~ 

% 

r. HOSHIZAKE AMERICA, INC, 

518 Hi hwa 74 South, Peachtree S Y Gty, Georgia 30259 s'hor.e ! I"' 48?-2331 

~ ra ~ State n o ~nl ~ oir 

HosN Jcs kG ~~°~ f~~~C~'~ ~ -; 

by 

Stephen Schaefer 

Before the 

Fnvironrnental Protection Agency 

0 ~n~ 

, Prot - ctJo - oof StIra'~JS~~`il~~~i

~ , C.! C 

Chang e of Ust~~~g S~~~ tus 1,or ;o ~ aL 

 ~ 

Subst ~ tuies Unds--~ rr Urijo S~ Tnj ~ 17 carjt Nev~vi 

Nltern~ a.Wes poDocy P rogram 

Docket Fl~ ljk~lo. E pi8-\,,—h' Q— oAR-20 1 a'co1 g --))-,- 

W~~~ ~ 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 death 
Hoshizaki 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 mandate 
Hoshizaki 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 with 
Hoshizaki 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.