 

extinguishing agent in handheld 

extinguishers in aircraft should be in 

accordance with UL 711, Rating and 

Testing of Fire Extinguishers and the 

Federal Aviation Administration (FAA) 

Minimum Performance Standard for 

Hand-Held Extinguishers 

(DOT/FAA/AR-01/37), with regard to 

the size and number of extinguishers 

depending on the size of aircraft. 

(10) 2-BTP handheld extinguishers should 

follow required minimum room volumes 

established by UL 2129, Halocarbon 

Clean Agent Fire Extinguishers, when 

discharged into a confined space.

Total 

flooding

2-BTP Acceptable, 

subject to use 

conditions

As of [insert date 30 days 

after publication of final 

rule], acceptable only for 

use on engine nacelles and 

auxiliary power units on 

aircraft.

This fire suppressant has a relatively low 

GWP of 0.23-0.26 and a short atmospheric 

lifetime of approximately seven days. 

This agent is subject to requirements 

contained in a TSCA section 5(e) Consent 

Order and any subsequent TSCA section 

5(a)(2) SNUR.

For establishments manufacturing, installing, 

and servicing engine nacelles and auxiliary 

power units on aircraft using this agent:

(1) This agent should be used in accordance 

with the safety guidelines in the latest edition 

of the National Fire Protection Association 

(NFPA) 2001 Standard for Clean Agent Fire 

Extinguishing Systems;

(2) In the case that 2-BTP is inhaled, 

person(s) should be immediately removed 

and exposed to fresh air; if breathing is 

difficult, person(s) should seek medical 

attention;

(3) Eye wash and quick drench facilities 

should be available. In case of ocular 

exposure, person(s) should immediately flush 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 288 of 289

FIRE SUPPRESSION AND EXPLOSION PROTECTION AGENTS—UNACCEPTABLE SUBSTITUTES

the eyes, including under the eyelids, with 

fresh water and move to a non-contaminated 

area. 

Exposed person(s) should remove 

all contaminated clothing and 

footwear to avoid irritation, and 

medical attention should be sought 

if irritation develops or persists;

(4) Although unlikely, in case of ingestion 

of 2-BTP, the person(s) should consult a 

physician immediately;

(5) Manufacturing space should be equipped 

with specialized engineering controls and 

well ventilated with a local exhaust system 

and low-lying source ventilation to 

effectively mitigate potential occupational 

exposure; regular testing and monitoring of 

the workplace atmosphere should be 

conducted;

(6) Employees responsible for chemical 

processing should wear the appropriate PPE, 

such as protective gloves, tightly sealed 

goggles, protective work clothing, and 

suitable respiratory protection in case of 

accidental release or insufficient ventilation;

(7) All spills should be cleaned up 

immediately in accordance with good 

industrial hygiene practices;

(8) Training for safe handling procedures 

should be provided to all employees that 

would be likely to handle containers of the 

agent or extinguishing units filled with the 

agent;

(9) Safety features that are typical of total 

flooding systems such as pre-discharge 

alarms, time delays, and system abort 

switches should be provided, as directed by 

applicable OSHA regulations and NFPA 

standards; use of this agent should also 

conform to relevant OSHA requirements, 

including 29 CFR 1910, subpart L, sections 

1910.160 and 1910.162.

End-use Substitute Decision Further Information

Total flooding PFCs (C3F8 and 

C4F10)

Unacceptable as of [insert one 

year after publication of final 

rule]

Total flooding systems 

These fire suppressants have GWPs 

ranging from 8,830 to 8,860. Other 

alternatives will be available for this 

end-use with lower overall risk to 
*** Interagency Working Comments on Draft Language under EO13563 and 12866 Interagency Review. Subject to 

Further Policy Review. Draft, Do Not Cite, Quote, or Release During Review ***

Page 289 of 289

8. In §82.154, paragraph (a)(1) is amended by adding paragraph iv to read as follows:

§ 82.154 Prohibitions.

(a)(1) * * *

(iv) Effective [INSERT DATE 30 DAYS AFTER PUBLICATION OF FINAL RULE IN 

THE FEDERAL REGISTER], propane (R-290) in self-contained commercial ice machines, 

very low temperature refrigeration equipment, and water coolers.

* * * * *

manufactured using these fire 

suppressants on or before [insert 

one year after publication of 

final rule] may be used after that 

date.

human health and the environment 

by the status change date.