RE: UL 484 

Monica Shimamura to: richard 11/20/2009 11:03 AM

Cc: Margaret Sheppard, gary

Follow Up: Normal Priority. 

Hi Richard,

The SNAP program does not provide "clearance" for an alternative refrigerant. Instead,

it finds alternatives acceptable, acceptable subject to use conditions, acceptable

subject to narrowed use limits, or unacceptable in a particular end-use. The original

SNAP rule, published in the Federal Register on March 18, 1994 (59 FR 13044,

available at http://epa.gov/ozone/fedregstr/59fr13044.html), clearly explains that EPA

would review substitute refrigerants in the end-use for which they are intended, and that

an acceptability determination in one end-use does not apply to other end-uses. 

Therefore, we are seeking to understand the risks associated with your refrigerants in

the variety of window-air conditioner appliances that may eventually use those

refrigerants, as well as any safety mitigation strategies or components that may be

employed. We feel that a national safety standard that, unlike UL 484 today, addresses

the use of a flammable refrigerant, helps such understanding. While it may be the

appliance manufacturer or appliance user rather than the refrigerant producer that is

subject to potential use restrictions, we must address these issues before we make a

final determination on a particular substitute.

Concerning the testing procedure using UL 484, it is not so much that it was the

"incorrect procedure" as that the standard in its current form does not sufficiently

address the risks specific to flammable refrigerants. Without tests to address those

specific risks, we are concerned that the test results may not show whether a passing

window AC unit with HCR-188C or HCR-188C1 is comparable in risk to a passing

window AC unit with a non-flammable refrigerant.

Thanks,

Monica

Monica Shimamura

U.S. Environmental Protection Agency

Stratospheric Protection Division

1200 Pennsylvania Ave. NW (6205J)

Washington DC 20460

(tel) 202.343.9337

(fax) 202.343.2362

Address for hand delivery (UPS/Fed Ex/etc):

1310 L St. NW, 10th Floor (1027N)

Washington DC 20005

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richard To all. 11/18/2009 01:57:46 PM

From: richard@astrust.com

To: Robert Hill Intertek <robert.hill@intertek.com>, Scott Mautz Intertek <scott.mautz@intertek.com>

Cc: Wayne Reeves Intertek <wayne.reeves@intertek.com>, Matt Snyder Intertek

<matt.snyder@intertek.com>, Monica Shimamura/DC/USEPA/US@EPA, Margaret

Sheppard/DC/USEPA/US@EPA, gary <riskscicom@aol.com>

Date: 11/18/2009 01:57 PM

Subject: RE: UL 484

To all.

As explained to me via phone conversation by Monica Shimamura of the EPA on Thursday November 12, 2009.

Intertek is only a testing body and does not write the test protocol for a hydrocarbon refrigerant. UL writes the tes

procedure and are testing window air conditioners at this time. UL will be coming up with a test procedure and

refrigerant charge amount for hydrocarbon refrigerants to be used in a window air conditioner.

I was informed the test procedure done on the window air conditioner using UL484 is incorrect. This can be verif

Monica at the EPA.

Monica: this is what was explained to me as I understood it. Is this correct?

This is the reason my window ac listing is being held up. I have to wait for UL to come up with a charge amount 

plan for window ac units which will take 6 to 8 months.

I just developed the refrigerant. The industry has to comply with how it uses it. Holding HCR188C or HCR188C

has nothing to do with the appliance. I'm coming in for an alternative refrigerant clearance not an appliance clear

Thank you

Richard

Richard Maruya

phone 808 2351890 

fax 808 235 0116

cell 808 5614688

e mail richard@maruya.net or richard@astrust.com

web site HCR188C www.hcr188c.com

The "CLIMATE FRIENDLY" Refrigerant
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intended recipient, or the person responsible for delivering the message to the intended recipient, then please noti

return e-mail immediately. Should you have received this e-mail in error then you should not copy this for any pu

nor disclose its contents to any other person.

--- On Wed, 11/18/09, Scott Mautz Intertek <scott.mautz@intertek.com> wrote:

From: Scott Mautz Intertek <scott.mautz@intertek.com>

Subject: RE: UL 484

To: "Robert Hill Intertek" <robert.hill@intertek.com>

Cc: richard@astrust.com, "Wayne Reeves Intertek" <wayne.reeves@intertek.com>, "Matt Snyder Intertek"

<matt.snyder@intertek.com>

Date: Wednesday, November 18, 2009, 8:16 AM

As far as Safety is concerned, The EPA allowed us to list with this refrigerant. We made sure the components were compa

this refirgerant and did testing to verify that it still complied with UL 484 with regards to pressures. The compatibility test w

already performed on the compressor and Richard provided us with the data done in our Columbus Facility.

Scott Mautz

Project Engineer - HVAC Safety / Quality Manager

Phone: 607-758-6557

Intertek

3933 US Route 11

Cortland, NY 13045

Fax: 607-758-6595

Mobile: 315-415-1109

E-mail: Scott.Mautz@intertek.com

www.intertek-etlsemko.com

CONFIDENTIALITY NOTICE

This e-mail may contain confidential or privileged information. If you are not the intended recipient, or the person responsible for delivering the message 

intended recipient, then please notify us by return e-mail immediately. Should you have received this e-mail in error then you should not copy this for an

nor disclose its contents to any other person.

From: Robert Hill Intertek

Sent: Wednesday, November 18, 2009 1:12 PM

To: Scott Mautz Intertek

Cc: richard@astrust.com

Subject: FW: UL 484

Scott,

I believe that Richard has this information and what is needed to explain to the EPA is compliance to UL 484.

Thanks,

Robert J. Hill

Senior Engineer / HVAC Sales

Telephone +1 607 758 6270
Intertek

3933 US Route 11

Cortland, NY 13045

Cell: +1 607 423 3190

Fax: +1 607 753 7560

Email Address: robert.hill@intertek.com

www.intertek.com/hvac

From: Scott Mautz Intertek

Sent: Wednesday, November 18, 2009 12:43 PM

To: Robert Hill Intertek; Wayne Reeves Intertek

Cc: Wayne Niggli Intertek

Subject: RE: UL 484

See the attached

Scott Mautz

Project Engineer - HVAC Safety / Quality Manager

Phone: 607-758-6557

Intertek

3933 US Route 11

Cortland, NY 13045

Fax: 607-758-6595

Mobile: 315-415-1109

E-mail: Scott.Mautz@intertek.com

www.intertek-etlsemko.com

CONFIDENTIALITY NOTICE

This e-mail may contain confidential or privileged information. If you are not the intended recipient, or the person responsible for delivering the message 

intended recipient, then please notify us by return e-mail immediately. Should you have received this e-mail in error then you should not copy this for any 

nor disclose its contents to any other person.

From: Robert Hill Intertek

Sent: Wednesday, November 18, 2009 11:20 AM

To: Wayne Reeves Intertek; richard@astrust.com

Cc: Wayne Niggli Intertek; Scott Mautz Intertek

Subject: UL 484

Wayne,

Scott mentioned that you received a letter regarding the HCR-188C in the room air conditioner and also a ruling from Bill Fis

additional information that you can give Richard for him to submit to the EPA will be helpful. EPA consulted with UL and the

that ETL could not list that refrigerant per UL 484 and Richard needs to show the EPA how we got a round that.

Thanks,

Robert J. Hill

Senior Engineer / HVAC Sales

Telephone +1 607 758 6270

Intertek
3933 US Route 11

Cortland, NY 13045

Cell: +1 607 423 3190

Fax: +1 607 753 7560

Email Address: robert.hill@intertek.com

www.intertek.com/hvac

CONFIDENTIALITY NOTICE

This email may contain confidential or privileged information, if you are not the intended recipient, or the person responsible for delivering the message t

intended recipient then please notify us by return email immediately. Should you have received this email in error then you should not copy this for any p

disclose its contents to any other person.

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