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 3 rd 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 feasibleRequested 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 equipmentQuestions & Comments

Washington, DC - USA 

# Thank You Presented by: Consumer Specialty Products Association

Aerosol Products Division Staff Executive 

# D. Douglas Fratz