SNAP: Change of Status Rule

Overview/Status Briefing 

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Scope of Briefing

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 Proposed Changes of Status

 Comments Received

 Final Rule by Sector
What Was Proposed (August 2014)

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Change of Status Rule:

END Use/ Proposed Date

Proposed Change

Aerosols

January 2016

 HFC-134a unacceptable except for some technical 

and medical aerosols including MDIs 

 HFC-125, -227ea (except MDIs) unacceptable

Motor vehicle A/C

Model year 2021

 HFC-134a unacceptable 

Foams

January 2017

 HFC-134a and blends thereof unacceptable

 HFC-245fa and HFC-365mfc and HFC blends 

unacceptable in all foam blowing end-uses except for 

spray foam

Supermarket systems: remote 

condensing units, new (& retrofits 

from ODS)

January 2016

 Certain HFCs unacceptable: 

HFC-227ea, R-404A, R-407B, R-421B, R-422A, R- 422C, R-422D, R-428A, R-434A, and R-507A

Stand-alone retail food 

refrigeration, vending machines: 

new

January 2016

 Certain HFCs unacceptable: 

HFC-134a, R-404A, R-407A, R-407C, R-507A, 

other blends

Stand-alone retail food 

refrigeration, vending machines: 

retrofits from ODS

January 2016

 Certain HFCs unacceptable: R-404A and R-507A
Comments Overview

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 The total number of comments received over 7,700:

 Form letter #1: 7,022 copies supporting proposed rule, asking EPA to cover 

additional sectors and implement more rigorous timelines

 Form letter #2: 436 letters asking EPA to delay timing for floatation foam

 Form letter #3: 93 letters asking for more flexibility for floatation foam

 200+ individual letters

 Where additional time was requested, often cited reasons were: 

 Technical challenges with converting manufacturing facilities without additional 

time, particularly for flammables

 Awaiting additional technologies or suppliers that will maintain or improve 

energy efficiency

 Prefer better alignment of timing with changes to DOE requirements (e.g., 

2020 for appliance foams)

 Building and fire codes may need to be revised
Changes Between Proposal and Final: Aerosols

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 Commenters concerns:

 A few applications asked for no change or additional time

 Some aerosols require testing and certification (e.g., insecticides)

 Do not limit MDIs to the treatment of Asthma and COPD

 Some concerns with capability and/or use of flammables

 Final rule:

 July 1, 2016 for most aerosols (e.g., consumer aerosols)

 Approximately one year from issuing a final rule 

 2018: change of status date for uses requiring federal program approval 

(e.g., FIFRA), functional testing of smoke detectors 

 Broadened medical uses to all MDIs approved by FDA

 Kept proposed uses where HFC-134a is acceptable, subject to conditions 

 Added uses on energized circuits, smoke detector sensitivity testing, refrigerant flushes 
Changes Between Proposal and Final: Foams

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 Commenters’ concerns:

 Retain HFC-134a for low-pressure spray foam

 Sub-divide spray foam 

 Need additional time for certain foam types including XPS, appliance, flotation foam

 Within a few years there will be more suppliers

 Prefer consistency with DOE timing 

 Newer alternatives coming to market have improved energy efficiency 

 In a few cases indefinite extensions were requested

 Final Rule:

 Maintain 2017: flexible foams, phenolic, polystyrene extruded sheet, integral skin, 

rigid PU and polyisocyanuarate laminated boardstock

 2019: rigid PU slabstock

 2020: rigid PU for appliances and floatation, commercial refrigeration, sandwich 

panels; polyolefin; and XPS boardstock and billet

 No final action on spray foam in this rule
Changes Between Proposal and Final: MVAC

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 Commenters’ concerns:

 Timing: too late, too soon

 OEMs commented on ‘Run out’ models & exports with HFC-134a

 OEMs requested clarity on relationship to the LD GHG rule

 Some chemical producers concerned with future markets

 Some supported earlier dates given the uptake of climate-friendly alternatives others 

requested later dates (or no date) given their HFC-134a market

 Final rule:

 MY 2021; However, includes a “narrowed use limits” exception until 2025 for HFC134a MVACs in vehicles destined for countries lacking infrastructure to service MVACs 

using low-GWP refrigerants
Changes Between Proposal and Final: 

Supermarkets and Condensing Units

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 Commenters’ concerns:

 Timing

 Supermarket and trade association for supermarkets supported proposal

 Equipment manufacturers asked for more time to further develop complete line of 

equipment, allow for already planned new stores (up to 3 years), train contractors, 

prepare literature

 No convenience stores commented

 One system manufacturer identified technical issue with their lower-GWP equipment

 Questions on “new” and “retrofit” in supermarkets

 Requests for consistency with DOE timing (where applicable)

 Final rule:

 2016: retrofit supermarket and condensing unit 

 2017: new supermarket store construction changing status for same list of refrigerants

 2018: new remote condensing units (e.g., cold-rooms)

 Relevant DOE EE rules take effect 2017
Changes Between Proposal and Final: 

Stand-Alones and Vending Machines

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 Commenters’ concerns:

 More time needed particularly if only available options are flammable 

 Concerns for larger-sized equipment (more refrigerant required) and for low-temperature 

equipment (limited choice)

 More time for design & test models, increase availability of alternative refrigerants and 

equipment components (e.g., CO2 and HFO compressors)

 Final rule: 

 New stand-alone equipment (includes reach-in coolers and some walk-in units):

 2019: HFC-134a and GWP HFC blends - smaller sized (e.g., one door reach-in cooler; capacity 

distinction based on manufacturer’s comment)

 2020: similar refrigerants – larger sized and low-temperature equipment

 New vending machines: 

 2018: HFC-134a and certain high-GWP HFC blends in new equipment

 Retrofits: 

 2016: R-404A and R-507A 
Other Topics

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 SNAP criteria

 GWPs 

 Imports and exports 

 Additional status changes EPA should consider 

 Interactions with other rules and international developments

 DOE 

 HCFC phaseout

 Montreal Protocol

 EU F-gas rule

 Climate Benefits:

 Emissions reductions from NPRM: ~ 38 MMTCO2eq in 2020, ~70 MMTCO2eq 

in 2025

 Emissions reductions from FRM: 28-36 MMTCO2eq in 2020, 53-69 

MMTCO2eq in 2025
Discussion

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