Rebecca von dem Hagen

Stratospheric Protection Division

Office of Atmospheric Programs

U.S. Environmental Protection Agency

EPA Update

MACS 2016 Training Event and Trade Show

Orlando, Florida

February 12, 2016
 Background 

 Significant New Alternatives Policy (SNAP) Program 

 Recent Actions & Future Considerations 

 Proposed Updates to CAA Section 608 

 Other HFC Activities

 Federal Procurement

 International Activities 

 Other MVAC Updates

Scope of Presentation

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Clean Air Act (CAA) Title VI Regulations on 

Motor Vehicle Air Conditioning (MVAC) 

 Section 612: Significant New Alternatives Policy (SNAP) Program

 SNAP evaluates and lists MVAC refrigerants 

as acceptable subject to use conditions or 

unacceptable based on comparison of 

overall risk to human health & the environment

 Section 609: Servicing of Motor Vehicle Air Conditioners

 Requires technician certification & use of approved servicing equipment 

 Section 608: Recyling and Emissions Reductions 

 Prohibits intentional venting of any refrigerant, unless specifically 

exempted

 Restricts sale of ODS refrigerant to certified technicians

 Requires recovery of refrigerant prior to disposal

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MVAC Refrigerant Transition

Environmental Impacts of MVAC Refrigerants

Global Warming

Potential

Ozone Depleting?

CFC-12 10,900 Yes

HFC-134a 1,430 No

HFC-152a 124 No

HFO-1234yf 4 No

CO2 (R-744) 1 No

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Climate Action Plan: HFCs

 President’s Climate Action Plan released June 2013

 Address HFCs through domestic actions

 Use existing CAA authority of Significant New Alternatives Policy 

(SNAP) Program to approve climate-friendly chemicals, prohibit some uses 

of most harmful

 Provide federal leadership by purchasing cleaner alternatives to HFCs 

whenever feasible and by transitioning to equipment using safe, more 

sustainable alternatives

 Continue international diplomacy

 Lead negotiations under the Montreal Protocol to phase down HFCs

 Work with partners in the Climate and Clean Air Coalition to Reduce 

Short-Lived Climate Pollutants to promote climate-friendly 

alternatives to high-GWP HFCs, address technical 

standards, and reduce emissions from HFC use 

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Significant New Alternatives Policy 

(SNAP) Program
• Acceptable - those that reduce overall risk to human health & environment

• Acceptable with use restrictions - if needed to ensure safe use

• Unacceptable

Evaluates alternatives & lists alternatives as:

• Aerosols; Foams; Refrigeration and A/C; Solvents; Fire 

Suppression; Adhesives, Coatings, Inks, etc.

Sectors include:

• Ozone Depletion Potential

• Global Warming Potential

• Flammability

• Toxicity

Considers: 

• Local Air Quality

• Ecosystem Effects

• Occupational & Consumer 

Health/Safety 7
Recent SNAP Actions

 Issued two notices expanding 

list of acceptable alternatives

 Proposed and finalized rule 

listing five low-GWP 

flammable refrigerants 

acceptable subject to use 

conditions for stationary 

applications

 Proposed and finalized rule 

prohibiting specific HFCs in 

certain end-uses

 HFC Emissions Reductions: 

54-64 MMTCO2eq in 2025

Near term changes can provide 

both near and long term benefits

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July 2015 Change of Status Rule 

Overview

• HFC-125 - January 2016

• HFC-227ea & blends - July 20, 2016

• HFC-134a - July 20, 2016/January 1, 2018

Aerosols

• HFC-134a in New Light-Duty Systems - MY 2021

• HCFC & HFC Containing Blends in New Light-Duty 

Systems - MY 2017

Motor Vehicle Air 

Conditioning

• New Supermarket Systems - January 2017

• New Remote Condensing Units - January 2018

• New Vending Machines - January 2019

• New Stand-Alone Units (small medium-temp, large 

medium-temp, low-temp)- January 2019/January 2020

• Retrofitted Retail Food Refrig Equipment and Vending 

Machines - July 20, 2016

Retail Food Refrigeration 

& Vending Machines

• All End-Uses, Except Rigid PU Spray Foam-Various dates 

between January 2017-January 2021

Foams

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July 2015 Change of Status 

Rule: MVAC Refrigerants

Final Rule Listed: 

 HFC-134a unacceptable 

 As of MY 2021

 New, light-duty vehicles only 

 Narrowed use limits finalized for export vehicles 

 Available through MY 2025 

 Limited to vehicles exported to countries lacking infrastructure for servicing 

alternative refrigerants

 Several HFC and HCFC refrigerant blends unacceptable 

 As of MY 2017

 New, light-duty vehicles only

Use of HFC-134a and refrigerant blends for servicing not impacted

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Next SNAP Proposed Rule: 

MVAC Refrigerants for HD

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 Next SNAP proposed rule under interagency review

 Sept. 11 SNAP Stakeholder Meeting 

 Nov. 18 Heavy-duty (HD) MVAC Stakeholder Workshop

 New listings of alternatives as acceptable subject to use conditions or 

unacceptable, and changes to listing statuses for variety of chemicals and end-uses

 EPA is considering to propose listing HFO-1234yf acceptable, subject to use 

conditions, for limited HD vehicle types e.g.,: 

 Medium-duty passenger vehicles (MDPVs)

 HD pickup trucks

 Complete HD vans

 HFO-1234yf listed as acceptable, subject to use conditions, in newly 

manufactured passenger vehicles and light-duty trucks in 2011

 CO2 (R-744) and HFC-152a are listed as acceptable, subject to use 

conditions, in all new MVAC systems, including HD
HD Vehicle Classifications by 

Gross Vehicle Weight Rating (GVWR)

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
Proposed Updates to Clean Air Act 

Section 608

National Recycling and Emission 

Reduction Program
CAA Section 608 Regulations

 Current requirements include:

 Prohibition against knowingly venting refrigerant (all refrigerants unless 

exempt)

 Leak repair and prevention for larger systems (for CFCs, HCFCs)

 Service practice requirements (for CFCs, HCFCs)

 Safe disposal requirements (for CFCs, HCFCs)

 Nov. 2015 EPA proposed updates intended to: 

 Extend Section 608 requirements to HFCs and other non-exempt 

substitutes

 Decrease leaks from large appliances

 Enhance clarity and ease of compliance

 Continue to create incentives that support careful management of 

refrigerants 14
 Extension of sales restriction 

 Restrict sale of refrigerants that are not exempt from the venting 

prohibition to 608 and 609 certified technicians only

 Exemption to sales restriction for small cans for MVAC servicing 

if equipped with self-sealing valve

 Small can = 2 pounds or less

 Cans with self-sealing valve currently in production to meet CA 

regulations 

 EPA proposed self-sealing valve standards based on those required in CA

 Distributors would have to keep refrigerant sales records and 

verify purchasers are (or employ) 608 or 609 certified technicians

 Non-exempt refrigerant must be recovered prior to disposal

Proposed Changes to CAA Section 608

Impacting MVAC

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• Federal Procurement

• International Efforts

Other HFC Activities
HFCs: Federal Procurement

 Climate Action Plan directive to provide federal leadership by 

purchasing “cleaner alternatives to HFCs whenever feasible and 

transition over time to equipment that uses safer and more 

sustainable alternatives” 

 Proposed rule addressing HFCs by amending Federal 

Acquisition Regulation directing the government to procure 

alternatives to high-GWP HFCs, where feasible

 Use acceptable alternatives identified by SNAP program

 Reporting on use of HFCs 

(i.e., refrigerants)

 Final rule expected in 2016

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U.S. Federal Sector: Fleet inventory 

(owned/leased): >635,000 vehicles1

1U.S. General Services Administration (GSA) 2013. Index of Data, Federal Fleet Report for FY 2013.
HFCs: International Efforts

 The United States, with Canada and Mexico, has been 

pursuing an Amendment to phasedown HFCs under the 

Montreal Protocol

 Phase DOWN, not OUT

 In November 2015, Parties reached an agreement on a 

pathway to work to an HFC amendment in 2016 

 A 2016 amendment to the Montreal Protocol to phasedown 

HFCs will achieve substantial greenhouse gas reductions and 

could avoid up to 0.5 degrees Celsius of warming by 2100

 Amending the Montreal Protocol will pave the way for all 

countries to transition to alternatives and away from highGWP HFCs

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Other MVAC Updates
Other MVAC-Specific Activities

 New website! www.epa.gov/mvac

 Improved content and removed outdated materials

 Intend to propose to Incorporate by Reference (IBR) new SAE 

standards for servicing equipment through rulemaking

 SAE J2843 R-1234yf Recovery/Recycling/ Recharging Equipment for 

Flammable Refrigerants for Mobile Air-Conditioning Systems

 SAE J2851 Recovery Equipment for Contaminated R-134a or R-1234yf 

Refrigerant from Mobile Automotive Air Conditioning Systems

 SAE J 3030 Automotive Refrigerant Recovery/Recycling/Recharging 

Equipment Intended for use with Both R-1234yf and R-134a

 Updates to Section 609 Technician Certification and Training 

Programs under Review

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Thank You!

Contact Information:

Rebecca von dem Hagen

vondemhagen.rebecca@epa.gov

(202) 343-9445