Regulatory Updates on Alternative Regulatory Updates on Alternative

Refrigerants for MVACs Refrigerants for MVACs

Yaidi Cancel

U.S. Environmental Protection Agency

SAE Automotive Refrigerant and System 

Efficiency Symposium, Scottsdale, AZ 

July 13, 2010
Overview Overview

• Background on the Significant New 

Alternatives Policy (SNAP) Program

• Alternative refrigerants for Motor Vehicle Air 

Conditioning (MVAC) systems

• Status of rules for alternative refrigerants

– CO2

– HFO-1234yf
Significant New Alternatives Policy Significant New Alternatives Policy

(SNAP) Program (SNAP) Program

• Part of U.S. response to Montreal Protocol

• Section 612 of the Clean Air Act

• Manufacturers are required to submit information 

to EPA on substitutes for ozone-depleting 

substances (ODS) before sale in US

• Directs EPA to evaluate alternatives

• Find acceptable those that reduce overall risk

to human health and the environment
Significant New Alternatives Policy Significant New Alternatives Policy

(SNAP) Program (SNAP) Program

• Types of Decisions under the SNAP Program

• Acceptable

• Listed in Federal Register (Notice of Acceptability)

• Acceptable subject to use conditions

• Acceptable subject to narrowed use limits

Unacceptable Rulemaking Required 
SNAP Application Submitted by:

Refr. Producer, MVAC Mfr, EPA, Anyone

SNAP Process SNAP Process

SNAP Team Reviews, Drafts Decision

SNAP Team Reviews

Need Additional Info?

EPA Internal Review

Proposed Rule

Comments

Final Rule

Public or 

confidential

EPA internal

OMB Review
What Alternatives are Already What Alternatives are Already

Acceptable under SNAP? Acceptable under SNAP?

• Listed substitutes in passenger cars & light 

duty vehicles (e.g. HFC-152a)

• Go to SNAP’s website:

• http://www.epa.gov/ozone/snap/

• IMPORTANT:

All MVAC refrigerants must be used with 

specified unique fittings and labels
What New Alternative is Already What New Alternative is Already

Acceptable under SNAP? Acceptable under SNAP?

• HFC-152a

• Non-ODS, low GWP flammable refrigerant 

• Found acceptable subject to use conditions in 

June 12, 2008 for new vehicles (73 FR 33304)

• Use conditions:

Systems must be designed to avoid occupant 

exposure to concentrations above 3.7% in the 

passenger cabin free space for > 15 sec.
What Else May be Added Soon What Else May be Added Soon

into the SNAP List for MVACs? into the SNAP List for MVACs?

• CO2

• Proposed subject to use conditions on 

September 14, 2006 (71 FR 55140)

• Announcement of data availability issued 

on September 17, 2009 (74 FR 47774)

• HFO-1234yf

• Proposed subject to use conditions on 

October 19, 2009 (74 FR 53445)
SNAP Proposed Rule on CO2

• Proposed use conditions:

– Engineering strategies to ensure exposure in 

passenger cabin remains < 3.0% over 15 min

– Manufacturers must meet requirements 

of SAE J639 (i.e. unique fittings, warning label)

• EPA took additional comments on:

– Should there be ceiling limit on exposure 

of 4.0%?

– Should use condition on exposure apply 

only when ignition is on?
SNAP Proposed Rule on HFO-1234yf

• Proposed use conditions:

• Engineering strategies and/or devices must be 

incorporated into the [HFO-1234yf MVAC] 

system:

• Such that leaks into the free space of the passenger 

compartment do not result in > 6.2% HFO-1234yf

in any part of the free space >15 seconds 

• Such that leaks into engine compartment or vehicle 

electric power source areas do not result in < 6.2% 

HFO-1234yf for any period of time

• 6.2% is lower flammability limit
SNAP Proposed Rule on HFO-1234yf

• Proposed use conditions (continued):

HFO–1234yf MVAC systems must incorporate 

protective devices, isolation and/or ventilation 

techniques:

• in areas where processes, procedures or upset 

conditions such as leaks have the potential to 

generate HFO-1234yf concentrations > 6.2%

• in proximity to exhaust manifold surfaces and 

hybrid/electric vehicle electric power sources
SNAP Proposed Rule on HFO-1234yf

• Proposed use conditions (continued):

• HFO–1234yf MVAC systems must adhere 

to all the safety requirements of SAE J639:

• unique fittings

• flammable refrigerant warning label

• high-pressure compressor cutoff switch

• pressure relief devices

• Manufacturers must conduct and keep on file 

Failure Mode and Effect Analysis (FMEA) as 

stated in SAE J1739
Major Comments on the

HFO-1234yf SNAP Proposal

• Environmental and health risk concerns

• TFA, HF, ground-level ozone formation, 

flammability, toxicity

• Proposed use conditions and suggested 

alternative protective strategies

• CRP1234 results
More on EPA Rules on HFO-1234yf

• EPA proposed a Significant New Use Rule 

[(SNUR), 75 FR 4983 & 75 FR 16706]:

• Requires submission of SNUN to EPA 90 days 

before using substance in activities designated 

as significant new use in the rule

• Addresses potential health concerns about 

significant inhalation exposure to consumers 

servicing their own MVAC systems

• Complements the SNAP rule

• Comment period closed
More on EPA Rules:

Status of New MVAC Alternatives

• CO2

• Proposed acceptable with use conditions 

for new motor vehicles

• Comment period closed

• Final rule is under development

• Anticipated final rule publication: 

Winter 2010
More on EPA Rules:

Status of New MVAC Alternatives

• HFO-1234yf

• SNAP

• Proposed acceptable with use conditions for 

new motor vehicles

• Comment period closed

• Final rule under development

• Anticipated final rule publication: Fall 2010

• SNUR

• Comment period closed

• Final rule under development

• Anticipated final rule publication: Winter 2010
For More Information:

• CO2 (SNAP):

• Yaidi Cancel, (202) 343-9512

Cancel.Yaidi@epa.gov

Docket: EPA-HQ-OAR-2004-0488

• HFO-1234yf (SNAP):

• Margaret Sheppard, (202) 343-9163

Sheppard.Margaret@epa.gov

Docket: EPA-HQ-OAR-2008-0664

• HFO-1234yf (SNUR): 

• Kenneth Moss, (202) 564-9232

Moss.Kenneth@epa.gov

Docket: EPA-HQ-OPPT-2008-0918

SNAP website: http://www.epa.gov.ozone/snap/
Why SAE Standards are

Important?

• Safety guidelines

• Widely used in MVAC industry

• EPA encourages the development 

of safe design and safety practices

• EPA often cites SAE standards in regulations 

• e.g., SAE J639 for safety requirements for 

alternative refrigerants