A.S. TRUST & HOLDINGS
 

44-129 MIKIOLA DRIVE
 

KANEOHE, HI 96744
 

TELEPHONE: (808) 235-1890 FAX: (808) 235-0116 CELLNM: (808) 561-4688
 

EMAIL: richard@astrust.net
 

February 25.2012 

Margaret Sheppard 

Environmental Scientist 

Significant New Alternatives Policy Program 

USEPA/Stratospheric Protection Division 

Margaret: 

The response to the New Vending Machine application is as follows. Please refer to 

attachments: 

•	 The Guidelines for use of HCR I88C/R44 IA. 

o	 Page 5: The cylinder size and type 

o	 Page 12: Recovery cylinder type 

•	 Comstar letter and documentation on cylinder type. 

•	 Brandon Button's email on recovery machines. At present there is no recovery 

machine available for flammable refrigerants. His email will explain the 

situation. I am using an existing recovery machine without any problems. 

Brandon is the AHRI testing engineer for recovery machines at Intertek in 

Columbus, Ohio. Email address: brandon,button@intertck,com and phone 

number: (614) 2798090 

•	 Copy of my certification on refrigerant recovery. At present, there is no EPA 

certification for recovery of flammable refrigerants. VCI training center has 

informed me they are working on one and hope to get it out by the end ofthis 

year. 

On the matter of a safety standard for flammable refrigerant in vending machines, 

I contacted Mr. Emad lafa at Pepsi and his response was that he has no idea. See 

attached. I also contacted Mr. Michael Lideman of Intertek in Columbus, Ohio. Michael 

informs me UL541 is the correct safety guideline for vending machines. See attached 

email. 

I feel all of your questions have been answered. 
Guidelines for Using HCR188C R441A/R443A in Refrigeration and Air Conditioning 

Systems

R441A and R443A will be referred as HCR188C

Introduction

HCR188C is a new hydrocarbon-based refrigerant that does not deplete our Earth’s 

protective ozone layer like fluorocarbon refrigerants including R-12 and R-22. 

It is now known that breathing these chlorofluorocarbon and hydrochlorofluorocarbon 

(CFC’s and HCFC) refrigerants can cause oxygen deprivation, serious heart problems 

and possibly other health issues. For these and other technical reasons, ozone-safe 

HCR188C was developed to replace all of the legacy fluorocarbon refrigerants. 

A direct replacement for fluorocarbon refrigerants, HCR188C is compatible with gaskets, 

seals, and most lubricants in existing refrigeration systems. HCR188C is also an 

economical replacement for the medium-pressure automotive refrigerant 134a. 

HCR188C is flammable like other hydrocarbon products and must be used only by HVAC 

personnel trained and certified in the specific, safe handling procedures for HCR188C. 

Fully trained and EPA-certified HVAC personnel following these precautions will find

that HCR188C is easily and safely charged into legacy HVAC systems. 

Although HCR188C is flammable, very little is used to charge a refrigeration system; 

usually only 25-35% for R441A and 30-40% R443A of the charge of fluorocarbons! 

Workplace safety is no accident! That is, it does take an effort to learn and to follow new 

safety procedures and to make them part of every refrigerant retrofit job. You alone have 

the responsibility to follow these HCR188C safe handling procedures to prevent accidents

and injuries and to uphold the high safety standards of the HVAC industry. 

Waiver of Liability Statement

This summary of safe handling procedures is intended for professional HVAC 

technicians servicing stationary home air condition systems, refrigeration, and 

automotive air condition systems containing HCR188C. Only trained, licensed and EPAcertified HVAC technicians have received specific safety training and are authorized to 

service equipment containing HCR188C. 

This material is not approved for use by Do-it-Yourself amateurs, home owners and alley 

mechanics. The hobbyist and HVAC professional alike are strongly cautioned that all 

liability is entirely the end user’s responsibility including equipment failure, personal 

injury, death, and loss of property. Standard disclaimers apply. 
2

HCR188C Safe Handling Procedures

SECTION 1.

The following procedures apply to all users of HCR188C. Specific precautions 

and safe practices for automotive, light refrigeration, and air conditioning service are 

summarized in sections following these general precautions: 

Personal Protective Equipment – PPE is always used for extra protection, just in case 

something goes wrong and energy is unexpectedly released. Anyone handling this 

refrigerant must use the following personal protective equipment (PPE): 

Eye Protection - Refrigeration technicians and observers must wear Z87.1 

approved mechanical safety glasses when 

• moving, connecting, & installing HCR188C gas cylinders 

• working on equipment, piping, & fittings containing HCR188C 

• charging or recovering HCR188C from a refrigeration system 

•

Hand Protection - Wear gloves for thermal protection since 

• operating compressors may exceed 120 Fo causing skin burns

• keep a first aid kit where you can reach it 

• expanding HCR188C reaches subzero temperatures instantly causing 

frostbite on contact 

Frostbite First Aid

• Immerse with water at 100 – 110oF to warm rapidly. Use body heat 

or warm air if a water bath or shower are unavailable. 

• Do not expose the wound to an open fire or flame. 

• Do not rub or massage the affected parts of the body. 

• Patients should not walk on frostbitten feet. 

• Do not use medications. Do not apply dressings on intact skin. 

• Keep the patient calm and at normal body temperature until 

medical help arrives. 

Controlling Energy – Search for these hazards and eliminate them from the work area 

before working with HCR188C: 

Ignition Sources - Eliminate open flames or other ignition sources like operating 

thermostats, relays, & open frame motors. 

Do not light a halogen flame leak detector, candle, or strike a match. 
3

Remove or eliminate hot surfaces from the work area including bare light 

bulbs, hot plates, and other hot surfaces near the refrigerant or working area, 

for example, use a shielded fluorescent work light 

Table of Ignition Sources*

Arc welding, plasma arc cutting Open flame, burning candle, lantern

Cigarette or other burning material Open frame motors

Condensate pump switch On/off manual switches 

Contactors Oil differential switches 

Defrost timers/switches Pressure switches 

Fan delay switches Propane or MAPP gas soldering torch 

Fan speed controllers Potential relays 

Flow switches Start relays 

Gas welding or cutting torch Static electricity

Halogen flame leak detector Striking a match

Hot automotive exhaust system Thermostats 

Hot plate or oven Thermal overload relays 

Humidity controllers Time switches/relays 

Incandescent light bulb Universal relays 

Isolator switches Programmable controllers 

Liquid level switch * List is not exhaustive 

Prevent live sparking of components and electrocution

• replace or install line shields over electrical contacts 

• use solid state relays and controllers in equipment 

• fix loose capacitors and other electrical ignition sources 

Warning Labels - Replace any missing ignition source warnings on HCR188C 

equipment and gas lines. 

No Open Flames

No Smoking

Lockout Tag out (LOTO) - Lockout and tag electrical disconnect switches to 

protect the worker from energized electrical controls and unexpected motor starts. 

The tag lists the name and tag out date. 

• pull fuses or trip circuit breaker before working 

• disconnect battery in automotive work 

• test after de-energizing electrical lines 
4

Energy Stored as Compressed Gas - Relieve system gas pressure before 

installing safety retrofit kit 

• pump out and recover refrigerant 

• pump out before breaking fittings 

Job Hazard Review – It is the refrigeration technician’s first duty to size up the work 

area and equipment to identify and mitigate hazards before starting work. A Hazard 

Review will assure that energy is controlled and adequate PPE is used. 

First, list the sequence of steps or tasks for the job at hand. Then list what can go 

wrong at each step. Finally list the safety factors and PPE necessary to prevent accident 

or injury. This is a good opportunity for HVAC technicians and their supervisor to work 

the JHR together, developing safe work practices for routine jobs. 

Job Hazard Review: Cutting the Refrigeration Line to Install a Retrofit Safety Valve

Task Problem Accident Prevention PPE Required

1. pump out old refrigerant Vacuum pump fittings leak 

Hose separates from quick 

connect 

Inspect/Replace O-rings 

Push collar until fitting locks 

Gloves, Safety Glasses 

Gloves, Safety Glasses 

2. cut refrigeration tubing Sharp edges on cut tubing Use deburring tool Gloves, Safety Glasses 

3. install retrofit valve Tight tubing fit, may leak Sand off paint layer first Safety Glasses 

Checks for Electrical Hazards

• verify that electrical ignition sources are eliminated 

• check that electrical equipment and lines are in good condition 

• complete an electrical ground continuity check 

• isolate electrical line voltages from the work area 

• verify that lock out tag out is complete 

Checks for Mechanical Hazards

• check that guards and shields are installed and in good condition 

• inspect entrapment and pinch points around rotating equipment 

• remove gloves before working around rotating equipment 

• secure loose clothing, long hair, and jewelry 

• do not work around rotating shafts, pulleys, and belts unless guards 

are complete and in place 

Ask “what can go wrong” and what if...?

• Answer all questions raised before starting work 

• Are eye protection and other PPE adequate if something goes 

wrong? 
5

• If there is a fire, where is the fire extinguisher? 

• Is there a clear exit route from the work area for evacuation? 

Storing and Transporting HCR188C - We are all required to follow Federal, State and 

Local safety laws, and the consensus Standards; for example from the American National 

Standards Institute (ANSI), The National Fire Protection Association (NFPA), and the 

American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE). 

Some of these standards and safety codes are summarized: 

• Close the cylinder (canister) valve after each use and when in storage 

o Screw the shipping plug into the cylinder valve before shipping

• Strap or chain cylinders to secure in storage 

o Store the cylinder upright 

o Lock the cylinder to prevent tampering

o 3-point contact with other cylinders in storage is permitted

• Keep oxygen cylinders away from cylinders of HCR188C or equipment 

containing HCR188C 

o Comply with local codes on flammable gases

o Store with a 20 ft minimum separation or use a rated 1⁄2 hour fire wall

between oxygen and HCR188C cylinders

• Take precautions against overfilling 

o The cylinder must have a working overpressure relief device

o Never invert the HCR188C cylinder. The pressure relief device must

relieve from the vapor phase, not the liquid phase

o Fill recovery cylinders only to 80% capacity 

o The cylinder must have an overfill protection device

• Store HCR188C at an ambient air temperature less than 120oF 

o Do not expose the cylinder to fire or strike an electric welding arc on the 

cylinder 

o Immediately return a cylinder to the vendor if damaged 

o HCR188C is filled in Dot-39 20 lb cylinders. Should a need for a smaller    

 cylinder be required for service technicians, a cylinder no less than 5 lb will 

 be available. 

 Confined Space Warnings – You can die by asphyxiation if you store or use HCR188C 

in a confined space. HCR188C like other combustible and inert gases is an asphyxiate. 

These gases displace breathing air when released. 

• Do not use HCR188C in an unventilated room or space 

o Especially do not use it below grade or ground level.

o Do not enter any confined space together with a gas cylinder188C

o For Example, do not ride in an elevator with any gas cylinder 

Do Not Ride Elevator with

A Compressed Gas Cylinder
6

• If someone is unconscious in a confined space, do not enter to attempt a rescue. 

You will become a second victim. Immediately call 911 for help. 
7

Retrofit Labeling and Color Code – Safety instructions are prominently labeled on the 

compressor and on the condenser coil. Alert others by replacing any missing pink stickers 

on compressors and systems containing or retrofitted with HCR188C. (Pink is the EPAapproved color code for HCR188C). 

• The Certified Refrigeration Mechanic completes the required information 

details on the preprinted pink stickers: 

o The installer’s name 

o The service company’s address

o Date of retrofit

o HCR188C charge rate for the system, grams

NOTICE: Converted to HCR188C

Non-Ozone Depleting

This Refrigerant is FLAMMABLE - Take Appropriate Precautions

Service by Qualified Personnel Only

SERVICED BY: TECHNICIAN: 

COMPANY: _ _ _ 

ADDRESS: _ _ 

_ _ _ _ 

DATE: _ REFRIGERANT: HCR188C 

CHARGE AMOUNT: LBS. OZ. [ Grams ] 

DO NOT ADD LUBRICANT DO NOT REMOVE THIS LABEL
8

Leak Detection - Learn about and prepare equipment for portable leak detection of 

HCR188C. The manufacturer blends HCR-188C with a warning odor agent (mercaptan) 

smell. 

• Warning Odor 

o Replace any missing warning labels on all appliances

o Use a polymer-soap solution to find gross leaks

o Use a battery powered gas sensor for detecting hydrocarbon refrigerant

o check all connections and lines with a leak sensor after servicing any unit

o DO NOT use a halogen flame leak detector 

HCR188C Warning Odor - Light Refrigeration

• If warning odor is noticed, extinguish smoking materials, 

turn off burners and other open flames. 

• Immediately open windows and doors for ventilation. 

• Leave the room. 

• The AC manufacturer has added fluorescent dye to the system before 

charging 

o Use an ultraviolet light to find the leak

• Tool and equipment Safety and Best Practices

o Use only proper tools and servicing equipment approved for HCR188C

o Never improvise tools and service equipment

o Piping and fittings-Comply with all codes, standards, and best practices
9

SECTION 2

.Automotive Air Conditioning Precautions

Installation of the Retrofit Safety Check Valve (RSCV)* is mandatory on supply 

and return lines whenever performing an automotive or a split-system air conditioning 

retrofit to HCR188C. The RSCV includes the EPA-approved quick connect fittings for 

HCR188C in a tamper-proof design to prevent accidents and injuries. 

The RSCV is a required safety device installed on the engine side of the firewall. 

It protects the passenger compartment from a slow evaporator coil leak and also prevents 

a refrigerant discharge into the passenger compartment from AC tubing severed in a font 

end collision. The EPA-approved pink color code dust cap seal and pink stripe identify 

the HCR188C Retrofit Safety Check Valve. 

Figure 1. Required Locations of the HCR188C Retrofit Safety Check Valves (RSCV) 
9

Front View Side View 

Figure 2. HCR188C Retrofit Safety Check Valve * (pink dust cap not shown) 

*patent pending

Retrofit Safety Check Valve Installation Instructions

• Recover pre-existing fluorohydrocarbon refrigerant by pumping into an 

evacuated and labeled refrigerant canister 

o cut out the legacy high and low pressure ports

o deburr the tubing ID and OD to remove any metal chips

o remove paint or powder coat layer from tubing OD

using stoppers to keep tubing clean inside

o insert RSCV into appropriate high and low pressure lines 

o apply sealant onto the compression ferrule sleeves

o orient the quick connect fittings vertically upwards

o use two opposing wrenches to properly tighten compression fittings

• Use only piping with the required HCR188C pink label 

• Use only the dedicated pink-labeled HCR188C refrigerant recovery tanks 

o Use an oil filter when recovering HCR188C

o Do not recharge recovered HCR188C back into refrigeration system

since HCR188C composition changes during recovery and precludes 

reuse 

o Reclaimed HCR188C can be used as gas BBQ grill fuel 

Warning and Precautions

HCR188C Warning Odor - Automotive

• If warning odor is noticed, extinguish smoking 

materials 

• Roll down windows 

• Pull off the road when safe to do so 

• Turn off ignition, step away from the vehicle 
10

SECTION 3.

Automotive Air Conditioning and Split Unit Air Conditioning

CHARGING – This section describes the approved procedures for charging 

evacuated CFC or HCFC System with up to HCR188C. This work is to be 

performed only by a Certified Air Conditioning Technician. First inspect the work 

site and remove or fix hazards before starting. Always charge the system with fresh

HCR188C to assure the correct charge rate; do not reuse recovered HCR188C. 

Please see Appendix II for maximum allowable refrigerant charge based on 

occupancy category and room size. 

• Hookup – Connect the HCR188C charging canister to a gauge set 

o check the vacuum pump capacity, HCR188C cylinders, and fittings

o Inspect condition of hoses, fittings, gaskets and O-ring seals

o use the EPA-approved HCR188C adapter connectors on a standard

low pressure gauge set

o use the EPA-approved HCR188C cylinder connection 

• Preparation – Charge the system with HCR188C 

o Unlock both Retrofit Safety Check Valves (RSCV)

• insert a splined Allen wrench through the quick connect stem 

• engage and turn clockwise until the screw stops turning 

• attach gauge set hoses with HCR188C adapter fittings to both 

RSCVs and to vacuum pump before opening slider valve

o Open slider valve 

• Slide stem horizontally over the pedestal until cleat stops, 

aligning the internal valve service ports 

o Pump down the system 

• evacuate the system to remove moisture and air 

• close the vacuum port valve 

• Charging the System – Calculate HCR188C charge rate (0.25 x CFC 

charge). 

o attach HCR188C canister 

• set on digital scale and tare scale 

• open canister valve until calculated charge flows into system. 

•

• Sealing the System – Close the HCR188C canister valve. 

• slide retrofit safety check valves (RSCVs) closed 

• disconnect gage set hoses and fittings 

• set anti-tamper lock screw in RSCVs 

• install pink cap and tamper seal 

RECOVERY – This process describes the approved procedures for recovering and 

recycling HRC188C refrigerant by a Certified Motor Vehicle Air Conditioning 
11

(MVAC) Technician. First inspect the work site and remove or fix hazards before 

starting the recovery and making repairs. 

• Hookup – Connect the empty HCR188C recovery canister to a gauge set 

o inspect condition of hoses, fittings, gaskets and O-ring seals

• use the EPA-approved HCR188C adapter connectors on 

standard low pressure gauge set

• use the EPA-approved HCR188C cylinder connection 

• install an oil separator when recovering HCR188C 

o connect the hose between the vacuum pump and recovery cylinder 

• evacuate the recovery cylinder 

• repeat to evacuate additional recovery cylinders 

• Evacuating the System –unlock the Retrofit Safety Check Valves

• insert splined Allen wrench through the quick connect stems 

• engage and turn counterclockwise to back out lock screw 

• do not slide valve to open until hoses are attached 

o attach gauge set hoses with HCR188C adapter fittings 

• connect to a refrigerant recovery machine (pending EPA 

clearance) 

• if not available, set evacuated canister onto top-loading digital 

scale; tare to monitor recovery 

o open slider valve sliding horizontally over the pedestal until cleat stops 

travel 

o pump down system

• evacuate the system to remove moisture and air 

• when fully evacuated, close the vacuum port valve 

• Recovering into an evacuated recovery canister

o open the refrigerant canister valve to recover HCR188C from AC

system

o after recovery, look for a pressure increase on the gauge 

• this shows that some refrigerant remains dissolved in oil and 

that additional recovery is needed

• continue recovery with another evacuated recovery canister 

until the system holds vacuum 

o disconnect recovery setup when pressure is constant

• close both HRC188C RSCVs 

• close recovery canister valve 

• disconnect gage set hoses and fittings 

• Sealing the System – Close the HCR188C canister valve. 

o lock RSCVs

• set anti-tamper screw in RSCVs 

• install pink cap and tamper seal 

o label recovery cylinder contents 
12

• Recovered HCR188C is not recharged back into refrigeration system

o Note that composition changes during recovery preclude reuse of 

recovered HCR188C . Recovery cylinder DOT -4BA-400 would 

be best suited for this use 

o Reclaimed HCR188C can be used as gas BBQ grill fuel

• recharge repaired system with fresh HCR188C to assure the 

correct charge rate 
13

Section 4,

Window Air Conditioner, Air Conditioner, Refrigerator, Freezer, Vending Machines 

including Wine Chillers and Dehumidifiers

This section describes how to recover HCR188C from appliances at the end-of-appliance 

life. Applicable precautionary measures from Section 1 are required when recovering 

HCR188C. The refrigerant recharging process for light refrigeration is also reviewed. 

• The HVAC Technician recovers the refrigerant using either a recovery 

machine or following the recovery process described above in Section 3. In 

both processes an oil separator is required to isolate clean HCR into the 

recovery canister. 

•       If no access port is available, a vampire connection is used to recover all 

HCR188C from the system under repair, e.g.: removing the compressor or 

removing evaporator. Old refrigerant is recycled as described in Section 3.

• Following the HCR188C recovery, a hand tubing cutter can part the tubing, 

then compressed air or flushing fluid is used to clear the system of any 

remaining oil/refrigerant mixture. Clean and degrease all tubing surfaces to 

prepare for joining the new component. 

• The system is evacuated and recharged * through the vampire fitting. The 

Certified Refrigeration Mechanic completes the required information details 

on the preprinted pink sticker shown in Section 1: 

o The installer’s name 

o The service company’s address

o Date of retrofit

o HCR188C charge rate for the system, grams

• Legacy appliances may also require updating to sparkless electrical wiring 

and solid state or potted components to prevent ignition. 

* The EU and British standards for hydrocarbon refrigerants permit a 

maximum1.5 Kg. (3.3. lb) charge for sealed domestic appliances. 
14

SECTION 5. Commercial Refrigeration Compressor Room Precautions

• Room Design - Ensure that non-combustible materials are used for room 

construction 

o Design the room with pressure-relief blowout panels if a release of 

refrigerant will exceed the Lower Explosive Level (LEL) 

o Provide ventilation for the compressor room

• Vent room to outside air 

• place the air inlet at floor level sized match the air discharge fan 

• Maintain a negative air pressure balance 

• this prevents entrainment into occupied building areas 

• else, natural ventilation is acceptable if six to ten air 

exchanges per hour are maintained 

• avoid stratification that could occur in dead air areas, 

pits, confined spaces; install local ventilation to 

evacuate these spaces 

• Ensure free air movement around all components containing 

HCR188C 

• Run forced ventilation continuously, or 

• instead use an exhaust fan activated by fixed 

combustible gas sensor 

• instead use a fan relay set to ensure concentrations no 

more than 0.5%, which is 25% of the lower explosive 

level (LEL) 

• Use the following type of fan system 

• maintains a negative air balance 

o prevents leak flowing to other areas

• has non-sparking fan system components 

• has an emergency fan control outside equipment room 

• Use HCR188C fixed leak detection in compressor rooms

o Install permanent combustibles sensor if a release can reach the LEL

o The combustibles detector activates exhaust fan system and alarm

• A/V in mechanical room and at facilities trouble desk 

• mount heavier-than-air combustibles detector at floor level 

• the manufacturer must calibrate the detector for HCR188C, set 

below one-fourth of LEL=0.5% (as stated in OSHA 29 CFR 

1910.94) 

• service sensors at manufacturer’s recommended intervals 

• Administrative Controls

o Have a response plan if the detector signals a trouble alarm and 

practice the response action 

o Provide for compressor room security 
15

• The facility owner must provide access key access only to 

HCR188C-certified technicians 

o Post flammable gas warning signs at all entrances 

• The signs must warn <<No Open Flames, No Smoking>> 

o Eliminate Ignition Sources 

• No bare light bulbs, hot plates, other hot surfaces 

• use a shielded fluorescent work light

• No open flames or other ignition sources 

• use only brushless motors

• Boilers, welding torches, and other open-flame devices 

must not share this space 

• Insulate electrical contacts 

• use solid state relays and controllers in equipment 

• Enclose the ignition source and use an inert gas purge 

• if ignition sources cannot be removed

o Provide fire extinguishers to meet local code requirements
16

References

a. ANSI/ASHRAE Standard 34-2007, Designation and Safety

Classification of Refrigerants, 1791 Tullie Circle NE, Atlanta, GA 

30329 

b. Alaimo, R. J. ed, Handbook of Chemical Health and Safety, Oxford 

University Press, 2001 

c. Callahan, F. J. SwagelokTM Tube Fitting and Installation Manual; The 

Swagelok Companies; Solon, OH 1998 

d. DOE Jefferson Lab EH&S Manual, Cryogenic and ODH Safety; 

http://www.jlab.org/ehs/manual/EHSbook-434.html; 2000 

e. Clayton, G., Clayton, F., eds, Patty’s Industrial Hygiene and

Toxicology, 5th ed; Wiley and Sons: New York, 2000 

f. Colbourne, D., Ritter, T.J., Hydrocarbon Refrigerant Safety: 

Standards and Quantitative Risk Assessments, Calor Gas Ltd, 

Warwick CV34 6RL, UK 

g. EPA Stratospheric Protection Division, 

http://www.epa.gov/ozone/desc.html

h. European Standard EN 13313, Refrigerating Systems and Heat Pumps, 

Competence of Personnel, DIN Deutsches Institut fur Normung e. V, 

Beuth Verlag GmbH, Berlin, 2001 

i. National Fuel Gas Code: NFPA 54; National Fire Protection 

Association: Quincy, MA. 1999. 

j. OSHA Hazard Communication Standard, 29 CFR 1910.1200, 

appendix A 

k. OSHA Permit Required Confined Space Standard, 29 CFR 1910.146 

l. OSHA The Control of Hazardous Energy Standard, 29 CFR 1910.147 

m. OSHA Personal Protective Equipment Standards, 29 CFR 1910 

sections 132-138 

n. Storage, Use and Handling of Compressed and Liquefied Gases in 

Portable Cylinders: NFPA 55; National Fire Protection Association: 

Quincy, MA. 1999. 

o. Whitmyre, G. Compressed Gases: Compressed Hazards; American 

Chemical society; Washington, DC, 1995 

p. Whitmyre, G. Compressed Gases: Safe Handling Procedures; 

American Chemical society; Washington, DC, 1995 
17

Appendix I.

HCR188C replaces most of these medium-pressure refrigerants :

Ozone-depleting substances - Chlorofluorocarbons ("CFCs") 

(1) CFC-11, also known as fluorotrichloromethane 

(2) CFC-12, also known as diclorodifluoromethane 

(3) CFC-13, also known as chlorotrifluoromethane 

(4) CFC-111, also known as pentachlorofluoroethane 

(5) CFC-112, also known as tetrachlorofluoroethane 

(6) CFC-113, also known as 1,1,2-trichloro-1,2,2, trifluoroethane 

(7) CFC-114, also known as 1,2-dichloro-1,1,2,2-tetrafluoroethane 

(8) CFC-115, also known as 1-chloro-1,1,2,2,2-pentafluoroethane 

(9) CFC-211, also known as heptachlorofluoropropane 

(10) CFC-212, also known as hexachlorodifluoropropane 

(11) CFC-213, also known as pentachlorotrifluoropropane 

(12) CFC-214, also known as tetrachlorotetrafluoropropane 

(13) CFC-215, also known as trichloropentafluoropropane 

(14) CFC-216, also known as dichlorohexafluoropropane 

(15) CFC-217, also known as chloroheptafluoropropane 

Azeotropic Mixtures 

(16) CFC-500 (CFC-12/HFC-132a, 73.8/26.2 wt. %) 

(17) CFC-501 (CFC-12/HCFC-22, 25.0/75.0 wt. %) 

(18) CFC-502 (HCFC-22/CFC-115, 48.8/51.2 wt. %) 

(19) CFC-503 (CFC-13/HCFC-23, 59.9/40.1 wt. %) 

(20) CFC-504 (HFC-32/CFC-115, 48.2/51.8 wt. %) 

(21) CFC-505 (CFC-12/HCFC-31, 78/22 wt. %) 

(22) CFC-506 (HCFC-31/CFC-114, 55.1/44.9 wt. %) 

Ozone-depleting substances - Hydrochlorofluorocarbons ("HCFCs") 

(1) HCFC-21, also known as dichlorofluoromethane 

(2) HCFC-22, also known as chlorodifluoromethane 

(3) HCFC-31, also known as chlorofluoromethane 

(4) HCFC-121, also known as tetrachlorofluoroethane 

(5) HCFC-122, also known as trichlorodifluoroethane 

(6) HCFC-123, also known as dichlorotrifluoroethane 

(7) HCFC-124, also known as chlorotetrafluoroethane 

(8) HCFC-131, also known as trichlorofluoroethane 

(9) HCFC-132, also known as dichlorodifluoroethane 

(10) HCFC-133, also known as chlorotrifluoroethane 

(11) HCFC-141, also known as dichlorofluoroethane 

(12) HCFC-142, also known as chlorodifluoroethane 

(13) HCFC-221, also known as hexachlorofluoropropane 

(14) HCFC-222, also known as pentachlorodifluoropropane 
18

(15) HCFC-223, also known as tetrachlorotrifluoropropane 

Ozone-depleting substances, continued - Hydrochlorofluorocarbons ("HCFCs") 

(16) HCFC-224, also known as trichlorotetrafluoropropane 

(17) HCFC-225, also known as dichloropentafluoropropane

(18) HCFC-226, also known as chlorohexafluoropropane 

(19) HCFC-231, also known as pentachlorofluoropropane 

(20) HCFC-232, also known as tetrachlorodifluoropropane 

(21) HCFC-233, also known as trichlorotrifluoropropane 

(22) HCFC-234, also known as dichlorotetrafluoropropane 

(23) HCFC-235, also known as chloropentafluoropropane 

(24) HCFC-241, also known as tetrachlorofluoropropane 

(25) HCFC-242, also known as trichlorofdifluoropropane 

(26) HCFC-243, also known as dichlorotrifluoropropane 

(27) HCFC-244, also known as chlorotetrafluoropropane 

(28) HCFC-251, also known as trichlorofluoropropane 

(29) HCFC-252, also known as dichlorodifluoropropane 

(30) HCFC-253, also known as chlorotrifluoropropane 

(31) HCFC-261, also known as dichlorofluoropropane 

(32) HCFC-262, also known as chlorodifluoropropane 

(33) HCFC-271, also known as chlorofluoropropane 

Appendix II. Permitted HCR 188C Charge Based on Room Size and Occupancy Type

Occupancy Type Charge Size* System Category Example

Domestic 1.5 Kg (3.3 lb) sealed systems Homes, apartments

Public 5.0 Kg (11.0 lb) open air or machinery

rooms 

Public places, 

institutions, businesses 

Commercial 2.5 Kg (5.5 lb) per system Offices, manufacturing

Private 10 Kg (22.0 lb) open air or machinery

rooms 

Offices, manufacturing

Industrial 10 Kg (22.0 lb) occupied spaces Non-public areas 

Restricted Access 25 Kg (55.0 lb) open air or machinery

rooms 

Cold rooms, food

processing, plants 

* not to exceed, providing ignition sources are not normally present 

These limits were established by the European Union (EN 378 annex C of Part 1) to 

maintain the room air concentration below 25% of the lower explosive limit or 0.008 

Kg/m3 (0.0005 lb/ft3

). The British Flammable Refrigerant Standard (BS4434:1995) also 

allows up to a 1.5 Kg maximum charge, with systems using up to 0.25 Kg located 

anywhere. The maximum charge for systems below ground level is 1.0 Kg. 

Please Visit our Website for the Latest Updates: http://www.hcr188c.com/
February 22, 2012 

Mr. Richard Maruya 

A.S. Trust & Ilolding. Inc. 

44-129 Mikiola Drive 

Kaneoke. HI 96744 

Reference: R441 a Cylinder Size Inl<.mnation 

Dear Richard: 

In response for information relating [p the cylinder sizes mentioned in the L:.S. EPA's 

letter of February 22 sent to) ou by \1s. i\1argan:t Sheppard. please notl: the following: 

Currently. ComStar International Inc. has bccn tilling a DOT-39 cylinder \vith 20 Ibs of 

R441a; attached is the Worthington DOT-l9 specitication sheet. The DOT-39 cylinder 

meets the requirements of and is accepted worldwide 1<'>1' the R441 a refrigerant. This size 

cylinder and fill rate has been used liJr appliance. uutDl11otin: and air conditioning OEM 

test purposes. 

Since R441a is not currently hcing used commercially in the U.S .. \Ve have not settled on 

an appropriate size cylinder lor service technicians. Ilowen:r. a smaller container size 

and fill rate of 5 lbs would be acceptahk. 

The current industry standard reti'jgerant reco\\:r) cylinder normally holds up to 30 Ibs of 

a eFe, HCFC or 1/Fe refrigerant. 110\\ e'er. due to the physical properties Df R441 a this 

cylinder would most likely hold only 20 lh:-. RecO\w)' cylinder specification sheet is 

attached. 

~~e~~l;r-' .....• ',,-:' '-'..-/'1' I 1/ .,,J 

s~~~~ P'~l~;;'~/ '­

Chief E~ccutive Oftieer 

ComStar International Inc. 

20-45 128 Street 

College Point. 1\Y 11356 

Phone: (800) 328-0142 

Fax: (718)353-5998 

F:mail: ~.~~~L~J_~ ...)t_n_~>.l...l.r\hl.if .• 1 1)]' -J', i.. ;:

Website: W\vw.comstarproducts.cOt11 
REF. 

NRV 

W/ LUBRICATED 

O-RING. 

B000943S 

TIN REF. 

BURST DISC 

#563090 

12" REF. TOP 

#B120200 ,+ 030" 

¢.125 -:000" # 

FLOW --IfORIFICE 

DWG. NO·:B1201 OS/295495 

WORTHINGTON CYLINDERS 

200 OLD WILSON BRIDGE RD 

COLUMBUS, OH 43085 

SECTION AA 

12" REF. 

#8120300 

49.6# lBS 

IN 

260 PSI PSI 

325 PSI PSI 

STANDARD 

00To39 

REV BY 

D PW 

E PW 

F DAH 9-02 

G DAM 6-06 

H NPH 6-19-07 

J CAB 1-29-09 

COLLAR 

#B000402 

A 

l:::::­

PRE-ASSEMBLED 

KRYTOX 

17 5/8" 

14 3/8" 

.036" MDT. -11--- ¢12.0" 1.0. ----I

BODOM 

WORTHINGTON 

CYLINDERS 

A Worthln\jton Indu.trI.. Company 
REFRIGERANT RECOVERY 

LARGE RECOVEHY 

SPECIFICATIONS 

MODEL (LBS.) 

HEIGHT (IN.) 

HEIGHT (MM) 

WATER CAPACITY (LBS) 

WATER CAPACITY (KG) 

NOMINAL TARE WEIGHT (LBS.) 

NOMINAL TARE WEIGHT (KG) 

CYLINDER DIAMETER (IN.) 

CYLINDER DIAMETER (MM) 

CYLINDER VOLUME (CU. IN.) 

CYLINDER VOLUME (LITERS) 

COLLAR DIAMETER (IN.) 

COLLAR DIAMETER (MM) 

COLLAR HEIGHT (IN.) 

COLLAR HEIGHT (MM) 

FOOTRING DIAMETER (IN) 

FOOTRING DIAMETER (MM) 

STANDARD SPECIFICATION 

SERVICE PRESSURE (PSIG) 

SERVICE PRESSURE (BAR) 

TEST PRESSURE (PSIG) 

TEST PRESSURE (BAR) 

OPTIONAL SPECIFICATION 

SERVICE PRESSURE (PSI G) 

SERVICE PRESSURE (BAR) 

TEST PRESSURE (PSIG) 

TEST PRESSURE (BAR) 

To (on vert to refrigerant capad1y 

M;)j(II~lum ,1!lowdtile ~)ro'i~ c.yln>,,1{>: HI \iY0'9~"\ :. C S i< \', 

tl!~' rp-fil~"'l"dPt iho"I>tNl ~l' 7r'F!~)S"C

,.
'';'"

,p'; ,',' ".'.." -, .";.:.:-:'.....)r::-•....:•..... ,,.... 

177
 

4509
 

262
 

11,9
 

II
 

I.! 

9
 

231 1
 

/26 

11.9 

1
 

I.K 

198 1
 

[)O r 4h/\ L}On
 

400
 

)lb
 

800
 

WI.. 

Nil' 

NiA 

188
 

417',
 

41 I
 

1 1
 

126
 

i 2 ] 

312 ,1
 

1,324
 

1 I
 

'). I
 

130
 

l)() 1 4bA 1,100 

) ?b 

S()O 

N/i\ 

Nil\ 

1.23 

263
 

10
 

254
 

3.393
 

3 9
 

984
 

~JiA

N/A 

10
 

L)O'l ·<:lBV\} 400
 

400
 

)lb
 

800
 

5':,2 

NiA 

N//\ 

Nil\ 

N1A 

Nll\ 

481
 

1,231
 

239
 

108.4 

18',
 

]',6 

14.1 

ll3i1 

6,591 

108
 

114
 

289.6
 

64
 

163
 

14. 

3683
 

DOTABW·260
 

260
 

1'J.9
 

520
 

Ni/\ 

N/f, 

N/A
 

NiA
 

N/A 

57.3
 

1,455
 

1,000
 

450
 

334
 

151.5
 

30
 

762
 

27,461
 

450
 

16
 

4064
 

6.9
 

175
 

22
 

558.8
 

DOTABW·260
 

260
 

17.9
 

520
 

35.9
 

DOTABW-400
 

400
 

27.6 

800
 

55.2 

, 

WORTHINGTON 

CYLINDERS 

1.4 A Worthington Indu~tnt's CompOIny 

200 (lid \''Vds-on Br !dgc HOdd 

C.olumbu'l., OhiO L~3085

lO!i·fri.:c' 3bb.VVC,TAhiKS (866.928,2657) 

Phone: 614.438.3013 

FdX: 614.438.3083 

(' yi! nd C'l ,;{jJ:Wor"! h InqtnnIndustries,(om 

VVc)rth,1 flU tonC yl Ind0rS.(On 
Print Page 1 of 3 

Subject: RE: Response to Incompleteness Letter re: Use of R-441 a in New Vending Machines 

From: Brandon Button Intertek (brandon.button@intertek.com) 

To: richard@astrust.com; 

Cc: michael.lindeman@intertek.com; terrence.lansing@intertek.com; 

Date: Thursday, February 23, 2012 6:08 AM 

Hi Richard, 

I oversee testing of refrigerant recovery equipment per the AHRI 740 Program. Presently, 

there are no manufacturers in that Program building equipment specifically designed for 

R441A or other flammable refrigerants. That is not to say that existing equipment would not be 

suitable. From a recovery standpoint, propane (R290) and your refrigerant, R441A, would be 

processed by the equipment in exactly the same way as old generation CFC's, HCFC's, and 

HFC's. Recovery performance would be expected to mirror other gases of similar saturation 

pressures. The only difference that would be expected for equipment designed specifically for 

'nammable gases would be added requirements with respect to safety. Such equipment would 

be expected to have no arcing, sparking or high temperature parts, or to have such parts 

isolated and sealed. That equipment would be evaluated by some hazardous location 

standard such as ISA 12.12.01 in addition to the regular recovery machine standards such as 

AHRI 740 and UL 1963. In the automotive world, they have already started mandating 

flammable refrigerant safety requirements for recovery/recycyle/recharge equipment. An 

example would be SAE J2843, for equipment servicing R-1234yf (mildly flammable), which 

outlines performance requirements of such equipment, but has added text addressing the 

suitablility of components and proper ventilation of the equipment so as to avoid a 

fire/explosion. 

Best regards, 

Brandon Button 

Senior Associate Engineer 

Phone: 

Intertek 

1717 Arlingate Lane 

Columbus, OH 43228 

Fax: (614) 279-4642 

Email: brandon. button@intertekcorn 

wwwintertek.colll 

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 to the 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 purpose nor disclose its contents to any other person. 

http://us.mgl.mail.yahoo.com/neo/launch 2125/2012 
" . . , .'~ " ' "; 

MairrstreartY E"ngi,neering .Corporatipn~. ' 

Technician Certification. . \, .;...~Uf;'I"

~--:,.-.., ---,.----.'~~;~ MVAC Tec;:hnician Certification 

EPA Clean Air Section 609 

Program c"rtlficatlon Date Sept 19. 1996 

;~rtt;.~'~~'l' RICHARD H MARUYA 

932CF37761916CBEO 

has been certified as a Motor Vehicle Air CondlliOnlng Technician 

as ReqUIred by 4QCFR Part 82 40 

. {!edtflcate of C!ompldwn 

.1JM4,. /4.,., ..nw .1J,at 

R .y~:~~ .PA ApproY8cl ~30.18l13

SAL 

\82~ fl. 

.~,l'rMIdInI VIII,. TIllinlr4ll\V 

'----,_._._-,._-~--
Print Page 1 of 1 

Subject: RE: Response to Incompleteness Letter re: Use of R-441 a in New Vending Machines
 

From: Michael Lindeman Intertek (michael.lindeman@intertek.com)
 

To: richard@astrust.com:
 

Cc: terrence.lansing@intertek.com: brandon.button@intertek.com:
 

Date: Friday, February 24, 2012 5:35 AM
 

Richard, 

Per our conversation this morning, the UL standard for safety for vending machines is UL541. 

I looked at UL 541 and Supplement SA in UL541 covers the requirements for refrigerated 

venders employing a flammable refrigerant in the refrigeration system. Additionally, each 

unique make and model of vender would need to be evaluated to these requirements to 

ensure thier safety in the event of a refrigerant leak. If you have any additional questions, 

please feel free to contact me anytime. 

Thanks, 

Mike Lindeman 

Phone: 

Intertek 

1717 Arlingate Lane 

Columbus, Ohio 43228 

Fax: 614-279-4642 

Email: michaellindeman@lntertek corn 

wwwintertek.com 

Valued Quality. Delivered. 

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 to the 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 purpose nor disclose its contents to any other person. 

http://wwwlfltertek.col11 

http://us.mgl.mail.yahoo.com/neo/launch 2/25/2012 
ul-541.8 Page 1 of 1 

Re'frigerated Vending Machines 

UL 541 

1 Scope 

1.1 These requirements cover self-contained, refrigerated vending machines intended 

for connection to alternating-current circuits rated 600 volts or less in accordance with 

the National Electrical Code, ANSI/NFPA 70. Venders machines covered by these 

requirements: 

a) Incorporate refrigeration systems of the air-cooled or water-cooled type 

employing hermetic refrigerant motor-compressors; 

b) May be battery operated; 

c) May employ flammable refrigerant as defined in Requirements for 

Refrigerated Venders Employing a Flammable Refrigerant in the Refrigerating 

System, Supplement sa; 

d) May employ thermoelectric chilling systems. 

1.2 These requirements do not cover vending machines incorporating universal motors 

rated at more than 250 volts, nor vending machines which have a principal function 

other than storage and dispensing of refrigerated products; nor to vending stations, that 

is, freestanding stationary structures for outdoor use. 

Purchase UL Standards UL Standards InfoNet UL Standards Catalog 

http://ulstandardsinfonet.ul.com/scopes/0541.html 2/25/2012 
Print Page 1 of 3 

Subject: RE: Response to Incompleteness Letter re: Use of R-441 a in New Vending Machines 

From: Jafa. Emad {PAS} (emadjafa@pepsico.com) 

To: richard@astrust.com; 

Date: Friday, February 24. 2012 12:52 PM 

Richard, 

I have no idea, but what I suggest is to contact Chevron or Linde who provide and sell HC refrigerant 

and understand the details for that or any refrigerant suppliers. 

Thank you, 

Emad 

From: richardastrust.com [mailto: richard@astrust.com]
 

Sent: Thursday, February 23,201210:29 AM
 

To: Jafa, Emad {PAS}
 

SUbject: Fw: Response to Incompleteness Letter re: Use of R-441 a in New Vending Machines
 

Emad 

# 2 from the EPA is asking a question which I know
 

you have worked with. Would you be able to share any information with me.
 

Thank you
 

Richard
 

Richard Maruya
 

http://us.mgl.mail.yahoo.com/neo/launch 2/25/2012