October 20, 2014

Ms. Rebecca von dem Hagen

U.S. Environmental Protection Agency 

Stratospheric Protection Division

Stratospheric Program Implementation Branch (6205J)

1200 Pennsylvania Ave, NW

Washington, DC 20460

RE: Honeywell International Inc. Comments on Proposed Rule: Protection of 

Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the 

Significant New Alternatives Policy Program (Docket no. EPA–HQ–OAR–2014– 0198)

Dear Ms. von dem Hagen,

Honeywell International Inc. (“Honeywell”) submits these comments in response to the 

Environmental Protection Agency’s proposed rule “Protection of Stratospheric Ozone: Change 

of Listing Status for Certain Substitutes Under the Significant New Alternatives Policy Program” 

(proposed rule). We appreciate the opportunity to provide input into EPA’s process to transition 

from high-global-warming-potential (GWP) products to more environmentally beneficial 

alternatives and applaud the Agency’s efforts in designing a proposed rule that paves the way for 

low-GWP substitutes across the fluorochemical industry. 

I. INTRODUCTION

Honeywell is a global leader in providing energy efficient technologies and innovations 

that can help the world solve its energy and environmental challenges. Our Fluorine Products 

business is a recognized leading innovator in the development of environmentally preferable 

fluorocarbons for use as refrigerants, foam blowing agents, solvents, propellants, and other uses. 

Since the 1990s, we have helped businesses replace ozone-depleting substances in these 

applications with alternatives that are more energy efficient and have less impact on the 

stratospheric ozone layer and global climate change. 

Honeywell supports EPA’s actions under the Clean Air Act and its commitment to 

transitioning the industry to alternatives with low-GWP and reduced-GWP substances. As a 

leader in fluorine technology, Honeywell has been at the forefront of the industry’s efforts to 

develop low-GWP products. In general, Honeywell supports EPA’s proposal to change the 

listing status from acceptable to unacceptable for many high-GWP substances. We believe the 

EPA’s proposal to list as unacceptable high-GWP substances will quickly yield carbon dioxide 

equivalent emissions (CO2e) reductions—setting an example for other countries around the 

world to follow. We believe that low-GWP and reduced-GWP solutions are available or will be 

available to replace these soon-to-be unacceptable substances. We also believe that there will be

sufficient time to comply with EPA’s proposed timelines. 

Across end-use sectors, Honeywell believes EPA should use the most up-to-date GWP 

values. EPA’s proposal references GWP values from the Intergovernmental Panel on Climate 
2

Change (IPCC) Fourth Assessment Report (AR4). Some of those GWP values differ from the 

GWP values listed in the more accurate IPCC Fifth Assessment Report (AR5). The use of outof-date GWP values in such an important rule can cause confusion, especially among those 

trying to evaluate and compare low-GWP technologies. Therefore, EPA should adopt the IPCC 

AR5 GWP values in the final rule.

According to EPA, the proposed rule could result in emissions reductions between 31 and

42 million metric tons of carbon dioxide equivalent (MtCO2e) annually by 2020.1 Honeywell 

estimates that listing HFC-134a as unacceptable for use in motor vehicle air conditioning could 

result in emissions reductions of approximately 10 million MtCO2e annually. Adopting our 

proposal in the condensing unit and supermarket system sector could result in emissions 

reductions of up to 3.6 million MtCO2e per year or 14 million MtCO2e from 2016-2020. In foam 

applications, Honeywell projects there are significant additional emission reductions that could 

be made. We estimate that EPA could reduce emissions by approximately 35 million MtCO2e 

per year in 2020 from the foam sector alone, including spray foam, which could result in 7 

million MtCO2e per year or about 20% more emissions reductions than the actions EPA 

proposes. Adoption of Honeywell technologies in the aerosols sector in the U.S. could reduce 

greenhouse gas emissions by more than 6 million MtCO2e per year in 2016.

We offer detailed comments on EPA’s proposal for specific applications and end-uses 

with respect to the availability of alternatives, including supply, the ease of transition, and the 

environmental benefits of substitutes. A list of alternatives adopted in each application and 

specific end-uses follows our comments in an Appendix. Our views are also summarized in the 

following tables.

 1 http://www.epa.gov/ozone/downloads/SAN_5750_SNAP_Status_Change_Rule-Fact_Sheet_070714.pdf
3

Table 1. SUMMARY OF HONEYWELL POSITION—REFRIGERATION

End-Use Product EPA 

Proposal Honeywell Position Supporting Information Supply of Alternatives

Motor Vehicle 

Air 

Conditioning 

(MVAC)

HFC134a

Unacceptable 

starting 

model year

2021

Unacceptable starting 

model year 2018

Alternatives:

HFO-1234yf

CO2

HFC-152a

x 28 auto brands selling approximately 60 models 

that use HFO-1234yf

x EU Directive prohibits HFC-134a by Jan 1, 2017

x Only minor equipment modifications needed

x Many OEMs are already implementing HFO1234yf and have plans to implement further

x SNAP-approved; GWP = .31

x HFO-1234yf commercial scale 

production today in China

x Mid-2015 commercial scale plant 

to be commissioned in Japan

x End of 2016 world scale plant in 

Geismar, Louisiana to be 

commissioned

New Retail 

Food 

Refrigeration 

and Vending 

Machines 

(stand-alone)

HFC 

blends R507A, 

R-404A

HFC134a

Unacceptable 

Jan 1, 2016

Unacceptable Jan 2017

GWP limit of 600 for HFC134a replacements; 

GWP limit of 1,500 for R404/R-507 replacements

Alternatives:

HFO-1234yf, HFO-1234ze, 

R-450A, R-513A, R-448A, 

R-449A

x SNAP applications for HFOs are under review; 

expect decision by early 2015, after which full 

industry evaluation will occur

x HFOs could provide optimal balance of safety, 

performance and GWP improvement

x Adoption of hydrocarbons and CO2 requires 

costly redesign; limited components are available 

for CO2 systems

x Propane, R-744a supply 

available, subject to component 

availability

x R-450A SNAP-approved, supply 

soon to be available

x Commercial quantities of HFO1234yf and HFO-1234ze 

available today, subject to SNAP 

approval

New Retail 

Food 

Refrigeration 

(Condensing 

Units and 

Supermarket 

Systems)

9 HFC 

Blends

Unacceptable 

Jan 1, 2016

Support and suggest GWP 

limit of 1,500 (Using AR-5 

values)

x Multiple HFO blend options being evaluated via 

numerous field trials, including R-448A and R449A. They offer excellent performance and 

lower energy consumption compared to R-404A.

x R-448A close to being qualified with numerous 

manufacturers

x Oak Ridge National Labs evaluation of R-448A 

showed excellent performance

x R-448A and R-449A currently 

being evaluated in extensive field 

trials

Retrofit Retail 

Food 

Refrigeration 

(Condensing 

Units and 

Supermarket 

Systems)

9 HFC 

Blends

Unacceptable 

Jan 1, 2016

Support and suggest GWP 

limit of 2,000 (Using AR-5 

values)

x Multiple options exist today including R-407A 

and R-407F which have been used successfully in 

thousand of retrofits

x Extensive field trials now occurring with R-448A

x R-407A and R-407F widely 

available and SNAP-approved

x R-448A currently being evaluated 

in extensive field trials
4

End-Use Product EPA 

Proposal Honeywell Position Supporting Information Supply of Alternatives

Chillers –

New and 

Replacement

HFC134a n/a

Unacceptable Jan 1, 2019

Alternatives:

HFO-1233zd(E), R-450A

HFO-1234ze(E), R-513A

HFO-1234yf

x HFOs have much lower GWPs

x HFOs offer comparable or better energy 

efficiency

x Time needed to allow for changes to UL 

standards, building codes and industry training to 

handle mildly flammable refrigerants

x There are multiple OEMs that have adopted HFO 

alternatives into their equipment

x Chillers are available today using 

both 1233zd and 1234ze

x HFO-1233zd(E) and HFO1234ze(E) are being produced in 

commercial quantities today

x HFO-1233zd(E) and HFO1234ze(E) are SNAP-approved 

for chillers

x R-450A SNAP-approved, supply 

available soon
5

Table 2. SUMMARY OF HONEYWELL POSITION—FOAM

End-Use Product EPA 

Proposal Honeywell Position Supporting Information Supply of Alternatives

Polyurethane 

Foams (all)

HFC-227ea 

and blends n/a

Unacceptable 60 days 

after publication of the 

final rule

x Highest GWP of all molecules used in PU foam

x GWP of HFC-227ea = 3220, which is 225% that of HFC134a

x Non-flammable solutions with 3000x lower GWP in use

x Rule would spur industry to develop low-GWP products 

x Limited use in industry; only recently approved 

x HFO-1233zd(E) – March 13,

2

May 20143

x HFO-1336mmz–2nd half 20162

x HFC-245fa, HFC-245fa/365 

blends2 (current proposal 

exempts spray)

High–pressure 

spray 

polyurethane 

foams

HFC-143a, 

HFC-245fa, 

HFC365mfc and 

blends

n/a Unacceptable Jan 1, 2018

x Significantly lower GWP alternatives SNAP-approved

x Quickest (6-18 months) and easiest application 

x Improved performance (energy efficiency) and lower 

cost (raw material yields)

x Additional savings of 7 million MtCO2e per year over 

EPA proposal

x Water

x HFO-1233zd(E) 

x HFO-1336mzz 

x Hydrocarbons 

XPS HFC-134a 

and blends

Unacceptable

Jan 1, 2017 Unacceptable Jan 1, 2016

x Numerous alternatives approved by SNAP and in use

x EU and Japan largely do not use HFC-134a 

x HFO-1234ze(E) offers both low-GWP and high energy 

efficiency (even better than 134a)

x Low cost of transition – 5-9% higher board costs; HFC134a prices increased due to preliminary anti-dumping 

rulings against Chinese imports

x CO2

x Butane 

x HFC-152a 

x HFO-1234ze(E) – 2008,

1

August 20142

Polyurethane 

(all 

applications)

HFC-134a 

and blends

Unacceptable

Jan 1, 2017

Unacceptable Jan 1, 

2016; low-pressure 2-

component spray foam 

unacceptable on Jan 1, 

2017

x Low-GWP one-component foam commercial since 2008

x Low-pressure low-GWP two-component pour foam 

systems commercially available 

x Low-pressure two-component spray foam – technical 

solutions being developed and optimized

x HFO-1234ze(E)

x HFO-1233zd(E) 

x Methyl formate

x HFO-1336mzz

Exceptions All HFCs Aerospace and 

military

Support

No other exceptions 

necessary

x Numerous solutions are SNAP-approved

x Technology and approvals similar or less than those 

applications that are already commercial 

x No new exceptions required

x HFO-1234ze(E)

x HFO-1233zd(E) 

x Methyl formate, methylal

x HFO-1336mzz

Products 

containing

All HCFCs, 

HFCs All Products

All products except 

refrigerator containers/ 

trailers 

x Allow transit of refrigerated containers/trailers

manufactured with unacceptable substitutes before status 

change date and sold after the date

x All HCFCs, HFCs

Open cell/ 

Flexible foam

Methylene 

chloride n/a List as unacceptable 60 days after final rule

x Unacceptable, consistent with NESHAP ruling of Aug. 

15, 2014

x CO2, acetone, water, HFO1233zd(E), others

 2 Small scale plant

3 Large scale, world-scale plant to supply global needs
6

Table 3. SUMMARY OF HONEYWELL POSITION—AEROSOLS

End-Use Product EPA Proposal Honeywell Position Supporting 

Information Supply of Alternatives

Consumer 

Aerosols

HFC134a

Unacceptable Jan. 1, 2016 for 18 different 

applications, including tire inflators and 

novelty aerosols

Support

x Multiple/wide-ranging 

low-GWP commercial 

products and/or shelfready prototypes 

currently available (see 

table of commercial 

products in Appendix 

III)

x Large, commercial-scale 

plants for low-GWP 

alternatives in operation to 

supply global demand 

(Hydrocarbons, HFC152a, HFO-1234ze(E), 

CO2)

Technical 

Aerosols

HFC134a

Unacceptable Jan. 1, 2016 

including

x Safety dusters for energized 

electrical equipment

x Refrigerant flush

______________________________

Acceptable in the Following:

1. Cleaning products for removal of 

grease, flux, soils from electrical 

equipment or electronics

2. Lubricants for electrical equipment or 

electronics

3. Sprays for aircraft maintenance

4. Duster sprays for photographic 

negatives, semiconductor, 

microscopes

5. Lubricants and cleaners for 

spinnerettes for synthetic fabrics

6. Mold release

7. Pesticides for use near electrical wires

8. Pesticides for use in an aircraft

9. Pesticides in total release insecticide 

foggers

10.Document preservation sprays

Support

__________________________

1. Unacceptable by Jan. 1, 2016

2. Support

3. Unacceptable by Jan. 1, 2016

4. Unacceptable by Jan. 1, 2016

5. Support

6. Unacceptable by Jan. 1, 2016

7. Unacceptable by Jan. 1, 2017

8. Unacceptable by Jan. 1, 20174

9. Unacceptable by Jan. 1, 2017

10. Support

x Multiple/wide-ranging 

low-GWP commercial 

products and/or shelfready prototypes 

currently available (see 

table of commercial 

products)

x It is industry practice to 

remove flushing agents 

from lines, etc. by 

blowing them dry with 

nitrogen or compressed 

air after flushing; no 

risks from residual 

flushing agents are posed 

by welding lines after 

flushing

x Large, commercial-scale 

plants for low-GWP 

alternatives in operation to 

supply global demand 

(Hydrocarbons, HFC152a, HFO-1234ze(E), 

CO2)

 4 SPRAY Magazine, May 2012
7

End-Use Product EPA Proposal Honeywell Position Supporting 

Information Supply of Alternatives

Medical 

Aerosols

HFC134a

Unacceptable Jan. 1, 2016 (including 

freeze spray for tissue)

______________________________

Acceptable in the following:

1. MDI

2. Wound care sprays

3. Topical coolant sprays for pain 

4. Liquid bandages

5. Bandage adhesive remover

6. Anti-fungal sprays

Support

__________________________

Acceptable in the following:

1. Support

2. Support

3. Unacceptable Jan. 1, 2018

4. Support

5. Support

6. Support

x For freeze sprays for 

pain relief, long-term 

exemption is not 

required since customers 

are already 

evaluating/prototyping 

low-GWP alternatives

x Large, commercial-scale 

plants for low-GWP 

alternatives in operation to 

supply global demand 

(Hydrocarbons, HFC152a, HFO-1234ze(E), 

CO2)

All Aerosols 

Applications HFC-125 Unacceptable Jan. 1, 2016 Support

x Multiple/wide-ranging 

low-GWP commercial 

products and/or shelfready prototypes 

currently available (see 

table of commercial 

products)

x Large, commercial-scale 

plants for low-GWP 

alternatives in operation to 

supply global demand 

(Hydrocarbons, HFC152a, HFO-1234ze(E), 

CO2)

All Aerosols 

Applications HFC-227 Unacceptable Jan. 1, 2016, except

in metered dose inhalers Support

x Multiple/wide-ranging 

low-GWP commercial 

products and/or shelfready prototypes 

currently available (see 

table of commercial 

products)

x Large, commercial-scale 

plants for low-GWP 

alternatives in operation to 

supply global demand 

(Hydrocarbons, HFC152a, HFO-1234ze(E), 

CO2)
8

Table 4. SUMMARY OF OTHER APPLICATIONS THAT SHOULD BE INCLUDED

End-Use Product EPA 

Status Honeywell Position Supporting Information Supply of Alternatives

Chillers –

New and 

Replacement

HFC-134a Acceptable

Unacceptable Jan 1, 2019

Alternatives:

HFO-1233zd(E), R-450A

HFO-1234ze(E), R-513A

HFO-1234yf

x HFOs have much lower GWPs

x HFOs offer comparable or better energy efficiency

x Time needed to allow for changes to UL standards, 

building codes and industry training to handle 

mildly flammable refrigerants

x There are multiple OEMs that have adopted HFO 

alternatives into their equipment

x HFO-1233zd(E) and HFO1234ze(E) are available today

x HFO-1233zd(E) and HFO1234ze(E) are being produced in 

commercial quantities today

x HFO-1233zd(E) and HFO1234ze(E) are SNAP-approved for 

chillers

x R-450A SNAP-approved, supply 

available soon

Polyurethane 

Foams (all)

HFC-227ea 

and blends

None; not 

yet 

evaluated 

under 

SNAP

Unacceptable 60 days after 

publication of the final rule

x Highest GWP of all molecules used in PU foam

x GWP of HFC-227ea = 3,220, which is 225% that 

of HFC-134a 

x Non-flammable solutions with 3000x lower GWP 

available 

x Rule would spur industry to develop low-GWP 

products 

x Limited use in industry; only recently approved 

x HFO-1233zd(E) – March 135, May 

20146

x HFO-1336mmz – 2nd half, 20162

x HFC-245fa, HFC-245fa/365 blends2

(current proposal exempts spray)

High–

pressure 

spray 

polyurethane 

foams

HFC- 143a, 

HFC-245fa, 

HFC-365mfc 

and blends

Acceptable Unacceptable Jan 1, 2018

x Significantly lower GWP alternatives SNAPapproved

x Quickest (6-18 months) and easiest application 

x Improved performance (energy efficiency) and 

lower cost (raw material yields)

x Additional savings of 7 million MtCO2e per year

over EPA proposal

x Water

x HFO-1233zd(E) 

x HFO-1336mzz 

x Hydrocarbons 

Open cell/ 

Flexible foam

Methylene 

chloride Acceptable List as unacceptable 60 days after final rule

x Unacceptable, consistent with NESHAP ruling of 

August 15, 2014

x CO2, acetone, water, HFO1233zd(E), others

 5 Small scale plant

6 Large scale, world-scale plant to supply global needs
9

II. DETAILED COMMENTS BY APPLICATION & END-USE 

We submit the following detailed comments on EPA’s proposal by application and enduse.

A. MOTOR VEHICLE AIR CONDITIONING

EPA proposes to allow continued use of HFC-134a in motor vehicle air conditioning 

systems through model year 2020 vehicles. Listing HFC-134a as unacceptable in this 

application could result in emissions reductions of approximately 10 million MtCO2e annually. 

Honeywell believes the transition to low-GWP alternatives can happen by model year 2018 

vehicles based on the following. 

x Major suppliers of mobile air conditioning systems have already developed systems to 

accommodate alternatives to HFC-134a, including HFO-1234yf, a widely available 

substitute. This is demonstrated by the fact that 28 different automobile brands are 

selling approximately 60 different models designed to use HFO-1234yf. U.S.-based 

companies, including Ford, GM, Chrysler, and Tesla are manufacturing more than a 

dozen models using HFO-1234yf.

7

x In the EU, the Motor Vehicle Air Conditioning Directive prohibits use of HFC-134a in 

new vehicles by January 1, 2017. In response, global auto manufacturers have already 

made plans to transition to non-HFC-134a alternatives. 

x While some auto manufacturers for U.S. car production have stated that their designs for 

new vehicles are locked-in until model years 2016 or 2017, they have time today to make 

plans to transition vehicles to adapt to low-GWP refrigerants by model year 2018. Given 

manufacturers’ experience in the EU and U.S. there is already an understanding and 

capability to transition vehicles for U.S. car production.

x Ford, General Motors, Chrysler, and Tesla are already selling 17 models using HFO1234yf systems. 

x Adequate refrigeration solutions exist. The EPA has already SNAP-approved HFO1234yf, HFC-152a, and CO2 (R-744) for motor vehicle air conditioning systems and, as 

noted above, low-GWP motor vehicle systems are currently in widespread use in the U.S. 

and Europe.

x There is one commercial scale HFO-1234yf production plant operating today in China, a 

second one is expected to be commissioned in the first half of 2015 in Japan via a 

strategic supply relationship between Honeywell and Asahi Glass Company Ltd, and a 

third world-scale plant will be commissioned by Honeywell by the end of 2016 in 

Geismar, Louisiana.

As part of its justification for a long timeline for transition out of HFC-134a in the motor 

 7 This data is from a list compiled by the Institute for Governance and Sustainable Development (IGSD) 

(Oct. 12, 2014) (Sources include Deutsche Umwelthilfe, Mobile Air Conditioning Society (9/19/2014), 

EU Stakeholder Meeting (11/2013) and IGSD communication with MVAC experts.
10

vehicle air conditioning application, the proposed rule states that auto manufacturers may need 

more time to ensure systems using HFC-152a and HFO-1234yf are safe, since both substances 

are classified as flammable. While it is true that systems using HFC-152a may require a 

secondary loop through the passenger cabin to adequately address the flammability risks of 

HFC-152a, EPA’s rationale is not justified with respect to HFO-1234yf. The American Society 

of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE) has assigned HFO-1234yf 

a flammability rating of A2L, mildly flammable. HFO-1234yf systems safely utilize the same 

architecture as HFC-134a systems, as documented by the Society of Automotive Engineers 

(SAE) study CRP1234, which adequately protects against any flammability risks. Using HFO1234yf does not require a secondary loop design.

The proposed rule also mistakenly states that HFO-1234yf has “measurably lower energy 

efficiency” than HFC-134a. To the contrary, auto manufacturers that have tested and used HFO1234yf in their vehicles have found that systems designed for the properties of HFO-1234yf are 

at least as efficient as those using HFC-134a, and in some cases systems using HFO-1234yf were 

found to be more efficient.

We understand some concerns have been raised regarding vehicles that are produced with 

HFO-1234yf in the U.S. and then subsequently exported to other countries that do not have 

similar low-GWP requirements and therefore appear not to be prepared to service cars with lowGWP refrigerants. We believe that this is not a valid concern since this issue is not unique to 

refrigerants; it is the same for other vehicles parts. If a vehicle is sold in another country, the 

vehicle servicing infrastructure must be available to perform all types of services and repairs and 

therefore all of the unique parts including body panels, engine parts, transmissions, refrigerants,

etc. must be available. It is the responsibility of the vehicle manufacturer to ensure that their 

authorized dealers in those countries are able to provide all the necessary service to these 

exported cars, especially since they will be required to provide warranty service for a period 

generally ranging from three to seven years after first sale. In addition, Honeywell has already 

developed an extensive network of distributors that are capable of supplying HFO-1234yf 

globally.

Lastly, the proposed rule appears to be using preliminary GWP values for HFO-1234yf 

derived from research papers, which conclude that HFO-1234yf has a 100-year GWP of 4. We 

submit that the IPCC’s AR5, the latest extensively peer-reviewed evaluation, should be used 

instead. That report concludes that HFO-1234yf has a 100-year GWP of just 0.31. 

B. REFRIGERATION

1. New Retail Food Refrigeration and Vending Machines (stand-alone equipment) 

EPA proposes to list as unacceptable as of January 1, 2016 HFC-134a and HFC blends,

including R-507A and R-404A, among other substances, for use in new retail food refrigeration 

and vending machines. Honeywell believes this proposal is too restrictive because it would limit 

the industry’s options to only a few SNAP-approved alternatives that are either highly flammable 

such as R-290 or R-600a, or less energy efficient, like R-744, which would negate the lowerGWP benefits of R-744.
11

For larger stand-alone units, it is not possible to adopt hydrocarbons (R-290 or R-600a) 

without completely redesigning the system to accommodate two separate refrigeration circuits 

that would meet EPA’s charge size limits. This could nearly double the cost of the refrigeration 

system to accommodate the use of hydrocarbons.

Adopting R-744 would require a complete redesign of prevailing stand-alone and 

vending machine systems. Currently there is very limited availability of the mechanical 

components necessary to implement such R-744 system redesigns. 

Overall analysis done by Honeywell and many of its equipment partners indicate that 

transitioning to R-744 requires a higher equipment cost than transitioning to other alternatives 

such as an HFO or HFO blends. HFOs and HFO blends could realistically offer an excellent 

balance of safety, performance, and cost.8

Furthermore, Honeywell recommends setting GWP limits, based on the IPCC AR5

values, for systems that have been designed to be used with medium pressure refrigerants, such 

as HFC-134a, and systems that have been designed to be used with higher pressure refrigerants 

such as HFC-404A.

x For systems currently designed for HFC-134a, we recommend limiting acceptable 

substitutes to those with a GWP of 600 or less. Such substitutes could include HFO1234yf (GWP <1), HFO-1234ze(E) (GWP <1), R-744, R-290, R-600a, and HFO blend

R-450A (GWP = 546). ASHRAE recently designated R-450A as non-flammable.

Commercial supply quantities exist today for HFO-1234yf and HFO-1234ze(E).

x For systems currently designed for R-404A, we recommend limiting acceptable 

substitutes with GWP of 1500 or less. Such substitutes could include R-744, R-290, R600a, and HFO blends R-448A (GWP = 1270), R-450A (GWP = 546), and R-513A 

(GWP = 572) (provisional ASHRAE designation). Both R-448A and R-450A are 

ASHRAE designated non-flammable.

In light of the above comments, Honeywell believes the effective date for listing HFC134a and higher-GWP HFCs and HFC blends as unacceptable should be January 1, 2017. This 

will allow proper time to accommodate significant equipment redesigns to incorporate the use of 

hydrocarbons and CO2. In addition, HFOs and HFO blends could be adopted and ultimately 

provide the industry with low-GWP solutions in these applications that are energy efficient, lowcost, and safe. 

EPA proposes to continue to allow existing equipment to be serviced with R-404A and 

R-507A indefinitely. Honeywell urges EPA to consider disallowing the use of these high-GWP

substances for servicing no later than January 1, 2022, to further encourage transition to lowerGWP alternatives. EPA should continue to allow recycled and reclaimed R-404A and R-507A 

to be used for servicing to encourage reclamation and make the transition to lower-GWP

substances less disruptive. 

 8 EPA recently signed a final rule listing R-450A, a blend of HFC-134a and HFO-1234ze(E), as 

acceptable for use in retrofit and new retail food refrigeration and retrofit vending machines. (See EPA 

SNAP Notice 29, at http://www.epa.gov/ozone/downloads/Notice29.pdf.)
12

2. Retrofit Retail Food Refrigeration and Vending Machines (stand-alone equipment) 

Honeywell supports EPA’s proposal in this application. 

3. Condensing Units and Supermarket Systems (new and retrofit)

Honeywell generally supports EPA’s proposal to find unacceptable by January 1, 2016 

nine HFC blends, including R-404A and R-507A, for new and retrofit condensing unit and 

supermarket system applications. Today there are multiple reduced-GWP refrigerants available 

that are near drop-in solutions for this application and provide improved energy efficiency and 

ease of adoption. This is clear and there numerous examples in place today.9 

To aid EPA in its goal to drive down the GWP of refrigerants as low as possible, 

Honeywell recommends bifurcating new and retrofit unacceptable recommendations in the 

following manner:

x Retrofit: List all HFC Blends with GWP greater than 2000, based on the IPCC AR5 

values, as unacceptable by January 1, 2016. We believe the proposal is not aggressive 

enough because it would allow the use of substances with a GWP above 2000 when there 

are various acceptable substitutes with GWPs less than 2000, such as R-407C (GWP = 

1624), R-407F (GWP = 1674), and R-448A (GWP = 1273) in wide use today or nearing 

commercialization. These substitutes are also more energy efficient than higher-GWP

refrigerants currently used in these applications and there is ample supply refrigerant to 

serve this application. In addition to finding certain refrigerants unacceptable for 

retrofitting condensing units and supermarket systems, we suggest that EPA consider 

finding unacceptable the use of high-GWP HFC blends for servicing of existing R-404A 

and R-507 systems at some date in the future. 

x New Units and Supermarket Systems: List all HFC Blends with GWP greater than 1500, 

based on the IPCC AR5 values, as unacceptable by January 1, 2016. There are multiple 

options that have been developed with lower-GWP refrigerant solutions which are in

early commercialization (e.g., R-448A and R-449A) that are highly efficient and near 

drop-in replacements to existing widely used HFC blends like R-404A, R-407A, R-407F, 

and R-507. EPA can draw a bright line by distinguishing new units and systems from 

retrofits and begin the process to transition all supermarkets to low-GWP substitutes. 

Adopting this proposal could result in emissions reductions of up to 3.6 million MtCO2e per year 

or 14 million MtCO2e from 2016-2020.

EPA asks whether listing some currently acceptable substances as unacceptable creates 

an unintended incentive to continue to use old leaky equipment, especially HCFC-22-based 

systems. Honeywell does not believe such an incentive will be created for the following reasons: 

(1) the availability of HCFC-22 will be limited under EPA’s allocation regulations, (2) the price 

will likely be sufficiently higher because of the progressively limited supply, and (3) alternatives 

to HCFC-22 are available. Thus, EPA should finalize its proposal to list as unacceptable highGWP substances in the applications described above.

 9 See Appendix I.D.
13

C. CHILLERS

EPA’s proposal does not include any change in status for refrigerants used in chillers, 

such as HFC-134a. Honeywell encourages EPA to list HFC-134a as unacceptable in new 

chillers effective on January 1, 2019 because alternatives such as HFO-1233zd(E), and HFO1234ze(E) are both commercially available, SNAP-approved, and have comparable or higher

efficiencies to HFC-134a and much lower GWPs. It should be noted that several chiller 

manufacturers have recently introduced chillers with low-GWP refrigerants. Specifically, this 

summer Trane introduced a line of high-efficiency chillers based on HFO-1233zd(E) that are

available in capacities ranging from 740 to 3,500 tons. In addition, several other manufacturers 

currently offer high-efficiency chillers based on HFO-1234ze(E) in sizes ranging from tens of 

tons to hundreds of tons. Please see Appendix I.C. for a select list of commercially-launched 

chillers that utilize HFO-1234ze(E). It is worth noting that these chillers using HFO-1234ze(E)

have largely been launched in the EU where the formal promulgation of the F-gas regulation has 

motivated manufactures to develop and commercialize these units. We believe that finding 

HFC-134a unacceptable for this use would similarly accelerate commercial development in the 

U.S. 

***

As shown in the table below listing select customer announcements, the motor vehicle air 

conditioning, commercial refrigeration, and chiller industries are already transitioning to lowGWP substances. 

Table 5. Announcements from Customers Adopting Low-GWP Alternatives in Air Conditioning 

and Refrigeration Applications

MOTOR VEHICLE AIR CONDITIONING 

Company Date Headline

General 

Motors

July 23, 2010 GM First to Market Greenhouse Gas-Friendly Air 

Conditioning Refrigerant in U.S.

Chrysler Oct. 30, 2013 Chrysler Rolls Out R-1234yf

COMMERCIAL REFRIGERATION

Company Date Headline

K-VA-T Food 

Stores, Inc.

(Food City)

July 2014 Genetron Performax® LT (R-407F) “Makes Sense” 

for New Supermarkets

U.S. 

Department of 

Energy

April 2014 Working Fluids: Low Global Warming Potential

Refrigerants

Les Salaisons 

du Mâconnais Jan. 2014 Performax® LT / R-404A : a life-size confirmation of achievable energy savings

Emerson 

Climate 

Technologies

Sept. 2013 Refrigerants Update
14

GEA Bock 

Compressors Sept. 2012

The Low GWP Refrigerant R407F – For highly 

efficient and environmental friendly refrigeration 

systems with Bock compressors

Emerson 

Climate 

Technologies

Sept. 2012 Copeland Discus Compressor Line Approval with R407F

ASDA 

(Walmart

Subsidiary)

March 2012 Innovative Refrigerant Helps Lower Carbon 

Footprint and Energy Costs

Super U June 2011 Super U adopts Performax LT for its refrigeration 

system

Bitzer June 2011 Interest in HFC-407F Grows

Sprouts 

Farmers 

Market

April 2011 Supermarkets Make Strides

CHILLERS

Company Date Headline

Trane July 25, 2014 Trane First with 1233zd Centrifugal Chiller

Cofely Aug. 1, 2014 Cofely Refrigeration Announces Quantum G

Star 

Refrigeration

Dec. 12, 2013 Star Launches Energy Efficient HFO Chiller

Airedale Dec. 2, 2013 Airedale First To Market With Production Range of 

Low GWP Chillers

Danfoss Sept 25, 2013 Danfoss Turbocor releases TG310 compressor 

running with HFO-1234ze(E)

Klima-Therm Jan. 1, 2012 World-First HFO Chillers Installed in South London

D. FOAM

Honeywell supports EPA’s proposal for foam applications, but believes the transition to 

low-GWP substitutes should be expanded to include new applications like spray foam. We also 

believe that in some cases the transition can occur more quickly than EPA proposes.

We agree with EPA that history shows that the foam industry can convert quickly to 

alternatives with very limited equipment changes and capital expenditures, especially when near 

drop-in solutions are available, as they are now. EPA states that during the last transition “the 

foam industry was able to convert from HCFC-142b and HCFC-22 to other acceptable 

substitutes” in 16 months. This is not the first the time industry is transitioning to new foam 

blowing agents. In fact, several low-GWP foam solutions are already available today and 

customers have already transitioned, as noted below. Many of the available solutions are close 

to drop-in and while reformulation work and testing are typically involved in any new foam 

(such is true of every previous transition or even improvements with existing generations), the 

technology is sufficiently advanced that the time for reformulation and testing is shorter than the 

timelines suggested by EPA for transition. Recently, several customers across many applications 
15

have already transitioned from high-GWP to low-GWP foam blowing agents. Below is a select 

list of customers across various foam applications that are already selling products commercially, 

and for whom reformulation and testing time have not delayed commercialization: 

x Extruded polystyrene (XPS)—Jackon, Abriso, Knauf, Fibran;

x Appliances—Whirlpool, Midea, Haier, Festivo; 

x Spray foam—Lapolla, West Development, Elastochem, Toyo, Asahi, BIP; 

x Panel—Kingspan, All Weather Panel; 

x Commercial refrigeration equipment—Porkka, Okamura;

x Refrigerated trailers—CIMC China; and 

x One-component foam—Dow, Fomo, Soudal. 

Across most applications, many additional customers globally are in various stages of 

commercial development. Some customers have only recently started trials and our expectation 

is that these customers will be able to reach commercial solutions within the timelines proposed 

by EPA. 

Customers have several available SNAP-approved options from Honeywell and

manufacturers. According to EPA even more options will become available in the near future. 

This year Honeywell started operating large-scale manufacturing plants for HFO-1233zd(E) and 

HFO-1234ze(E), which are replacements for HFC-134a, HFC-245fa, and HFC-365mfc. DuPont 

announced that full-scale production of HFO-1336mzz (a substitute for HFC-245fa, HFC365mfc, and blends thereof) would be available in the second half of 2016.10 As noted above, 

several customers in the U.S. and abroad have adopted substitutes for HFC-245fa, HFC-134a, 

HFC-365mfc and blends thereof. Strong regulatory action will continue to drive conversions 

away from high-GWP HFCs to products with much lower climate impact. 

EPA estimates the emissions reductions from the proposed unacceptability listings in all

sectors could be between 31 and 42 million MtCO2e in 2020.

11 By taking the actions noted here

in the foam sector we estimate that EPA could reduce CO2e emissions by approximately 35 

million Mt CO2e per year in 2020, including spray foam, which alone could result in 7 million 

MtCO2e per year or about 20% more emissions reductions than the actions EPA proposes. 

Further, in many instances customers are seeing benefits of better performance, energy 

efficiency, non-flammability, and better product yields (less foam for the same performance), 

making solutions not just lower in climate change impact but also better in other attributes. For 

example, refrigerators made with HFO-1233zd(E) are 8-10% more energy efficient than those 

manufactured from flammable hydrocarbons and 2-4% more efficient than those that use HFC245fa, so appliance manufacturers can either reduce foam thickness or improve energy efficiency 

at the same foam thickness. Similar energy efficiency benefits are being seen across spray foam 

and other foam applications as well, offering customers better performance and/or lower cost 

alternatives across a range of applications. 

 10 http://www.gupta-verlag.com/general/news/industry/14939/dupont-fluorochemicals-announces-worlds-first-full-scale-production-of-hfo-1336mzz/pdf. 11 http://www.epa.gov/ozone/downloads/SAN_5750_SNAP_Status_Change_RuleFact_Sheet_070714.pdf
16

Many low-GWP substitute solutions, such as HFO-1233zd(E) for polyurethane (PU) 

foam or HFO-1234ze(E) for extruded polystyrene (XPS), are similar or better on a life-cycle 

analysis basis. They are of similar or better energy efficiency than the HFCs they are replacing 

and significantly lower in GWP. Hence their life-cycle impact is order(s) of magnitude better 

than the HFCs they are replacing. For example, a thorough life cycle analysis of HFC-245fa and 

HFO-1233(zd)(E) in closed-cell spray foam12 showed that the impact of using HFO-1233zd(E)

improved the GWP payback by up to 90% compared to HFC-245fa. Therefore, in addition to 

offering direct GWP savings, several substitutes for HFCs are expected to dramatically reduce

the CO2e emissions on a life-cycle basis as well. 

Honeywell believes that the proposed rule can be expanded to cover more applications 

since solutions are already in commercial use. In some cases, EPA could list substances as 

unacceptable earlier than proposed. 

1. HFC-227ea and Blends Containing HFC-227ea 

EPA should list HFC-227ea and blends containing the same as unacceptable for use in all 

foam applications quickly, beginning sixty days after publication of the final rule. Since EPA 

proposes to list HFC-134a and other high-GWP molecules as unacceptable, we recommend that 

EPA list HFC-227ea (the molecule and its blends) as unacceptable for the reasons detailed 

below. Honeywell is supportive of EPA’s approach to target the specific molecule, since in the 

foam industry, it is possible to blend the molecule with other substances, e.g., water (which is 

also a blowing agent), and reduce the GWP. 

Listing HFC-227ea as unacceptable immediately could prevent use of a material that has 

a GWP 225% greater than HFC-134a, while having minimal impact to foam customers.

x HFC-227ea has an extremely high GWP, 225% of HFC-134a: HFC-227ea has a 

GWP of 3,220-3,350, which is the highest GWP of all molecules used in PU foam. In 

other words, it is 225% the GWP of HFC-134a. Since EPA proposes to list HFC-134a 

as unacceptable across all foam applications due to its high GWP, it makes good 

sense to also list HFC-227ea and its blends as unacceptable. 

x HFC-227ea is not an effective blowing agent: HFC- 227ea, by itself, is not listed 

under SNAP as acceptable or unacceptable as an alternative blowing agent in foam 

applications. It is listed as acceptable when blended with HFC-365mfc. As the 

industry knows well, HFC-227ea is not an effective blowing agent when used on its 

own. Its primary purpose is to reduce the flammability of other HFCs, primarily 

HFC-365mfc, by blending the two substances together. 

x Several other non-HFC-227ea, non-flammable solutions are available to customers: 

HFO-1223zd(E) has a GWP 3000 times lower than HFC-227ea, is non-flammable, 

and has been approved by SNAP for over 2 years. HFO-1233zd(E) has been 

commercial in spray foam for 18 months. Moreover, EPA has already approved 

HFC-365/245fa blends, which are non-flammable and also much lower in GWP than 

 12 Bogdan and Pascual, Environmental assessment of next generation blowing agent technology using 

Solstice LBA in ccSPF, Polyurethane Magazine, 5 (2012).
17

using 227ea, allowing customers to choose from several lower-GWP options even 

without HFC-227ea. Honeywell’s HFO-1233zd(E) large-scale plant started up in 

May 2014 in Baton Rouge, Louisiana. Spray foam customers will have yet another 

low-GWP option as DuPont has announced they will begin commercial production of

HFO-1336mmz in the second half of 2016. 

x Small to no current impact on foam industry of listing HFC-227ea as unacceptable: 

Since EPA listed HFC-227ea/365mfc blends as acceptable in May 2013, it has gained 

very limited use in the U.S. Listing HFC-227ea and blends containing HFC-227ea as 

unacceptable would thus have little negative impact to foam customers. 

x Enable industry resources and time to be spent on much better, lower-GWP solutions: 

Listing HFC-227ea as unacceptable quickly will send a clear signal to customers not 

to formulate with a product that is as much as 3000+ times more harmful than other 

solutions like HFO-1233zd(E) that are commercially available and being adopted by 

companies like Lapolla, West Development Group, and Elastochem in the past 18 

months. Customers could then spend their technical resources and time on 

formulating with low-GWP alternatives rather than formulating with the much more 

environmentally harmful HFC-227ea. Listing HFC-227ea as unacceptable will also 

reduce the demand on testing labs to test products made with HFC-227ea, which will 

have the side benefit of helping to decrease the testing time for much lower-GWP

solutions. 

Given the ultra-high GWP of HFC-227ea (225% higher than HFC-134), the availability 

of several substitutes, and limited impact on customers, EPA should list HFC-227ea and blends 

containing HFC-227ea as unacceptable in all foam applications, including spray foam, sixty days 

after the issuance of the final rule. 

2. HFC-134a in Foam Applications

EPA proposes to list HFC-134a as unacceptable for use in foam applications as of 

January 1, 2017. Honeywell is ready to support the transition starting January 1, 2016.

Honeywell believes solutions are available across a wide range of applications and that the

relative cost of transitioning to substitutes is not significant, especially given the recently rising 

price of HFC-134a imported from China due, in part, to preliminary anti-dumping rulings against 

Chinese imports by the Department of Commerce and the International Trade Commission. A 

December 2013 preliminary determination by the U.S. International Trade Commission13 is 

proposing significant duties on imports of HFC-134a from China, and prices of HFC-134a have 

been increasing to pre-dumping levels. This means that solutions for HFC-134a are not only 

available but the relative cost of transition away from HFC-134a to lower-GWP alternatives 

could be significantly reduced. Honeywell’s position on EPA’s proposal with respect to XPS and 

PU foam, two large users of HFC-134a, are detailed below.

 13 http://www.usitc.gov/trade_remedy/731_ad_701_cvd/investigations/2013/tetrafluoroethane_from_

china/preliminary/PDF/FR_ITC_Determinations_Prelim.pdf
18

a. HFC-134a in XPS Applications 

For XPS users, several solutions are already available, listed as acceptable under SNAP, 

and have been in use globally for some time. For example, in Europe, approximately 80% of the 

industry uses solutions other than HFC-134a, including CO2, HFC-152a, isobutane, and HFO1234ze(E). Similarly, in Japan, all XPS is produced with alternatives to HFC-134a, such as 

isobutane and HFO-1234ze(E). All of the above solutions are listed under SNAP as acceptable 

and are available to U.S. customers, some of whom are already using these low-GWP 

technologies in other parts of the world. HFO-1234ze(E) has been commercial since 2008, and 

is being used by customers in Europe and Japan. Honeywell is now running a large, world-scale 

commercial plant in Baton Rouge, Louisiana, which started operating in September 2014. 

Honeywell is ready to support an unacceptability listing date of January 1, 2016.

Energy efficiency and cost are two important factors to consider in evaluating 

alternatives. First, with respect to energy efficiency, the table below shows that HFO-1234ze(E)

is an excellent foam-blowing agent and results in energy efficiency properties that are 

comparable and in some instances better than HFC-134a. Vo and Fox from The Dow Chemical 

Company published a peer-reviewed study, which noted, “... [T]hermal insulation performance 

of foams obtained with HFO-1234ze(E) and co-blowing agents is very similar to those blown 

with HFC-134a produced today.”14 Jackon has been selling boards in the EU with energy 

efficiency that is better than HFC-134a since mid-2011 and four other EU customers are using 

HFO-1234ze(E) commercially. A major Japanese producer has also been commercially been 

selling boards made with HFO-1234ze(E).

Table 6. Comparison of Energy Efficiency Performance of Foam Blowing Agents15

Blowing Agent CO2 HFC-134a HFO-1234ze(E)

Aged lambda

(lower = better) 34-38 29-30 27-30

% improvement 

over CO2 — ~12-15% ~12-20%

In addition to HFO-1234ze(E), which offers comparable or better energy efficiency as 

HFC-134a in XPS, companies like The Dow Chemical Company have commercialized other 

solutions to improve energy efficiency with CO2. For example, Dow’s XENERGY technology, 

according to Dow, is the “[t]hermal insulation of the future. XENERGYTM combines proven 

features of STYROFOAMTM with up to 20% higher insulating properties made possible by a 

 14 Vo and Fox, Assessment of hydrofluoropropenes as insulating blowing agents for extruded polystyrene 

foams, JOURNAL OF CELLULAR PLASTICS, 49, 423 (2013).

15 Honeywell analysis based on customer information.
19

new manufacturing process using CO2 and reflecting particles in the foam cells. The result: 

reduced heating costs - increase efficiency, comfort and sustainability.”16

Cost is another important criterion. The economics of boards produced with HFO-1234ze 

are also reasonable compared with boards produced with HFC-134a, especially as the cost of 

HFC-134a has risen recently due, in part, to preliminary anti-dumping rulings against Chinese 

imports by the Department of Commerce and the International Trade Commission. Honeywell 

estimates that XPS board made with HFO-1234ze(E) is likely to be no more than 5% to 9% more 

expensive than a comparable board made out of HFC-134a. 

b. HFC-134a in PU Applications

HFC-134a is also used extensively in PU foam in rigid applications, such as continuous 

and discontinuous panels, commercial appliances, and spray foam. Honeywell is ready to 

support a transition date of January 1, 2016 for all PU applications except for two-component 

low-pressure spray foam, where we suggest the EPA finalize its proposed date of January 1, 

2017.

Across the various applications, a variety of solutions are available, including 

hydrocarbons, methyl formate, formic acid, methylal, HFO-1234ze(E) and HFO-1233zd(E), and 

HFO-1336mmz. Both HFO-1234ze(E) and HFO-1233zd(E) have large-scale U.S. 

manufacturing plants: Honeywell’s HFO-1233zd(E) plant began operating in May 2014 and

HFO-1234ze(E) plant started up in September 2014. DuPont announced plans to start its HFO1336mmz plant in the second half of 2016. Several customers in a variety of industries, 

including construction and commercial appliances have trialed HFO-1233zd(E) and HFO1234ze(E) and are in various stages of transitioning to those substances. They are seeing 

benefits of not only significantly lower climate impact but also improved thermal insulation 

performance. 

HFC-134a is used in three main PU foam applications, each of which is described below 

(and further described in comments by the Center for Polyurethanes Industry (CPI) and the 

American Chemistry Council): 

x Low-pressure one-component foams: Honeywell’s HFO-1234ze(E) has been 

commercially sold in the EU in low-pressure one-component foam since 2008 by 

companies like Dow, Fomo, Saudal. Hydrocarbons are also used extensively in these 

applications. 

x Low-pressure two-component foams used in commercial appliance and other pour 

applications: Customers have several solutions that are low-GWP and acceptable 

under SNAP, including Honeywell’s HFO-1233zd(E) and HFO-1234ze(E). 

x Low-pressure two-component spray foams: Honeywell’s HFO-1233zd(E) and HFO1234ze(E) product and blends thereof are being technically proven in this application 

by several customers, several of whom are optimizing the product.

 16 http://www.dow.com/products/market/construction/product-line/xenergy-extruded-polystyreneinsulation/
20

Overall, across all foam applications, including XPS and PU foams, customers have 

either commercialized non-HFC-134a solutions or have technically feasible solutions ready for 

commercialization, and there are sufficient number of SNAP-acceptable solutions to enable 

customers to transition to low-GWP substances relatively quickly. The relative cost of transition 

to low-GWP substances compared to continued use of HFC-134a has decreased dramatically, 

due in part to the rising costs of HFC-134a imported from China. Thus, Honeywell supports

listing HFC-134a as unacceptable by January 1, 2016, rather than January 1, 2017, for all foam

applications, except low-pressure two-component spray foam. For low-pressure two-component 

spray, we support EPA’s proposal to list HFC-134a as unacceptable, effective on January 1, 

2017. 

3. High-Pressure Spray Foam Applications for PU Foams

Currently, EPA does not propose to list as unacceptable any substances used in highpressure spray foam applications, such as HFC-143a, HFC-245fa, HFC-365mfc and blends 

thereof. In Honeywell’s view, this is the easiest and quickest application to transition, as 

demonstrated by transitions by several customers noted below. For example, high-pressure spray 

foam was one of the last applications that Honeywell started to commercialize with customers, 

but the first low-GWP product commercialized in the U.S. was in a spray foam application with 

West Development Group. Honeywell strongly supports listing HFC-143, HFC-245fa, HFC365mfc and blends thereof as unacceptable in high-pressure spray foam. Including high-pressure 

spray foam will offer additional savings of 7 million MtCO2e per year, which is approximately 

an additional 20% in CO2 savings before 2020 compared to what is included in the proposed 

rule.

Several low-GWP and non-flammable alternatives have been listed as acceptable under 

SNAP for use in spray foam applications. Honeywell has been selling HFO-1233zd(E)

commercially in this application since March 2013 in the U.S. and globally. HFO-1233zd(E)

was also successfully trialed in Philippines by UNIDO in 2012, almost two years ago. In the 

U.S., several customers, including small businesses such as Lapolla industries, West 

Development Group and Elastochem, have commercialized low-GWP spray foam formulations 

containing HFO-1233zd(E). There have been several case studies, attached to these comments 

as Appendix IV, demonstrating the capabilities of HFO-1233zd(E) in spray foam applications. In 

Japan, spray foam made with HFO-1233zd(E) has been commercialized by numerous customers 

including Toyo, Asahi, and BIP. In our experience, in the U.S., it took just 6-18 months from 

start of development to a formulated system that was technically and commercially saleable, with 

all the requisite regulatory approvals. Further, several U.S. customers are close to commercial 

systems and will be undergoing product certification shortly. We expect the commercialization 

timelines to continue to shorten. The supply chain of additives (catalysts, surfactants) has also 

developed substantially, so customers have a wide variety of components to formulate with 

HFO-1233zd(E). As another proxy for how quickly spray foam can transition, recently, when 

new materials such as HFC-365mfc blends have come to market, the industry has indicated that 

it can transition rapidly, typically in less than six months. 

Low-GWP alternatives in spray foam applications are high performance, low cost, and in 

ample supply. Customers who have already commercialized low-GWP spray foam based on 

HFO-1233zd(E) are seeing benefits of better energy efficiency as well as reduced cost. HFO1233zd(E) has demonstrated better yields (more foam per pound of liquid component) by as 
21

much as 10-12%, which results in large cost savings. In addition, these foams have shown 4% to 

8% improved energy efficiency, which means that customers can either improve the energy 

efficiency for the same thickness of foam or reduce the thickness to further bring down cost. On 

a total life-cycle analysis basis, which includes both direct and indirect GWP, foams with HFO1233zd(E) are shown to reduce CO2e life-cycle emissions by up to 90%.17 EPA should thus 

include spray foam applications in this rule.

These alternatives are available to supply the U.S. market. Honeywell’s HFO-1233zd(E)

large-scale plant started up in May 2014 and DuPont announced plans to start its HFO-1336mmz 

plant in the second half of 2016.18

Given the availability of low-GWP solutions, the ability of the industry to transition 

easily and quickly, and the benefits that go well beyond low-GWP, such as better energy 

efficiency and lower costs, Honeywell urges EPA to list high-GWP compounds such as HFC143a, HFC-245fa, and HFC-365mfc, and blends thereof, as unacceptable in spray foam 

applications beginning January 1, 2018. Inclusion of high-pressure spray foam in the rule will 

offer additional savings of about 7 million MtCO2e per year.

4. Other Applications (Transport, Marine, Specialized refrigerators, etc.)/Exemptions For PU

Foam

The EPA proposed rule is expansive with respect to foam applications, except for a few 

applications like military and aerospace. In Honeywell’s experience, the available solutions, 

including HFO-1233zd(E), HFO-1234ze(E) and others that are acceptable under SNAP have 

been commercialized in a number of applications such as spray, panel, appliance, etc. The 

formulation knowledge from those applications is easily transferable to other applications such 

as marine, road and sea transport, continuous or discontinuous panels, integral skin, flexible 

foam, etc. 

EPA might receive comments from customers and industries in more niche applications, 

such as medical refrigerators and boats, which typically do not engage in serious product 

development until after regulatory actions are near final. We do not believe that the technical and 

approval requirements of these industries present any serious challenges, and in fact, in some 

cases, such as flotation foams for boats, the technical requirements may be much simpler than 

other industries in which customers are already transitioning. We do not believe that any new 

exemptions, other than those already identified by EPA above for aerospace and military are 

necessary.

5. Products Containing HCFCs and HFCs

EPA proposes to extend its unacceptability determinations to foam blowing agents 

contained in the cells of closed-cell foams and to foams and products containing them, as well as 

the use of the foam blowing agent in manufacture of those products. Honeywell supports EPA’s 

proposal, but would like to the Agency to further define and specify its position on the 

 17 Bogdan and Pascual, Environmental assessment of next generation blowing agent technology using 

Solstice LBA in ccSPF, Polyurethane Magazine, 5 (2012).

18 http://www.gupta-verlag.com/general/news/industry/14939/dupont-fluorochemicals-announces-worlds-first-full-scale-production-of-hfo-1336mzz/pdf.
22

refrigerated containers and trailers industry. Refrigerated containers and trailers are used to 

transport food, medicine, other perishables, and may be manufactured with products that are 

classified as acceptable today but unacceptable in the future. These refrigerated containers and 

trailers travel through country borders and are used in service from 5-10 years, and then sold at 

the end of their life for use as storage, living, or other applications. Honeywell would like EPA 

to clarify in the final rule that refrigerated containers and trailers containing unacceptable 

blowing agents that were manufactured before the status change date are allowed to be in transit 

and are to be sold in the U.S. (for example at the end of their life) after the status change date. 

In addition, EPA is also proposing to prohibit import of products containing foams blown 

with unacceptable substitutes, such HCFC-141b, 60 days after the issuance of the final rule. 

Honeywell strongly supports EPA’s position, since prohibiting imports of products containing 

foam blown with HCFCs will not only benefit the environment by reducing use of an ozonedepleting substance, but also to maintain U.S. jobs and improve the competitiveness of U.S. 

companies who will not have to compete with imports of products made with substances that are 

not only ozone-depleting, but also less expensive. Honeywell believes it would be helpful for 

EPA to clarify the timing of prohibition as it would apply to products containing HCFCs and 

HFCs further in Section 2c of Foam Blowing Agents or elsewhere. Our understanding is that: a) 

imports of products containing foams with HCFCs would be prohibited 60 days after the 

issuance of the final rule; and b) imports of products containing foams with HFCs would be 

prohibited on the effective date of the unacceptability listing for those HFCs.

6. Open Cell Foams/ Flexible foams

EPA also seeks comment on whether it should consider the unacceptability 

determinations for foam blowing agents to apply to open cell foam and products containing open 

cell foam. Honeywell is aware of only one open cell application that uses a blowing agent other 

than water: flexible polyurethane. The most widely used blowing agents are CO2, acetone and 

methylene chloride. On review of the various SNAP approval tables through the past transitions 

(CFCs to HCFCs and HCFCs to HFCs), it is not clear whether or not methylene chloride is 

approved under SNAP. Honeywell supports EPA’s current position in the proposed rule to list 

select HFCs as unacceptable but also recommends that EPA list as unacceptable methylene 

chloride, consistent with the August 15, 2014 National Emission Standard for Hazardous Air 

Pollutants final rule,19 disallowing methylene chloride in flexible foams because it is a hazardous 

air pollutant. Our belief is that methylene chloride is not widely used in foam blowing 

applications in the U.S., but it is used to a large extent abroad, particularly in China, in the 

manufacture of flexible polyurethane products subsequently exported to the U.S. 

Honeywell believes EPA should list methylene chloride and products containing foam 

blown with methylene chloride as unacceptable, starting 60 days after the issuance of the final 

rule.

***

 19 79 Fed. Reg. 48073 National Emission Standards for Hazardous Air Pollutants Residual Risk and 

Technology Review for Flexible Polyurethane Foam Production (Aug. 15, 2014) (available at 

http://www.gpo.gov/fdsys/pkg/FR-2014-08-15/pdf/2014-18734.pdf).
23

As shown in the tables below, foam customers are already transitioning away from highGWP substances, and are seeing benefits in addition to lower climate impact, including higher 

energy efficiency and lower cost. 

Table 7. Announcements from Customers Adopting Low-GWP Alternatives in Foam 

Applications

APPLIANCE FOAM

Company Date Headline

Whirlpool Aug. 15, 2012 Whirlpool Corp. Leaps Ahead of Industry 

Standards, Committing to Use Honeywell’s Solstice 

Liquid Blowing Agent

Whirlpool

(WHR 

Release)

Aug. 15, 2012 Whirlpool Corporation and Honeywell Introduce 

Most Environmentally Responsible and Energy 

Efficient Insulation Available into U.S. Made 

Refrigerators

Midea Nov. 5, 2013 Midea to Adopt Honeywell’s Next-Generation 

Insulating Materials in Energy Efficient Refrigerators

Whirlpool

(WHR 

Release)

Jan. 22, 2014 Whirlpool Corporation Partners with Honeywell, 

Announces Use of Next Generation Solstice® Liquid 

Blowing Agent in U.S. Refrigerators

Midea July 8, 2014 Honeywell Will Help Reduce Climate Impact of 

Refrigerators and Freezers in China

BASF

(BASF 

Release)

July 24, 2014 BASF, Honeywell and Whirlpool bring the first 

commercial polyurethane insulation system using 

HFO blowing agent to market

Haier Sept. 18, 2014 World’s Largest Appliance Manufacturer to use 

Honeywell’s Low-Global-Warming-Potential 

Insulating Material in Energy-Efficient Refrigerators

SPRAY FOAM

Company Date Headline

West Roofing Sept. 19, 2013 Honeywell’s Solstice Liquid Blowing Agent Used in 

New, Highly Durable Roof for Cleveland Airport

Achillles Feb. 24, 2014 Leading Japanese Company to Use Honeywell’s 

Low-Global-Warming-Potential Blowing Agent for 

Spray Foam Insulation

Lapolla July 28, 2014 Lapolla Industries is the First Globally to Incorporate 

Honeywell’s Solstice Liquid Blowing Agent for 

Spray Foam Wall Insulation

Whirlpool, 

Lapolla

Sept. 12, 2014 Honeywell’s Low-Global-Warming Material 

Insulates Net-Zero Energy Home Project at Purdue 

University

PANEL FOAM

Company Date Headline

Kingspan May 20, 2014 Leading Insulation Company to use Honeywell’s 

Low-Global-Warming-Potential Blowing Agent
24

E. AEROSOLS

Honeywell supports EPA’s proposal for aerosol applications, but believes it can be 

strengthened by (1) closing potential loopholes, (2) further restricting the sell-through period, 

and (3) expanding the proposed rule to include additional applications for which preferable, lowGWP alternatives are already readily available.

EPA proposes to list some HFCs as unacceptable in targeted aerosol applications by 

January 1, 2016. Honeywell agrees with EPA that history shows the aerosols industry can 

convert quickly to alternatives with very limited equipment changes and capital expenditures, 

especially when drop-in replacements are available, as they are now. Customers have several 

options from Honeywell and others that are listed as acceptable under SNAP and are currently 

available. A significant number of customers in the U.S. and internationally (in both Europe and 

across Asia) have already adopted HFO-1234ze(E), and have commercialized products or have 

shelf-ready prototypes.20 Strong regulatory action will continue to drive broad conversion to 

available low-GWP alternatives in the U.S. Adoption of Honeywell technologies in the aerosols 

sector in the U.S. could reduce greenhouse gas emissions by more than 6 million MtCO2e per 

year in 2016.

1. Supply

Honeywell has invested significant capital ($33 million) at its Baton Rouge, Louisiana 

manufacturing facility to ensure high-volume manufacturing capability for HFO-1234ze(E).

21,22 

As announced on September 16, 2014, construction of the plant has been completed and 

commercial operations began in Q3 of 2014.23 The investment provides more than sufficient 

capacity to meet growing demand for this low-GWP product and would support the actions and 

timelines proposed by EPA.

2. Flammability

The proposed rule states that “at slightly higher temperatures (30oC or 85oF), HFO1234ze(E) exhibits lower and higher flammability limits and could catch fire under specific 

conditions of concentration and in the presence of a high energy spark or flame.” While it is 

accurate to say that HFO-1234ze(E) may exhibit vapor flame limits at elevated temperatures, that 

is only one of many properties that must be taken into consideration when characterizing HFO1234ze(E) and its usefulness in formulating non-flammable aerosol products.24

 20 See Appendix III to these comments. 

21 http://honeywell.com/News/Pages/Honeywell-To-Invest-$33-Million-In-Louisiana-Facility.aspx

22 http://honeywell.com/News/Pages/Honeywell-Announces-Investments-Of-$200-Million-In-LouisianaFacilities-Backed-By-Tax-Incentive-Framework-Agreement.aspx

23 http://honeywell.com/News/Pages/Honeywell-To-Increase-Production-Of-Low-Global-WarmingMaterials-Reduce-Hydrofluorocarbon-HFC-Production-By-Nearly-Half.aspx

24 It bears noting that HFO-1234ze(E) is not the first fluorochemical product to exhibit flammability 

characteristics under certain conditions and still be used safely. HFC-134a, a widely-used aerosol 

propellant, can become flammable when pressurized with air and exposed to strong ignition sources.
25

HFO-1234ze(E) is classified as a UN 2.2 non-flammable liquefied gas. That 

determination is based on testing by ASTM E 681 and ISO 10156:2010 standards. It has also 

been tested by the EC testing method A 11 (Flammability of Gases) and found to be nonflammable. HFO-1234ze(E) does not meet the National Fire Protection Association (NFPA)

definition of a flammable gas or flammable liquefied gas found in NFPA 55. (NFPA does not 

specifically define a non-flammable liquefied gas.)

HFO-1234ze(E) was also tested to determine its minimum ignition energy (MIE). MIE is 

the minimum spark energy required to ignite a substance under the test conditions. The standard 

test is run at room temperature. HFO-1234ze(E) could not be ignited in that test. At a 

temperature of 1300 F, the MIE was greater than 61,000 millijoules. That is considered to be a 

very high value. For comparison, the MIE of propane is 0.25 millijoules and HFC-152a is 0.38 

millijoules. A static electric discharge, from a person for example, will typically not exceed 10 

millijoules.

In addition to tests carried out on neat HFO-1234ze(E), aerosols containing HFO1234ze(E) have been tested using the standard aerosol flammability test methods – flame 

extension, ignition distance, and enclosed space ignition (closed drum test) – and found to be 

non-flammable by all of those methods. Honeywell has also carried out some non-standard tests 

such as spraying a HFO-1234ze(E) aerosol, both liquid and vapor, into a red-hot crucible at a 

temperature of greater than 9000 F. No ignition, flash, or other activity was observed.

The aerosol flammability tests described so far were conducted internally or at outside 

laboratories using HFO-1234ze(E) aerosol samples prepared by Honeywell. Honeywell has also 

had flammability tests run on products provided by customers. One example is an aerosol used in 

a product known as a “blast bag.” The product consists of an inflatable bag containing an 

aerosol can of propellant with a total-release valve. Blast bags are used in mining to seal a bore 

hole and provide a stable, effective deck for loading explosives. The valve is activated and the 

bag is lowered into the bore hole. Aerosol cans from blast bags were submitted for enclosed 

space ignition testing. This example is relevant because the cans contained only HFO-1234ze(E)

and because the enclosed space ignition test is particularly sensitive. The results showed the 

samples to be non-flammable.

One likely use of HFO-1234ze(E) is in aerosol tire inflators. Because of past accidents 

traced to the use of flammable tire inflators, there is great concern over demonstrating that there 

is no flammability hazard associated with servicing a tire containing a “non-flammable” tire 

inflator. This requires a different type of testing to create the conditions that exist within an 

automobile tire (temperature, pressure, etc.) and to utilize the likely ignition sources that may 

exist during servicing. The two that are most often identified are a torch applied to the rim of the 

tire and a spark within the tire created by a metal reaming tool scraping a steel belt in the tire. 

Testing was carried out by a third party laboratory using commercial-quality, HFO-1234ze(E)

tire inflators supplied by a filler/marketer of those products. The test matrix was designed to 

include normal and worst-case scenarios. The HFO-1234ze(E) tire inflators were found to be 

non-flammable. 

HFO-1234ze(E) aerosols are currently being filled in the U.S., Europe, and Asia. 

Honeywell is not aware of any plant or equipment modifications related to flammability 

concerns undertaken by fillers in converting from HFC-134a to HFO-1234ze(E). Furthermore, 
26

we note that there are non-flammable HFO-1234ze(E) aerosol products already commercially 

available or shelf-ready in many categories, including, but not limited to: dusters, freeze sprays, 

tire inflators, horns, defluxers, party string, and smoke alarm testers. In a testimonial discussing 

a new line of HFO-1234ze(E) dusters and freeze sprays, Ms. Jade Bridges, a technical support 

specialist at HK Wentworth Ltd., noted that the non-flammable qualities of HFO-1234ze(E), 

along with its environmental properties, made it a viable alternative to HFC-134a.25

3. Vapor Pressure

EPA states in the proposal that the vapor pressure of HFO-1234ze(E) is lower than that of 

HFC-134a. Propellant pressure is a key property that must be taken into account when 

developing an aerosol product. Honeywell notes, however, that the lower vapor pressure of 

HFO-1234ze(E) has not prevented the development of a wide variety of HFO-1234ze(E) aerosol 

products such as dusters, freeze sprays, and horns – in which the propellant is the only ingredient 

– as well as formulated aerosols such as defluxers, tire inflators, novelties, smoke detector 

testers, and others. In an article published in Aerosol Europe, Ms. Virginie Fourneau of Inventec 

Performance Chemicals suggests that the vapor pressure of HFO-1234ze(E) is actually better 

than that of HFC-134a for aerosol formulation.26

4. Conversion Requirements

While it is not possible to address potential conversion requirements under all possible 

circumstances, Honeywell is not aware of any special or costly modifications undertaken at any 

of the locations at which HFO-1234ze(E) aerosols are currently being filled. This was confirmed 

in a recent conversation with a U.S. filler of technical aerosols who has been using HFO1234ze(E) for several years. Conversion costs were described as being “minimal.”

x One-Time Costs: Based on customer conversions that have occurred to date, and 

discussions on pending conversions, it is not anticipated that there will be any capital 

costs required to convert an aerosol filling line from HFC-134a to HFO-1234ze(E). In 

some instances, a nominal expense might be required to replace gaskets and seals, but 

even this is uncertain because HFO-1234ze(E) is generally compatible with the same 

materials as HFC-134a.

x Aerosol Package Costs: In general, no changes in aerosol package components (i.e., 

cans, valves, actuators, dip tubes, etc.) are required when converting from HFC-134a 

to HFO-1234ze(E). However, in at least one product category, it will be possible to 

use a less expensive package with HFO-1234ze(E). Aerosols like dusters and freeze 

sprays, which contain only HFC-134a, exceed the allowable pressure for Department 

of Transportation (DOT)-specified aerosol cans. Those products are packaged in 

specially permitted cans, which cost approximately twice as much as a standard DOT 

2Q can. A DOT 2Q can costs approximately $0.30 per unit, versus approximately 

$0.60 per unit for the more robust container. Dusters and freeze sprays containing 

HFO-1234ze(E) will not require the more expensive packaging because HFO1234ze(E) has lower vapor pressure than HFC-134a. 

 25 http://www.honeywell-solstice-propellants.com/ResourceCenter/Pages/Details.aspx?ItemID=2

26 Vol. 18, No. 11 – 2010
27

x Aerosol Product Costs: Historically, HFC-134a prices have been very volatile because 

of supply/demand imbalances, and have ranged from $2.00 per pound to nearly $6.00 

per pound. Based on current HFC-134a pricing, the price of HFO-1234ze(E) at full 

commercialization is expected to be approximately 1.5-2 times the price of HFC-134a. 

The incremental cost to use HFO-1234ze(E) in an aerosol will depend upon the 

propellant concentration, which will typically range from 100% (as in a duster or 

freeze spray) to as low as 20-25% in a formulated aerosol product like a cleaner or 

mold release.

5. Availability of Products Not Containing HFC-134a

Honeywell agrees that many of the aerosol product classes in which the use of HFC-134a 

will continue to be acceptable under the current proposal are both necessary and useful. 

However, in some categories, such as cleaning products for electronics, sprays for aircraft 

maintenance, and dusters, there are either commercially available products or shelf-ready 

products that have not yet been commercialized that do not contain HFC-134a or any other highGWP propellant. Many of these products do contain HFO-1234ze(E), but several contain other 

propellants.27 We believe that the continued availability of products containing HFC-134a in 

these categories will serve as a disincentive for companies to develop and market lower-GWP

versions of those products. This was demonstrated at the August 1, 2014 Small Business 

Administration Roundtable by a commenter noting that they had not started reformulating their 

product simply because there was no regulation making it necessary to do so.

6. Open-Ended Sell-Through Period

EPA has proposed a sell-through period to prevent “stranded inventory.” The sell-through 

period would allow inventory produced prior to January 1, 2016 to be sold, imported and 

exported after that date, even if the product is classified as an unacceptable use of HFC-134a. 

Honeywell does not object to a sell-through period to prevent stranded inventory, but allowing 

continued sale of unacceptable product without an end-date would delay the transition to lowGWP substitutes, and disadvantage small businesses that are unable to carry large 

inventories. Honeywell thus proposes that EPA prohibit the sale, import and export of aerosol 

products manufactured with unacceptable substitutes by no later than January 1, 2017, thereby 

allowing manufacturers a year to transition their inventory. Honeywell also proposes that the 

sell-through period should apply only to products that were manufactured prior to January 1, 

2016 and that have entered the distribution channel. Honeywell believes that extending the sellthrough period to manufacturers, especially with an open-ended sell-through period, serves as a 

disincentive for the timely conversion to low-GWP substitutes. 

7. Additional Product Bans

Honeywell does not believe there is sufficient justification to allow continued use of 

HFC-134a in duster sprays for photographic negatives, semiconductor chips, and specimens 

under electron microscopes. Honeywell believes that eliminating these uses of HFC-134a is 

practical because of the commercial availability of dusters containing alternate propellants such 

 27 See the table “Summary of Honeywell Position—Aerosols” at page 5-7, above.
28

as HFC-152a and HFO-1234ze(E). Furthermore, since dusters are often distributed through 

channels over which the marketer has no control, this special exemption creates a loophole 

whereby a duster labeled for an exempt use could be purchased and used for other applications.

As a practical example, California regulations allow HFC-134a dusters to be used only on 

energized electrical equipment, and cans are so labeled. However, it is possible to purchase an 

HFC-134a duster from an online catalog for delivery to an address in California without any 

restrictions or questions about the intended end-use. Honeywell believes that the special 

exemption for duster sprays for photographic negatives, semiconductor chips, and specimens 

under electron microscopes creates a loophole without any demonstrated offsetting benefit.

Honeywell also proposes that EPA list HFC-134a as unacceptable for use in cleaning 

products for removal of flux and other soils from electrical equipment and electronics. There are 

numerous examples of available defluxers containing alternative propellants, including nonflammable propellants such as HFO-1234ze(E).

28

***

As shown in the table below, aerosol customers are already transitioning to low-GWP

substances. 

Table 8. Announcements from Customers Adopting Low-GWP Alternatives in Aerosol 

Applications

Company Application Date Headline

Mission 

Pharmacal Personal Care Sept. 17, 2014

Dr. Smith’s® Goes to Washington to 

Participate in White House HFC Industry 

Leadership Roundtable

Home Safeguard 

Industries (HSI)

Smoke Alarm 

Tester Dec. 2013 Home Safeguard Industries Chooses Solstice® Propellant for Fire Safety Testing

Microcare Dusters May 28, 2009

Honeywell's New Propellant Reduces 

Global Warming Impact of Aerosol 

Cleaners in Europe by 99 Percent

Falcon Safety Dusters Feb. 28, 2011 Dust-Off® Non-Flammable ECO Duster Set 

for U.S. Launch

Solchim S.p.A. Novelty Aerosols 2009

Solchim S.p.A., Specialty Aerosols 

Company, Replaces R-134a with Solstice® 

Propellant

HK Wentworth 

Group

Dusters / Freezer 

Sprays Jan. 2012

HK Wentworth Group, an industrial 

products company selling to markets around 

the world, leverages the low carbon benefits 

of Solstice® Propellant in its air-dusters and 

freezer sprays

Produits 

Sanitaires 

Aeronefs (PSA)

Airplane OnBoard Insecticide May 2012 Solstice® Takes Flight

 28 See Appendix III. 
29

MTi Group Mining Products August 2013 MTi Group Chooses Honeywell Solstice® 

Propellant for Inflatable Mining Products

Electrolube

Duster Spray for 

Electrical and 

Electronic 

Equipment

July 21, 2011 Electrolube Exhibits “Green Products” at 

AATE

III. CONCLUSION

Thank you for this opportunity to share our comments on the proposed rule. Honeywell is 

strongly supportive of EPA’s proposal, and believes that the time to act is now so that the U.S.

can lead the rest of the world in transitioning away from high-GWP compounds. If you have any 

further questions, please do not hesitate to contact: Ken Gayer at 

kenneth.gayer@honeywell.com, Amy Chiang at amy.chiang@honeywell.com, or Dave Stirpe at 

david.stirpe@honeywell.com.
30

APPENDIX I

Alternative Products for Refrigerant Applications

A. Mobile Air Conditioning (MAC) – Solstice® MAC (HFO-1234yf)

x In use in nearly two million cars globally

x 99.9% reduction in GWP compared to HFC-134a

x More efficient than CO2

x 28 different automobile brands are selling approximately 60 different models in the 

world designed to use HFO-1234yf. U.S.-based companies, including Ford, GM, 

Chrysler, and Tesla are manufacturing more than a dozen models using HFO1234yf.29

 29 This data is from a list compiled by the Institute for Governance and Sustainable Development (IGSD) 

(Oct. 12, 2014) (Sources include Deutsche Umwelthilfe, Mobile Air Conditioning Society (9/19/2014), 

EU Stakeholder Meeting (11/2013) and IGSD communication with MVAC experts.

Company, 

Product Name Product Photo

General MotorsCadillac XTS, others

www.gm.com

Chrysler 

CorporationJeep Cherokee, 

others

www.chrysler.com
31

B. Vending Machines - HFO-1234yf

x In use by two manufacturers in Japan

x 99% reduction in GWP compared to HFC-134a

x More efficient than CO2, safer than hydrocarbons

Company Product Photo

Kubota Corporationwww.kubotaglobal.net/vending/english/

Fuji Electricwww.fujielectric.com
32

C. Chillers – Solstice® zd and Solstice ® ze

(HFO-1233zd(E) and HFO-1234ze(E))

x Approximately 99% reduction in GWP compared to HFC-134a or HCFC-123

x Chillers are 10% more efficient than best chillers today.

Company, 

Product Name

Product Photo

Trane – HFO1233zd(E) Centrifugal 

Chiller

http://www.trane.com/

commercial/northamerica/us/en.html

Climaveneta- HFO1234ze(E) Chiller

http://www.climavenet

a.com/

Airedale-HFO1234ze(E) Chillers

www.airedale.com

Geoclima – HFO1234ze(E) Chiller

www.geoclima.com

Star Refrigeration –

HFO-1234ze(E)

Chiller

http://www.starref.co.uk
33

D. Commercial Refrigeration - Solstice® N-40

x GWP of N-40 is 67% lower than R-404a while delivering higher efficiency

x Oak Ridge National Labs testing shows 11.6% increase in the coefficient of 

performance compared to R-404A

x Copeland testing shows 3-8% higher efficiency than R-404A

Company, Product Name Logo or Product Photo

Oak Ridge National Labs

http://www.ornl.gov

Copeland – Emerson

Climate Technologies

http://www.emersonclimate

.com/enus/brands/pages/copeland.as

px
34

APPENDIX II

Alternative Products for HFC-134a, HFC-245fa and HFC-365mfc 

Foam Applications

A. One Component Foam 

x HFO-1234ze(E) in one-component foam, replacing HFC-134a

x Commercial in EU since 2008 

Company, Product Name Logo or Product Photo

Product Name:
35

B. Extruded Polystyrene (XPS)

x HFO-1234ze(E) in extruded polystyrene foam, replacing HFC-134a and HFC-152a

x Commercial in EU since 2010 and Australia, Japan since 2014

Company, 

Product Name Logo or Product Photo

Product Name:
36

C. Continuous Panels

x HFO-1234ze(E) and HFO-1233zd(E) replacing HFC-134a, HFC-245fa, HFC-365mfc, 

and hydrocarbons 

x Commercial in EU since early 2014, commercialization imminent in US 

Company,

Product Name Logo or Product Photo

Kingspan (EU)

x phenolic boards 

for residential 

insulation

All Weather Insulated 

Panels (US)

x Insulated metal 

panels for 

industrial 

construction and 

cold storage. 
37

D. Domestic Appliances 

x HFO-1234ze(E) and HFO-1233zd(E) replacing HFC-134a, HFC-245fa and HFC365mfc/227ea

x Commercial in US, Mexico, China; imminent in EU 

Company, 

Product Name Logo or Product Photo

Adoption complete / 

underway: Whirlpool 

(US / Mex), Midea 

(China), Festivo 

(Finland), Haier 

(China)
38

E. Commercial Appliances 

x HFO-1234ze(E) and HFO-1233zd(E) replacing HFC-134a, HFC-245fa and HFC365mfc/227ea

x Commercial in EU, Japan; imminent in US, Mexico 

Company, Product 

Name Logo or Product Photo

Adoption complete 

/ underway: Porka 

(Finland), Okamura 

(Japan)

Trials Nearing 

Completion: 

(company names 

confidential) US / 

Mex, US, Japan
39

F. Spray Foam 

x HFO-1234ze(E) and HFO-1233zd(E) replacing HFC-134a, HFC-245fa and HFC365mfc/227ea

x Commercial in US, Japan; imminent in EU 

Company, 

Product Name Logo or Product Photo

Lapolla (US), 

West 

Development 

Group (US), 

Soflanwiz 

(Japan), Nihon 

Puftem (Japan), 

BIP (Japan) 

Cleveland Airport (Company: West Development Group)

Purdue house (Company: Lapolla industries) 

Philadelphia Water Treatment Facility (Company: West Development Group)

Nihon Puftem Announcement

Toyo Tire (Soflanwiz) 

Announcement
40

APPENDIX III

Alternative Aerosol Products For HFC-134a Applications

A. Tire Inflators

x HFO-1234ze(E) based tire inflator

x At least 90% of the manufacturers are currently evaluating or have shelf-ready products

Company, 

Product Name Logo or Product Photo

Technical Chemical 

Corporation, Tire 

Inflator
41

B. Dusters

x All non-flammable and recommended for use on electronics

x At least 90% of the manufacturers in the market have a commercialized product

Company, Product Name Logo or Product Photo

Miller Stephenson, Aero 

Duster, http://www.millerstephenson.com/low-globalwarming-products/

Falcon, Dust-Off ECO, 

http://www.amazon.com/indus

trialscientific/dp/B009L9A2X6

MicroCare, Big Blast EU, 

https://www.microcare.com/pr

oductdetail.html?xRefId=1&xRefIte

mId=46&product_id=18

ITW Chemtronics, Typhoon 

Blast, Typhoon Blast All the 

Way, Typhoon Duster and 

Typhoon Surge, 

http://www.chemtronics.com/p

roducts/product.asp?id=598

Techspray, ECO-Duster, 

http://www.newark.com/techsp

ray/1580-10s/eco-duster-spraybottle-253ml/dp/88T4950
42

C. Safety Horns

x HFO-1234ze(E) based non-flammable safety and marine horns

x At least 90% of the manufacturers in the market have a commercialized product

Company, Product Name Logo or Product Photo

ECO Sonic Safety: For Marine 

as well, 

https://www.falconsignal.com/

shop/category/eco-sonicsafety-horn

ECO Sound Signal Horn: For 

Marine as well, 

https://www.falconsignal.com/

shop/eco-sonic-horn
43

D. Party Streamers

x Non-flammable option propelled by HFO-1234ze(E), available in Europe 

Company, Product Name Logo or Product Photo

Solchim, Party String

Xiomara, Party String, Snow 

Spray
44

E. Smoke Alarm Testers

x Non-flammable option propelled by HFO-1234ze(E)

x Major manufacturers are either currently evaluating or have commercialized product

Company,

Product Name Logo or Product Photo

HomeSafe Guard, 

PurCheck, 

http://www.homesaf

eguard.com/pur_che

ck.html
45

F. Freeze Sprays for Tissue

x Non-flammable option propelled by HFO-1234ze(E)

x Many manufacturers have shelf-ready products or commercialized products

Company, Product Name Logo or Product Photo

Miller Stephenson, Quick 

Freeze, http://www.millerstephenson.com/low-globalwarming-products/
46

G. Freeze Sprays for Electronics

x Non-flammable with HFO-1234ze(E)

x At least 90% of the manufacturers have a commercialized product

Company, Product Name, 

Link Logo or Product Photo

Miller Stephenson, Quick 

Freeze, http://www.millerstephenson.com/low-globalwarming-products/

MicroCare, Circuit Chiller, 

https://www.microcare.com/pr

oductdetail.html?xRefId=1&xRefIte

mId=49&product_id=58

Techspray, Freeze Spray, 

https://www.techspray.com/p158-eco-freezer.aspx

ITW Chemtronics, Freeze 

Spray, 

http://www.mcmelectronics.co

m/product/CHEMTRONICSES1054-/20-5130
47

H. Additional: Industrial Cleaners and Rust Inhibitors

Company, Product Name, 

Link

Logo or Product Photo

Miller Stephenson, Dry 

Lubricant, Precision Cleaning, 

Heavy Duty Solvent, Rust 

Inhibitor, http://www.millerstephenson.com/low-globalwarming-products/

Microcare, Flux Remover, 

https://www.microcare.com/pro

ductdetail.html?xRefId=1&xRefIte

mId=47&product_id=44
48

I. Additional: Other Products

Company, Product Name Logo or Product Photo

Mission Pharmacal, Diaper Rash line 

of products, 

http://www.adultbarrierspray.com

Dental Ceramic Spray

Radio Systems Corp: Pet 

Training/Bark Control Product 

(Australia), 

http://intl.petsafe.net/intl/ch/products

/bark-control/spray

MTi Mining Safety: Blast Bag 

(Australia), 

http://www.zero.mtigroup.com.au/

Fumakilla: Bug Control Product 

(Japan), http://www.fumakilla.co.jp
49

APPENDIX IV

Case Studies of HFO-1233zd(E) in Spray Foam and Appliance 

Foam Applications

x SolsticeTM Liquid Blowing Agent “Takes Off” at Cleveland Hopkins International Airport

x SolsticeTM Liquid Blowing Agent Receives Positive Review for Theater Roof Repairs

x Honeywell Solstice® Liquid Blowing Agent: An Insulation Retrofit From the Outside-In

x Solstice® Liquid Blowing Agent Helps Philadelphia’s Quest to be “America’s Greenest 

City”

x Whirlpool Corporation, Case Study (April 2012)
Copyrighted page(s) removed. Copyrighted 

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it may not be reproduced without consent of the 

copyright holder. 

Removed pages can be viewed at the USEPA 

Docket Center, Public Reading Room. 

Address: 1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 202-566-1744 

Email: docket-customerservice@epa.gov