call

richardastrust.com to: Margaret Sheppard, Monica Shimamura,

gary

04/13/2008 02:49 PM

Follow Up: Normal Priority. 

.

Monica and Margaret

4/11/08 1 pm EST by telephone for the introduction of Monica.

As per our discussion, and my answers to questions and concerns

 NO SMOKING WARNING NO SMOKING

FLAMMABLE REFRIGERANT HCR188C IN SYSTEM. USE PROPER CARE IN

CHARGING

RECOVERING AND STORAGE OF REFRIGERANT ONLY CERTIFIED TRAINED

TECHNICIAN TO HANDLE THIS PRODUCT. PLEASE REFER TO WEB SITE FOR

INSTRUCTIONS, AND SERVICING PROCEDURE. 

MANUFACTURES WEB SITE (appliance manufactures web address)

 

 NO SMOKING WARNING NO SMOKING

This is an example of the permanent label that the manufacturer would place on the appliance for

any service technician or recyclers. This will inform anyone about the care that should be taken

during removal and replacement of refrigerant.

As for the fault tree on untrained persons handling flammable refrigerant, I was told that Karen

has come across many established shops that are using untrained or non certified personnel.

The one question I will ask is: is the shop or shop owner licensed or certified?

If the shop is certified or license for example then the responsibility lies on the shop owner 

whose license or certificate is registered to the shop or service center to train their personnel on

safety matters and if any problems occur the shop or owner takes the responsibility for the person

working on the appliance.

Example auto repair shop.
In the State of Hawaii

1 A auto repair shop must be licensed by the Motor vehicle Repair Industry Board

 before it can get any liability insurance. see attached

2 The shop must be licensed.

 a. Each tech or mechanic must have his or her own license or certified by a governing 

body (ASE) 

 b Any trainee comes under the shop license or certificate. meaning he can perform the

 work even if unlicensed the repair facility is responsible for his work performed.

3 If the shop performs the vehicle inspection then all inspectors must be licensed.

 Including the shop.

 a Any unlicensed worker or trainee can perform the inspection as long as supervised

 by a licensed inspector and only the licensed inspector can sign the certificate

 of inspection.

If a person wishes to become a certified technician then he must go to school and take the normal

courses pass the certified written exams and have 24 months of OJT (on the job training) before

he or she can become a certified technician. During that time the student or trainee falls under the

shop or supervisors certification or license - meaning the shop is responsible for his training and

safety,use of products, equipment and the work that this individual does. He is watched over by a

trained certified person. If the trainee makes an error, the shop or supervisor is responsible.Lot's

of dealerships or companies hire people and begin training on the job. These people are not

certified but are in training. In my many years as a shop owner I had to do the same and got a

young person started in the profession. It was not easy to be responsible for the individual with

the training and watching over that person but, at the end, it was worth it. Many went on to

become shop owners themselves and teach the same things I thought them, SAFETY FIRST.

As far as appliance repair, any legitimate repair center must be EPA certified for recovery of

refrigerants - this is a law. When HCR188C is approved the EPA on the website will have the

information on how to handle and care for HCR188C provided by the guidelines.

The appliance manufacture will place a permanent warning label cautioning the use of

flammable refrigerant in the system and have on their web site the proper steps in handling,

recovering, and recharging of the refrigerant, both guidelines will emphasize only qualified

trained technician handle the product. Before any appliance can be sold retailers would require a

UL certification on the appliance and the refrigerant HCR188C. Meaning the appliance would

have to pass all UL safety standards,and HCR188c be a listed UL refrigerant, the warning label

would be part of the standard. If there is no UL certification sticker then Wal Mart, K Mart,

Sears, etc cannot carry or sell the appliance.

If, at that point with all of the warnings and a untrained person from a unlicensed shop works on

a appliance and disregards all safety rules, then this is beyond a human being's common sense

thinking. If any vocation schools, certifying or labor organizations should see the website that we

did a fault tree on untrained personnel, they would take a position that the EPA is encouraging
companies to hire untrained personnel because it's OK with the EPA since we did a fault tree this

can be misinterpreted, in short they would assume EPA condones untrained personnel to work

with HCR188C. As a license certified technician, I DO NOT condone unlicensed or untrained

personnel working or handling any product or equipment without proper training or supervision

as this individual is jeopardizing the safety and welfare of the people around him or her. I'm very

shocked after hearing your reasoning that your Enforcement Staff had witnessed violations like

this. It is my hope that your Enforcement Staff informed the shop or service center's owners of

the violation and had them rectify it immediately. This is why we have laws and training centers

and licensing boards : to train young technicians in the proper and SAFE ways of handling or

working with any refrigerant, flammable or not. SAFETY FIRST. Having a fault tree analysis

for untrained or uncertified personnel is like saying it's OK to have them handle the refrigerant

without proper supervision. It appears like an implied approval from the EPA allowing this to

happen.

For your information.

A refrigerator charged with HCR188C is very small.

28.3 grams was used in the refrigerator that was tested at Intertek.Full charge with 134

113 grams. See attached refrigerator test.

According to Chemir Lab the calculation for HCR188C is 1.71 grams = 1 cc at 60 degrees

will equal 1.11 tablespoons or 3.35 teaspoons of HCR188C in the system.

Very small charge amount, this would take a recovery machine a very short time to recover.

We also discussed about the experts checking on the Valeo test that was done on the

charge determination on the auto air conditioner. You felt that they might have questions and

Karen and Monica will get back to me with their concerns. the one thing I will explain to you that

auto manufacturers have a minimum and maximum charge. The minimum charge is when the

system is operating properly and cooling is at it's best. At that point the manufacturer will add a

little more and call it a maximum charge to compensate for slight refrigerant loss from

factory.They feel that this would prevent a customer from retuning to the dealership after so

many months to have has A C system recharged. The maximum system charge rate is the

calculation of 25% charge of HCR188C that I use.

Example 2007 Toyota Camry

See attached auto charge

.

max charge 0.55kg 1.21lbs

min. charge 0.45kg or.99lbs

On the Valeo test 4.5oz was used that is 25% of the maximum charge size of 1.21lbs

On the charge size of a auto system I use the maximum charge size and go 25% for

HCR188C.

I know this is confusing to a lot of people about HCR188C. A person cannot imagine what I've
done here. At Valeo Wind Tunnel when we started the test I had a lot of confused looks before

we started. Craig was concerned that the charge was too low and it would not function at the start

charge rate of 20% but, as we slowly moved on, the meters started to rise and got everyone

excited. HCR188C was working at 25% and as they say at Valeo and Intertek testing lab.What

you see is what you get...this is what was told to me before the test started at Valeo they also

emphasize that they will follow the approved test plan and not alter from it and I had to sign a

agreement not to alter the approved test plan from the EPA.

When the agreed test was over is when I did the other 2 test for I wanted to see is on normal 110

degrees and 20% humidity HCR188C can function. I did it because I had 4 hours

of wind tunnel time left and was not going to be credited for the 4 hours of non use. So I ran that

test for my own satisfaction.

Please note that even in the automobile a permanent warning plate will also be used.

This is my opinion: If the auto manufacture would build a quality evaporator core then we would

not have a problem with leaks in the passenger compartment. I have seen so many poor quality

manufactured evaporator cores which I had to replace in auto ac systems.

In my opinion if we can send a man to the moon without any problems, why can't we

manufacture a quality evaporator core.

Before the end of our call, Margaret, you agreed with Monica present, that after the Fault Tree is

submitted that my application for white good is complete and EPA will issue a letter stating my

completed application and my product is legal to be sold in the U.S.

If any questions please feel free to contact me.

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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