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## ungton DD.C.Hoshizaki America's Ora! Statement on Change of listing Status of Certain Substitutes EPA Hearing, August 27, 2014

Page 12 Hoshizaki America thanks the EPA for their important work and the opportunity for industry engagement in the process. Hoshizaki America is a small business from Georgia that specializes in food equipment.
We manufacture commercial ice machines and commercial refrigerators/freezers. Hoshizaki America prides ourselves on quality, reliability, and being stewards to the environment. Hoshizaki America has been chosen as ENERGY STAR Partner of the Year two years running due to the ingenuity involved in qualifying many ENERGY STAR products. Hoshizaki America would like to join the EPA in a mission to achieve goals of the SNAP program without compromising occupational health, public safety, or market competitiveness. The choices that the EPA is giving the Commercial Refrigeration industry to phase-out R-134a and R-404A present many challenges and complications on all of those fronts and could cripple the industry if not given proper evaluation. One of the primary challenges in this proposai is limited substitutes. Carbon dioxide is in no way a viable replacement for R-134a or R-404A in standalone units. The pressures needed by the refrigeration system are 5 times that of our current refrigerant. To change the system to accept carbon dioxide would result in larger pipes and high risk of deathHoshizaki Amereca's Ora! Statement on Change of Listing Status of Certain Substitutes EPA Hearing, August 27, 2014

Page 13 for undertrained service personnel and innocent bystanders when servicing. No suppliers except one has even attempted to offer CO2 components for the industry. CO2 has been known for decades but has never been considered viable due to the lack of support, components, and failures in the industry. Isobutane and propane are also suggested replacements due to low gwp. These choices have restrictions and risks due to high flammability that make the design cycle complicated and probiematic for potential injuries to school children, hospital patients, and prisoners to name a few. Risks such as the potential for sparks in the current system would need to be carefuliy reviewed in relation to a flammable refrigerant. Highly flammable refrigerant poses risk of death when combined with service people who are thrust into working on equipment without the proper amount of training time. Manufactures production lines would need to be transformed to take into account a flammabie charge. On top of this, there is strong concern as to the energy efficiency of these alternative refrigerants that could pose a great risk to the industry. The DOE has imposed much tighter restrictions for energy use and each model must be designed to meet these requirements in order to be sold. Refrigerant change is also to be handled concurrently with the mandateHoshizaki America's Oral Statement on Change of Listing Status of Certain Substitutes EPA Hearing, August 27, 2014

P a g e 14 

### to change foam blowing agents by 2017. Added to the list of mandatory tasks, each unit must be evaluated by UL and NSF for safety and sanitation which again adds time to the design schedule. Hoshizaki America estimates the minimum time needed for each model is 30 weeks due to design, testing, and approval by overloaded third party approval agencies. Another concern is that vendors for critical components such as compressors have specified they do not have product ready for every model and might not have alternatives until 2-3 years from now. As demonstrated, the complexity of changing refrigerants while simultaneously designing to meet new mandatory DOE energy efficiency requirements makes it impossible to deliver all necessary changes in 18 months. This phase-out should be done methodically with proper alternatives given that not only help the environment, but also properly prioritize the safety of manufacturers, service personnei, and end users alike. If the alternatives are not as efficient and end up requiring more energy, the net result would be an increase in carbon footprint and even more damage to the environment. Hoshizaki America implores the EPA to allow for a 10 year phase-out for commercial refrigeration to not oniy allow for the refrigerant and component manufacturers to come up withHoshizaki America's Ora1 Statement on Change of Listing Status of Certain Substitutes EPA Hearing, August 27, 2024

f'ag_ 15 viable non-flammable choices, but also for manufacturers to save countless children's lives by not rushing to change over refrigerant without the time for each safety aspect to be considered. Unlike previous changeovers, the altematives given now are truly in the infant stage of entering the US market. Hoshizaki America agrees that we need to be good stewards of the environment, but as the original intent of SNAP, flammable refrigerants should not the first choice and proper time be given every safeguard so as to protect innocent iives from being lost.