UNDERWRITERS LABORATORIES INC.

FLAMMABLE REFRIGERANT STAKEHOLDER FORUM 

TUESDAY, JANUARY 11, 2011 - 9:00 AM TO 5:00 PM

CRYSTAL GATEWAY MARROITT HOTEL ARLINGTON, VA

REPORT 

Representatives of a number of organizations participated in a stakeholder forum hosted by Underwriters 

Laboratories Inc. (UL) on the potential widespread introduction and use of flammable and semi-flammable 

refrigerants in appliances and HVAC/R equipment in the US. This is a report of the meeting. It is not 

intended as a complete record of the discussions but rather it serves to highlight some of the topics 

discussed.

1. Welcome 

The objective of the stakeholder forum was to serve as a catalyst for the US safety system to 

appropriately anticipate and ultimately address the safety challenges presented by flammable 

refrigerants. The forum was designed to bring key stakeholders (identified by UL) together to share their 

unique perspectives regarding the post-production transport, installation, use, storage, servicing and 

ultimately disposal of HVAC/R equipment and appliances employing flammable refrigerants. Participants 

were asked to represent the views of their broader stakeholder community as well as to share their 

particular expertise. 

The expected outcome of the forum was the identification of current activity and trends for introduction of 

flammable refrigerant technology to the market, stakeholder concerns, potential gaps in currently 

applicable installation codes and safety standards, need for education in the market and other matters 

identified by the participants. Participants would also help determine next steps.

2. Introductions 

A total of 35 individuals participated in the meeting. Everyone introduced themselves and their affiliation. 

Refer to Appendix A for a list of participants.

3. Background 

The market situation and need for stakeholder coordination was described in a White Paper published by 

UL, “Revisiting Flammable Refrigerants.” An advance copy was provided to the participants and a final 

version will be publicly available shortly via UL University at: 

http://www.uluniversity.us/common/ncsresponse.aspx?rendertext=thoughtleadership. Although some 

relevant UL product safety standards were updated in the last 15 years, the US market was rather quiet 

regarding flammable refrigerants in appliances and HVAC/R until a little over 4 years ago. Since then the 

interest in flammable refrigerants has increased and a number of stakeholders had begun to act on how 

to accomplish their introduction safely and within the appropriate regulations.

The US relies on a safety system to assure public safety. Equipment standards are a part of the system, 

but there are other equally important elements, including the efforts of producers, installers, enforcement, 

etc. The knowledge of the user / service personnel, whether through general education / training or 

information provided on the product or in instructions, is also a very important part of the system. 

Representatives of government agencies, installation and product safety standards committees, fire and 

mechanical code committees, professional associations and other stakeholders provided background and 

status of their areas of responsibility with respect to flammable refrigerants. Perspective was also shared 

on what the future may hold for flammable refrigerants in appliances and HVAC/R.

Of most significance to the participants was the expectation that a final rule would be published by EPA in 

2011 that would recognize isobutane, propane and two additional refrigerants (HCR-188C and HCR188C1) as substitutes for R-12 and R-22 in household refrigerators, freezers, and combination 

refrigerator and freezers and commercial refrigeration (retail food refrigerators and freezers – stand-alone 
Report of Flammable Refrigerant Stakeholder Forum

Underwriters Laboratories Inc. Page 2 of 6 January 2011

units only). The extent to which this rule may apply to products similar to those described (e.g. wine 

coolers) is yet to be determined.

In addition, interest was expressed in the upcoming (February 2011) meeting of a Joint Task Group of the 

UL product safety standards technical panels (STP’s). Lastly, the new 2L refrigerant class was discussed 

at length.

During the meeting it was confirmed that the Clean Air Act rule prohibiting venting of refrigerant to the 

atmosphere applies to hydrocarbon refrigerants, though it does not apply to industrial applications.

4. Industry Trends (AHAM / AHRI) 

Representatives of trade associations and manufacturers shared their perspective on experience to date 

in other markets, the technical challenges of the new refrigerants and insight into the distribution and 

service networks that currently support the use of appliances and HVAC/R.

While it was generally agreed to be too early to authoritatively forecast the use of flammable refrigerants, 

hydrocarbon refrigerants were anticipated for use in residential appliances. This would be dependent 

upon the ultimate outcome of the EPA final rule. HFO refrigerants, being considered for automotive 

applications, were not expected to be used in appliances and HVAC/R applications. Commercial 

refrigeration and HVAC was expected to still predominantly employ HFC’s due to the need for a larger 

charge, though room air conditioners may eventually use hydrocarbon refrigerants.

5. Discussion on Stakeholder Impact 

The bulk of the stakeholder forum involved discussion of the potential impact of flammable refrigerant 

usage in appliances and HVAC/R. The subjects discussed included:

Installation and Use 

Retail (Restaurants / Convenience / Supermarkets) 

 Kitchen design (placement of adjacent heating equipment, side-by-side installation)?

 Remote vs self-contained refrigerators (leak potential)? When / where refrigerant charging be done 

(off hours? Is charging location designed to meet fire codes?)

 ASHRAE 15 requires special permission for A3 refrigerant except for portable refrigeration? Will AHJ’s 

accept?

Workplace 

 Water coolers, vending machines near means of egress?

Residential 

 DIY quick connects for split system A/C?

 Multi-family dwellings?

 Potential for installation markings not taking into account multiple units with flammable refrigerant 

charge

 Need for odorization?

 Anticipate huffing?

Special Occupancies (School / Institutional) 

 Concern with vandalism, abuse?

 “Unregulated” portable equipment

Servicing 

 Training of technicians? Toolbox contents?

 Repairing in-place? Recovery? Charging? Discharging (what does Clean Air Act allow)?

 Availability of flammable refrigerant recovery equipment?

 Preventing DIY

Fire Service (mass storage / warehousing) 

 Identification of equipment w/ flammable refrigerant?

 Venting due to overpressure?

 Warehouse (and other) sprinkler design density

 Do “design to code” installations have adequate “safety margin?”
Report of Flammable Refrigerant Stakeholder Forum

Underwriters Laboratories Inc. Page 3 of 6 January 2011

End-of-Life 

 Rules for disposal? 

 Venting of “natural refrigerant?”

Refrigerant Supply Chain

 What types of cylinders for service (5# vs larger)?

 Fuel grade versus refrigerant grade HC’s? Anything different in supply chain? 

 Need for odorant? Consistent color-coding of refrigerant containing components?

6. Future Plans 

Upon completion of the general discussion on stakeholder impact, the participants summarized the gaps 

identified and related observations. The intent was to capture where stakeholders could individually or 

collectively take future action. These can be found in Appendix B.

Stakeholder participation in UL product safety consensus committees was discussed. Subject to 

maintaining a balance of interests, UL encouraged participants to consider membership in these 

committees. Refer to Appendix C for details on the interest categories and how one could apply for 

membership.

The remainder of the forum was spent discussing the value of the meeting and whether another such 

meeting should be held at a later date. The consensus was that there was a good exchange of 

information and the participants believed that another meeting should be held shortly after the adoption of 

EPA’s final rule on hydrocarbon refrigerants. UL agreed to organize such a meeting at that time.

7. Close 

The meeting was closed by 5 pm. All the participants were thanked for their contributions to an open and 

informative dialogue.

Report Recorded by UL Staff
Report of Flammable Refrigerant Stakeholder Forum

Underwriters Laboratories Inc. Page 4 of 6 January 2011

APPENDIX A – Forum Participants

Name Company

Alan W. Perdue International Association of Fire Chiefs

Andrew Sullivan Liebherr Refrigeration

Barry Kalian UL

Bruce E. Johnson International Code Council

Chuck Schlosser Manitowoc Ice

Christianna Papazachariou Shecco

Cindy Newberg U.S. Environmental Protection Agency

Claire Kammer UL

Claudette Juska Greenpeace

Dave Godwin U.S. Environmental Protection Agency

Ed Altizer Virginia State Fire Marshal & IFMA

Evelyn Swain U.S. Environmental Protection Agency

Glenn Hourahan Air Conditioning Contractors of America

James Douglas Tecumseh Products Company

Jeff Staub Danfoss

Jim Flowers Linde Canada

Karim Amrane Air Conditioning, Heating, and Refrigeration Institute (AHRI)

Kevin Daniels UL

Kevin Messner Association of Home Appliance Manufacturers (AHAM)

Lasse Lykke Espersen Nestle

Marc Scancarello Emerson Climate Technologies

Margaret Sheppard U.S. Environmental Protection Agency

Matt Williams Association of Home Appliance Manufacturers (AHAM)

Monica Shimamura U.S. Environmental Protection Agency

Patrick Walsh Association of Home Appliance Manufacturers (AHAM)

Phillip Johnson McQuay International

Rafael Sanchez U.S. Environmental Protection Agency

Randy Haseman UL

Reinhold Resch AHT Cooling Systems Austria

Robert Wilkins Danfoss

Roy Deppa National Association of State Fire Marshals

Scott Ayers U.S. Consumer Product Safety Commission

Scott MacLeod UL

Sonny G. Sundaresan Sundaresan Consulting Services, LLC

Tom Blewitt UL

Representatives from North American Association of Food Equipment Manufacturers (NAFEM), Food 

Marketing Institute (FMI) and National Fire Protection Association (NFPA) were also invited, but were 

unable to attend.
Report of Flammable Refrigerant Stakeholder Forum

Underwriters Laboratories Inc. Page 5 of 6 January 2011

APPENDIX B – Action Items

Potential gaps in standards, codes and regulations regarding the use of flammable refrigerants identified 

by the stakeholders present during the forum discussion are shown bulleted below. No formal attempt to 

validate the gaps identified or to develop a consensus approach to address them was performed, 

 There was discussion about a reported fire event attributed to the lubricant of a fire suppression 

system described as comparable to a system containing a Class 1 refrigerant. Do ASHRAE 

standards 15 and 34 need to consider the potential for fire from lubricants?

 Do ASHRAE standards 15 and 34 need to consider the potential for ignition of fusite due to a 

lightning strike on outdoor installations?

 Current published refrigerant standards (e.g. ASHRE 34, ISO 817 and UL2182) make no specific 

reference to purity / impurity requirements for refrigerants (flammable or otherwise). Should they?

 Stenching (odorization) is required for LP fuel gas. Should hydrocarbon refrigerants be odorized? 

 UL 484 labeling requirement for allowable charge vs room size for room AC units does not take into 

consideration the potential use of multiple units in a single room. [The Joint Task Group of product 

safety standards technical panels will consider this matter.]

 UL471 refrigerant leakage test does not specifically take into account the proximity of adjacent 

appliance ignition sources. [The Joint Task Group of product safety standards technical panels will 

consider this matter.]

 EPA Snap flammable refrigerant notice of public rulemaking does not currently address vending 

machines, household AC, water coolers, chillers, dehumidifiers and ice machines.

 There is no known published EU or US standard regarding servicing of non-industrial appliances and 

HVAC/R containing hydrocarbon refrigerants. It is reported that discharge to the atmosphere is 

permitted in Europe. If so, what criteria are applied? [Secretary Note: Subsequent to the meeting, a 

participant provided background information published by German Technical Cooperation – Programme Proklima, 

“Guidelines for the safe use of hydrocarbon refrigerants.” It is available for download at 

http://www.gtz.de/en/themen/umwelt-infrastruktur/28719.htm. Note that this document is being cited for reference 

only and should not be construed as endorsed by the Stakeholder Forum or Underwiters Laboratories Inc.]

 No public training or certification program is known to exist for service technicians and other handlers 

of flammable refrigerants during servicing and disposal. “EPA 608” requires a one-time certification 

of technicians working with ozone depleting substances and EPA develops the test(s) for certification 

that are administered by organizations recognized by EPA. This certification is not required for 

hydrocarbon refrigerant service technicians.

 Servicing of un-odorized hydrocarbon refrigerant systems in household and commercial applications 

could result in an undetectable flammable gas – air mixture in the occupancy. Should these units be 

serviced off-site? Should the hydrocarbon refrigerant be stenched?

 Retailers, insurers and end of life equipment recyclers do not appear to be part of the current 

standards and related activities regarding flammable refrigerant use. Should they be?

 The Clean Air Act requires recovery of refrigerants including hydrocarbons using equipment 

authorized by EPA. The reported EU practice is understood to be that hydrocarbon refrigerants are 

not required to be recovered, and that their environmental release is acceptable within limits. Should 

the US consider emulating this practice? If so, what restrictions if any should apply? Will there be 

refrigerant recovery equipment and processes suitable for use with flammable refrigerants? 

 Storage locations may be designed for fire suppression on the assumption of the known heat of 

release for traditional refrigerants. The presence of flammable refrigerants may require reevaluation 

of a sprinkler system design.

 Traditional refrigerants (aside from ammonia) have been exempted by fire codes from regulations 

affecting flammable gas installations. Where such regulations consider hydrocarbon gases, these 

gases are assumed to be odorized as required by NFPA 58 for fuel gases. Should odorization 

(stenching) of hydrocarbon refrigerants be considered?
Report of Flammable Refrigerant Stakeholder Forum

Underwriters Laboratories Inc. Page 6 of 6 January 2011

APPENDIX C – Consensus Committee Membership

What are UL Standards Technical Panels and how do you become a member?

A Standards Technical Panel (STP) is a balanced group of individuals representing a variety of interest 

categories, formed to review submitted proposals and to meet and discuss UL standards-related issues. 

An STP serves as the consensus body to review and vote on proposals prior to publication. The interest 

categories for a UL STP are defined as follows: 

• Authority Having Jurisdiction (AHJ): Those involved in the regulation or enforcement of the 

requirements of codes and standards at the regional (e.g. state or province) and/or local level.

• Commercial/Industrial User: Organizations that use the product, system, or service covered by the 

applicable standards under the STP in a commercial or industrial setting. An example is a 

restaurant owner/operator serving on an STP for commercial cooking equipment.

• Consumer: Consumer organizations, consumer departments at universities, home economic 

departments at universities, and professional consumers.

• General Interest: Consultants, academia, scientists, etc. that are not covered by the other 

participation categories, also including professional societies, safety experts, and trade 

associations.

• Government: Representatives from national government agencies. For U.S. representatives these 

may include CPSC, FDA, EPA, DOT, DOE, DOD, NIST, etc.

• Producers: For standards establishing product requirements, a representative of a company that is 

engaged in the manufacture of products covered by the standard.

• Supply Chain: Component producers for an STP responsible for standards covering end products, 

or end-product producers for an STP responsible for standards covering components; and 

installers, distributors, and retailers.

• Testing and Standards Organization: Organizations that test and/or certify products, services, or 

systems covered by the standard, or that develop standards/codes related to the products, services, 

or systems covered by the standard.

• International Delegate: An individual representing a National Standards Body outside the United 

States (e.g. JISC, DIN).

There are no membership dues associated with STP’s, and anyone interested in membership is 

encouraged to complete an STP application. The STP Chair appoints members to the STP based on 

completed applications, and UL’s goal is that an interest category should not exceed 33.3% of the overall 

membership. Therefore, balance plays a role in determining acceptance to the STP.

To view all active STP’s, their scopes and responsible UL staff, visit:

http://ulstandardsinfonet.ul.com/stp/active-stps.html

If interested in joining an STP, send a request for an STP application to the responsible STP Project 

Manager. Additional information regarding UL STP’s can be found at:

http://ulstandardsinfonet.ul.com/stp/