Washington, DC - USA

Consumer Specialty Products Association

SBA Environmental Roundtable

EPA SNAP Proposal for Reduction of Use of HFCs

D. Douglas Fratz

Aerosol Products Division Staff Executive

August 1, 2014

Small Business Administration, 409 3rd St. SW, Washington, DC 
Aerosol Product HFC Use History

• 1990s Use of HFC-152a and HFC-134a

• Compliance with VOC Standards

• Safety for Nonflammable Products

• 2002 Responsible Use Principles for HFCs

• Partnership of US EPA, Japan METI and UNEP

• CSPA Signed on as Founding Member

• 2007-2013 CARB GWP Standards

• Early Action Measures under AB32

• GWP >150 Restricted in 13 Product Categories

• Categories Carefully Defined to Allow Product Safety
HFC-134a Use in Aerosol Products
Additional Essential Uses for HFC-134a

• Emergency Tire Inflators and Sealers

• Estimated Annual Usage: 2.2 MMTCO2eq (0.2%)

• Need: Nonflammability 

• Critical for Post-Use Tire Repair

• Critical for In-Vehicle Storage

• Problems with Alternatives

• HFO-1234ze Needs Further Evaluation

• Substitutes Must be Compatible with Sealants

• High Cost Could Deter Consumer Usage
Additional Essential Uses for HFC-134a

• Safety Dusters for Energized Electrical Equipment

• Estimated Annual Usage: <0.16 MMTCO2eq (0.15%)

• Need: Non-flammability 

• Used on Live Electrical Equipment - Sparking Can Occur

• Problems with Alternatives

• HFO-1234ze Needs Further Evaluation

• High Cost Could Encourage Unsafe Usage of Other Dusters 

with Flammable Propellants

• Small Business Costs are Significant Over Short Time
Additional Essential Uses for HFC-134a

• Emergency Safety Horns

• Estimated Annual Usage: <0.13 MMTCO2eq (0.01%)

• Need: Nonflammability 

• Used in Emergencies Where Fire Can be Present

– Facility Evacuations

– Marine Emergencies (Hundreds of Boat Fires Annually)

• Problems with Alternatives

• HFO-1234ze Needs Further Evaluation

• High Cost Could Encourage Unsafe Usage of Other Horns 

with Flammable Propellants

• Small Business Costs are Significant Over Short Time
Additional Essential Uses for HFC-134a

• Party Streamers 

• Estimated Annual Usage: 0.4 MMTCO2eq (0.04%)

• Need: Nonflammability

• Can Come into Contact with Flames

• Problems with Alternatives

• HFO-1234ze May be Usable

• Time Needed to Assure Safe for US Consumer Use

• January 2017 phase out may be feasible
Requested Modifications to Proposed Approved List

• duster sprays specifically for removal of dust from 

photographic negatives, semiconductor chips, and 

specimens under electron microscopes, or energized 

electrical equipment

• emergency portable safety horns specifically for 

emergency use in assisting facility egress or marine 

emergencies

• emergency tire inflators and sealants specifically for use 

in motor vehicle roadside emergencies prior to 

subsequent tire repair

• party streamers (until January 1, 2017)
Additional Essential Uses for HFC-134a

• Smoke Alarm Tester 

• Need: Nonflammability

– UL Listed file # S7201

– Used for calibration/sensitivity testing

• Problems with alternatives

• HFO-1234ze still being evaluated

• Loss of current test equipment at significant cost
Additional Essential Uses for HFC-134a

• Freeze Sprays for Tissue

• Need: Pharmaceutical Grade Purity

– Used on tissue for preservation

• Problems with Alternatives

• HFO-1234ze not evaluated for all uses

• Pharmaceutical Grade Purity HFO may be needed
Additional Essential Uses for HFC-134a

• Freeze Sprays for Circuit Boards

• Need: Nonflammability

– Used on live circuits

– Used in confined spaces

• Problems with alternatives

• HFO-1234ze still being evaluated by some

• Higher cost could encourage unsafe usage of other 

freeze sprays with flammable propellants

• Small Business costs are significant
Accompanying wording

• Smoke Alarm testers used around live circuits

• Freeze sprays for Tissues

• Freeze sprays used on or around energized 

electrical equipment
Questions & Comments

Washington, DC - USA

Thank You

Presented by:

Consumer Specialty Products Association

Aerosol Products Division Staff Executive

D. Douglas Fratz