A S TRUST & HOLDINGS INC.

44-129 IVIIKIOLA DRIVE, KANEOHE, HI 96744

PHONE: 8082351890 FAX: 808 2350116 CELL: 808 5614688

EMAIL Richard@astrust.com WEB SITE www.hcr188c.com

Richard H. Maruya

March 7, 2014

Rebecca Von Dem Hagen

Alternatives and Emissions Reduction Branch

Stratospheric Protection Division

U.S. Environmental Protection Agency

1310 L Street, NW, 10 th Floor

Washington, DC 20005

RE: Submission of responses to Agency's May 15, 2013 letter regarding Incompleteness of

SNAP Submission on the Proposed Use of R-443A (HCR188C2) for NEW Residential Central

Split-System Air Conditioning Units, Central Heat Pumps, and Portable (Floor) Room Air

Conditioners (filed on February 11, 2013)

Dear Ms. Rebecca Von Dem Hagen:

A.S. Trust & Holdings is pleased to provide this reply to Cindy Newberg's May 15, 2013

letter that addressed the U.S. Environmental Protection Agency's response to our SNAP

submission of February 11, 2013 for the use of R-443A (HCR188C2) in NEW Residential Central

Split-System Air Conditioning Units, Central Heat Pumps, and Portable (Floor) Room Air

Conditioners. Our reply consists of this letter, organized to address the Agency's questions, plus

attached documents that we believe will assist the Agency in completing its review.

As a general clarification for completeness (based on discussions with Cindy Newberg),

please note that all responses, as well as the original SNAP application, refer to NEW

Residential and light-Commercial Versions of Central Split-System Air Conditioning

Units/Heat Pumps/Chillers and Portable (Floor) Room Air Conditioning Units.

Consultant Gary Whitmyre has provided answers in the attached document (A),

numbered according to the May 15, 2013 letter.

A.S. Trust also conferred with Alan Yamamoto, State Director at the office of U.S.

Senator Mazie K. Hirono (Hawaii) with respect to OSHA safety requirements; we have attached

a copy of his email reply (B).v Sincerely,



# .u**~//,(}/**

# /i~¥~ Richard H. Maruya -" /)

President, A.S. Trust &

# H~S Inc.



### Attachments

A - Supplemental Report on the Use of R-443a in Residential Split-System Air Conditioning and

Heat Pump Units, and in Portable Room Air Conditioners, Gary Whitmyre, February 28, 2014

(includes "Risk Assessment of Flammable Refrigerants in Room Air Conditioners/' D. Colbourne,

July 1, 2001)

B- Email: Alan K. Yamamoto, January 6, 2014From: "Alan.K.Yamamoto@hawaii.gov"

To: richardastrust.com

Sent: Monday, January 6, 2014 9:16 AM

Subject: Re: Fw: test

Aloha Mr. Maruya

‐

OSHA/HIOSH requires employers to conduct a hazard assessment to determine the hazards present at a

work site in order to determine if hazards are present that require the use of personal protective

equipment (PPE) per 29 CFR 1910.132(d)(1). Each employer who uses hazardous chemicals in their

workplace is required to conduct a hazard assessment.

When the hazards involve chemical products, a chemical product's Material Safety Data Sheet (MSDS) or

Safety Data Sheet (SDS) should be consulted when conducting the hazard assessment. The MSDS or SDS

is required to state what precautionary protections should be taken when working with the chemical

product under normal conditions and when responding to emergencies involving the chemical product,

as recommended by the chemical manufacturer.

In this instance, the MSDS for R443A states what what procedures to follow during hazardous situations

under Part II, What should I do if a hazardous situation occurs?. The MSDS also addresses what PPE

should be worn under normal conditions in Section 8, Exposure Controls

– Personal Protection.

OSHA's Hazard Communication Standard requires employers to provide Hazard Communication Training

to all of its employees who use hazardous chemicals, per 29 CFR 1910.1200(h)(1). Per 29 CFR

1910.1200(h)(3)(iii), the training is required to include “The measures employees can take to protect

themselves from these hazards, including specific procedures the employer has implemented to protect

employees from exposure to hazardous chemicals, such as appropriate work practices, emergency

procedures, and personal protective equipment to be used.”

Thank you,

Alan Yamamoto

Alan.K.Yamamoto@hawaii.gov

State Director at U.S. Senator Mazie K. Hirono