MEMORANDUM

To: Margaret Sheppard, U.S. EPA

Cc: Rebecca von dem Hagen, Luke Hall-Jordan, and Bella Maranion, U.S. EPA

From: Sabrina Andrews, Kasey Knoell, Becky Ferenchiak, and Mark Wagner, ICF International

Date: January 12, 2015

Re: Potential Impacts of Hydrocarbon Refrigerants during Recycling and Disposal of Appliances 

(EPA Contract Number EP-W-10-031, Task Order 405, Task 1)

This memorandum presents an assessment of the potential impacts of hydrocarbon refrigerants during 

the recycling and disposal of appliances. It is prepared in response to a public comment on EPA’s 

proposed rule, Protection of Stratospheric Ozone: Listing of Substitutes for Refrigeration and Air 

Conditioning and Revision of the Venting Prohibition for Certain Refrigeration Substitutes (EPA-HQ-OAR2013-0748) from the Institute of Scrap Recycling Industries (ISRI) which commented that EPA did not 

adequately consider the potential impacts of the proposed rule on the recycling industry. 

Please contact Mark Wagner at 202-862-1155 (mark.wagner@icfi.com) with any questions or 

comments.
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1 Background/Overview of Appliance Recycling and Disposal

Section 608(c)(2) of the Clean Air Act (CAA) prohibits knowingly venting or otherwise knowingly 

releasing or disposing of any refrigerant substitute for class I or class II substances by any person during 

maintaining, servicing, repairing, or disposing of appliances or industrial process refrigeration

equipment. EPA’s rule, Protection of Stratospheric Ozone: Listing of Substitutes for Refrigeration and Air 

Conditioning and Revision of the Venting Prohibition for Certain Refrigeration Substitutes (EPA-HQ-OAR2013-0748), exempts four hydrocarbon refrigerants from the venting prohibition for the following enduses:

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 Propane (R-290)

o Residential and light commercial AC and heat pumps

o Vending machines

o Household refrigerators, freezers, and combination refrigerators and freezers

 Isobutane (R-600a)

o Retail food refrigeration (stand-alone units only)

o Vending machines

 R-441A

o Residential and light commercial AC and heat pumps

o Retail food refrigeration (stand-alone units only)

o Vending machines

 Ethane (R-170)

o Very low temperature refrigeration

o Non-mechanical heat transfer equipment (e.g., thermosiphons)

EPA determined that for the purposes of CAA section 608(c)(2), the venting, release, or disposal of such 

hydrocarbon refrigerant substitutes in the specified end-uses does not pose a threat to the 

environment, considering both the inherent characteristics of these substances and the limited 

quantities used in the relevant applications. EPA additionally concluded that other authorities, controls 

and practices that apply to such refrigerants (including those established by OSHA and NIOSH guidelines, 

various standards, and state and local building codes) help to mitigate environmental risk from the 

release of those four hydrocarbon refrigerant substitutes. For example, OSHA Standard 1910.32 

designates appropriate personal protective equipment (PPE) for workers to minimize exposure to any 

releases, state and local air quality agencies may include VOC emissions reduction strategies in state 

implementation plans developed to meet and maintain the NAAQS that would apply to hydrocarbon 

refrigerants; and UL Standards for flammable refrigerants (e.g., UL 250 Supplement SA, UL 471 

Supplement SB) provide charge size restrictions for hydrocarbons in refrigeration equipment. 

 

1 On May 23, 2014 at 79 FR 29682, EPA revised the venting prohibition for refrigerant substitutes to exempt three 

hydrocarbon refrigerant substitutes listed as acceptable subject to use conditions in the specified end-uses under 

the SNAP Program: isobutane (R–600a) and R–441A, which were listed as acceptable, subject to use conditions, as 

refrigerant substitutes in household refrigerators, freezers, and combination refrigerators and freezers, and 

propane (R–290), which was listed as acceptable, subject to use conditions, as a refrigerant substitute in retail food 

refrigerators and freezers (stand-alone units only).
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Furthermore, the use restrictions imposed on the hydrocarbon refrigerants are intended to allow for the 

use of these flammable refrigerants in a manner that will ensure they do not pose a greater risk to 

human health or the environment than other substitutes that are currently or potentially available. 

These restrictions include conditions consistent with industry standards, limits on charge size, and 

requirements for warnings and markings on equipment (e.g., labeling, color coding) to inform 

consumers and technicians of potential flammability hazards.

During the public comment period for this proposed rulemaking, EPA received a submission from the 

Institute of Scrap Recycling Industries (ISRI) which commented that “EPA did not adequately consider 

potential impacts of this Proposed Rule on the recycling industry” (ISRI 2014). In addition, ISRI expressed 

concerns that, as 40 CFR 82 Subpart F gives recyclers the regulatory responsibility to properly extract 

(and recycle, if applicable) refrigerant from equipment prior to further processing, recyclers will be 

responsible for removing these flammable refrigerants from appliances, which would add additional risk 

to the recyclers (ISRI 2014).

The remainder of this memorandum assesses the safety risks for the recycling and disposal industry 

associated with flammable refrigerants through a review of the disposal policies and identified best 

practices for other regions where hydrocarbon refrigerants are more widely used: European Union, 

Australia, and Japan. In addition, this memorandum reviews the potential safety risks associated with 

disposing of appliances containing hydrocarbon refrigerants to a landfill without removing the 

refrigerant prior to landfilling (i.e., no prior venting or recovery). 

2 Assessment of Safety Risks Associated with Flammable Refrigerants

on the Recycling Industry

In order to assess the safety risks associated with flammable refrigerants to workers in the recycling 

industry in the United States, a review of current practices for recycling and disposal of appliances 

containing hydrocarbon refrigerants and a review of risks associated with releases was undertaken for 

locales with substantial experience working with hydrocarbon-based equipment.

2.1 Current Practices for Recycling and Disposal of Appliances Containing 

Hydrocarbon Refrigerants

Hydrocarbon refrigerant use in the United States is currently limited, but expanding. As such there are 

some procedures in place in the U.S., but the development of further requirements can be informed by 

looking to how these refrigerants are handled in other countries where hydrocarbon refrigerants are 

used widely. After presenting available information on U.S. regulations and procedures for hydrocarbon 

refrigerants, best practices for safe disposal and recovery of hydrocarbon refrigerants based on 

publically available information from regions/countries that already use appliances with hydrocarbon 

refrigerants were reviewed, including the European Union (EU), Australia, and Japan.

2.1.1 United States

Hydrocarbon refrigerants have been SNAP-listed in appliances starting in 2012, with isobutane and R441A in household refrigerators and freezers and propane in retail food refrigeration (stand-alone units 

only), with charge size restrictions of 57 grams and 150 grams, respectively. Since the date of SNAP 

listing, hydrocarbons have slowly begun entering the U.S. market in these end-uses. The SNAP approval 
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of four hydrocarbon refrigerants in six end-uses in this final rule, coupled with restrictions proposed on 

certain HFC refrigerants in the SNAP Status Change Rule, is anticipated to increase the penetration of 

hydrocarbon use in the identified equipment in the U.S. moving forward. 

Summary of Hydrocarbon Refrigerant Recovery and Disposal Requirements

Releases and/or disposal of hydrocarbon refrigerants, along with many other refrigerant substitutes, are

controlled by other authorities in addition to EPA including OSHA and NIOSH guidelines, various 

standards (e.g., UL, ASHRAE), and state and local building codes. To the extent that release during 

maintaining, repairing, servicing or disposing of appliances is controlled by regulations and standards of 

other authorities, EPA believes these practices and controls for the use of hydrocarbons are sufficiently 

protective. 

Furthermore, EPA intends to update the CAA Section 608 technician certification test bank in 

accordance with 40 CFR 82.161 to specifically include questions concerning flammable refrigerant 

substitutes. The Refrigeration Service Engineers Society (RSES) has also developed a technician training 

program in collaboration with refrigeration equipment manufacturers and users that addresses safe use 

of flammable refrigerant substitutes, including introduction to hydrocarbon refrigerants; regulations and 

standards; refrigerant safety; compressor-terminal venting; compressor change-out; system flushing, 

purging, and pressure testing for leaks; compressor misuse; compatibility; service procedures; 

temperature-pressure chart for HC refrigerants; and a SNAP appendix detailing substitutes subject to 

use restrictions. EPA also considered establishing a use condition in the final rule requiring training in 

handling flammable refrigerant substitutes for technicians servicing or disposing of equipment 

containing such substitutes, and requested public comment on the mandatory elements of such training 

(EPA 2014). In addition, several submitters who have received SNAP approval for hydrocarbon 

refrigerants have already developed training programs and updated equipment manuals specifically for 

flammable refrigerants for technicians and users. 

Best Practices for Hydrocarbon Refrigerant Recovery and Disposal

The proposed rulemaking included use restrictions for all four hydrocarbons in their proposed end-uses. 

These use restrictions were implemented in order to ensure that use of these flammable refrigerants 

will not result in a greater risk to human health or the environment than other substitutes that are 

currently or potentially available, particularly for technicians servicing such equipment. 

Although recovery of flammable hydrocarbon refrigerants is not required, best practices for safe 

servicing, venting, and disposal of appliances with hydrocarbon refrigerants identified by EPA in the 

proposed rule (EPA 2014) include:

 Only technicians specifically trained in handling flammable refrigerants should service or dispose 

of refrigeration and AC equipment containing these substances.

 Releases of large quantities of refrigerant substitutes during servicing and manufacturing should 

not take place in enclosed, poorly ventilated spaces, but rather release should be in a wellventilated area, such as outside of a building.

 Releases of refrigerant substitutes should not take place near an ignition source, particularly if 

large amounts of refrigerant are stored nearby.

 Warning labels are required on household and retail refrigerators and freezers, vending 

machines, non-mechanical heat transfer equipment, very low temperature refrigeration 

equipment, and room air conditioners.
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 Equipment must have distinguishing color-coded hoses and piping to indicate use of a 

flammable refrigerant.

 Equipment refrigerant charge sizes are restricted for household and stand-alone commercial 

refrigerators and freezers, including very low temperature freezers; vending machine;, and room 

AC units that reflect the UL 250, UL 471, UL 541 and UL 484 standards.

 Separate service fittings for use with flammable refrigerants is recommended in the event that a 

servicing access port is added to the equipment.

2.1.2 European Union

Manufacturers of domestic refrigeration and air conditioning equipment in the Europe Union (EU) have 

been converting to hydrocarbon refrigerants, such as isobutane in compressor cooling systems, since

1995 (CECED 2005a), and portable air conditioning systems containing propane have been available on 

the European market since 1985 (Unilab 2013). Most domestic refrigerators and freezers made in 

Europe use hydrocarbons (i.e., isobutane) as the refrigerant (F-Gas Support 2009). Approximately 8 

million refrigerators using hydrocarbons are produced in Europe annually by companies such as Bosch, 

Electrolux, Miele, Whirlpool, and AEG. In addition, the majority of hydrocarbon portable air conditioners 

manufactured in China are exported to Europe (UNEP 2011). Furthermore, in 2009, there were already 

more than 100 million small domestic refrigerator and freezer systems operating in Europe (F-Gas 

Support 2009). In accordance with EU Standard EN 378:2008 the maximum allowable quantity of 

hydrocarbon refrigerant in domestic refrigerators and small portable air conditioners is 150 grams (ARTI 

2010). 

Summary of Hydrocarbon Refrigerant Recovery and Disposal Requirements

Regulations for refrigerants in the EU are governed by both standards and directives. The directives, 

issued by the European Commission (EC), contain requirements for certain types of equipment, while 

standards are more technical documents developed by European standard setting organizations (ARTI 

2010). There are several directives related to the recovery and disposal of hydrocarbon refrigerants in 

appliances in the EU. 

Table 1 summarizes some of the Directives established in the EU that apply to the recovery and disposal 

of hydrocarbon refrigerants.

Table 1: Summary of Regulations and Standards for Recovery and Disposal of Hydrocarbon 

Refrigerants in the European Union

Regulation/

Standard

Title Description Source

Directive 

2012/19/EU

WEEE (Waste and 

Electronic 

Equipment) Directive

 Revisions to Directive 2002/96/EC

 As a minimum, hydrocarbons have to be 

removed from any separately collected WEEE

 Such hydrocarbons shall be disposed of or 

recovered in compliance with Directive 

2008/98/EC (see below)

European 

Parliament 

and Council of 

the EU 2012

Directive 

2008/98/EC

EU Waste 

Framework Directive

 Sets basic concepts and definitions related to 

waste management, including definitions of 

waste, recycling, and recovery

EC 2014a

Directive 

2002/96/EC

WEEE Directive  ODS or gases with a GWP higher than 15 must 

be separately collected and treated

CECED 2005a;

CECED 2005b
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Regulation/

Standard

Title Description Source

 Annex II(2) requires extraction and proper 

treatment of HFCs used for refrigerators and 

freezers, but exempts gases, such as isobutane 

 Annex III requires hazardous explosive 

atmospheres be designated, ignition sources 

be labeled, and unauthorized personnel 

should not enter the treatment center

Directive 

1999/92/EC

ATEX (Atmosphères 

Explosibles) 

Workplace Directive

 Includes the health and safety protection of 

workers potentially at risk from explosive 

atmospheres

 Describes the safety measures employers 

must implement to prevent and protect 

against explosions

 Classifies hazardous areas into different zones

 All treatment facilities, even those for CFC 

appliances, shall comply with explosion 

protection measures

ARTI 2010; 

CECED 2006

EN 378:2008 Refrigerating 

Systems and Heat 

Pumps – Safety and 

Environmental 

Requirements

 Published by European Committee for 

Standardization (CEN)

 EN 378-4:2008, the 4th part of the standard, 

covers operation, maintenance, repair, and 

recovery

 Compliance with the safety requirements of 

EN 378 will ensure compliance of all regulatory 

standards and documents

ARTI 2010

EN 13313:2001 Refrigerating 

Systems and Heat 

Pumps –

Competence of 

Personnel

 Published by European Committee for 

Standardization (CEN)

 Establishes procedures for achieving and 

assessing the competence of personnel who

design, install, inspect, test and commission, 

maintain, repair and dispose of refrigerating 

systems and heat pumps with respect to 

health, safety, environmental protection, and 

energy conservation requirements

ARTI 2010

EN 60079 Electrical Apparatus 

for Explosive Gas 

Atmospheres

 Published by European Committee for 

Electrotechnical Standardization (CENELEC)

 Requirements for construction, safety, 

protection, and training for electrical systems 

in potentially explosive gas atmospheres

 EN 60079-15:2005 is harmonized with the 

ATEX Directive for equipment in potentially 

explosive atmospheres

ARTI 2010

Best Practices for Hydrocarbon Refrigerant Recovery and Disposal

Under a joint project by the WEEE Forum (an open non-profit association of voluntary industry-driven 

collective WEEE take-back systems), EERA (European Electronics Recyclers Association) and CECED 

(European Committee of Domestic Equipment Manufacturers) titled “Treatment of New Generation 
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Refrigerators and Freezers Containing Hydrocarbons (HC),” a set of voluntary standards on the 

collection, storage, transport, and handling of cooling and freezing appliances containing hydrocarbon 

refrigerants were developed and agreed upon in 2006 (CECED 2006). These voluntary standards, which 

serve as best practices for such activities related to hydrocarbon appliances, complement Directive 

2002/96/EC on WEEE and include recovery and recycling specifications. 

According to the voluntary standards developed by the WEEE Forum, EERA, and CECED, cooling and 

freezing appliances and components, materials and substances thereof must be processed at a rate of 

recovery of at least 80% and a reuse and recycling rate of at least 75% by weight per appliance. Sorting 

of types of cooling and freezing appliances should take place at the treatment plant and be performed 

and supervised by trained personnel, in accordance with treatment requirements for such appliances. 

In summary, these best practices at end-of-life of hydrocarbon appliances include the following:

 removal of all liquids and hydrocarbon refrigerants must be separated from oil;

 hydrocarbon emissions must comply with national legislation; and

 operations must be equipped with protective measures against possible fires and explosions.

In a 2005 press release, the Director of CECED noted that for recycling facilities to be designed to 

properly protect workers, “all that is required is a controlled release of hydrocarbons at the recycling 

facilities. Ventilation needs to be arranged so that the ratio HC/air is kept within safety limits” (CECED 

2005a). According to a report by the UK Environment Agency and Scottish Environment Protection 

Agency on guidance on the recovery and disposal of controlled substances contained in refrigerators 

and freezers, levels of hydrocarbons in the treatment system and headspace of the filter units should be 

maintained below 25% of the lower explosive limit (LEL). To properly detect an exceedance of this 

recommended level, detectors with automatic shutdown should be installed (Environment Agency 

2002). 

Because it is often difficult to identify which appliances contain hydrocarbons at end-of-life, such safety 

and engineering control practices should always be followed to mitigate any potential explosion risks. 

Therefore, all treatment facilities must comply with the explosion protection measures outlined in 

Directive 1999/92/EC (CECED 2006). According to Directive 1999/92/EC, in practice, explosions inside 

the shredder can be avoided by controlling conditioning, including rarefaction of the hydrocarbon 

atmosphere by blowing air into the process, reduction of the oxygen content by substituting air with 

inert gases, and use of alternative explosion proof processing-technologies (CECED 2006).

According to Directive 2012/19/EU, as a minimum, hydrocarbons must be removed from any separately 

collected WEEE and disposed of or recovered in compliance with Directive 2008/98/EC. Only gases that 

are ozone depleting or have a GWP above 15 must be properly extracted from equipment and properly 

treated. Therefore, this directive does not explicitly require the further treatment of hydrocarbons 

following removal; however, the directive also does not explicitly state that these hydrocarbon 

refrigerants may be vented intentionally. Best practices include the employment of proper safety 

measures during all hydrocarbon refrigerant recovery and equipment disposal activities. 

2.1.3 Australia

Manufacturers in Australia have adopted hydrocarbons in domestic refrigerators, small integral 

commercial cabinets, fluid chillers, industrial refrigeration, and mobile air conditioning systems. In 2013, 

approximately 100 metric tons of hydrocarbons were supplied to charge or service equipment for use in 
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multiple refrigeration and air-conditioning sectors. The market share for hydrocarbons is expected to 

grow with the continued phase out of ozone depleting substances (Australian Government 2013). The 

Australian Government has proven experience using natural refrigerants, and believes that natural 

alternative refrigerants can be used safely and effectively (Australian Government 2012).

Summary of Hydrocarbon Refrigerant Recovery and Disposal Requirements

In Australia, recovery and recycling of any fluorocarbon refrigerant or fluorocarbon blend at the end of 

its useful life is mandatory (AIRAH and IRHACE 2007); however, Australia allows venting of nonfluorocarbon refrigerants. According to the Australian Institute of Refrigeration, Air Conditioning and 

Heating (AIRAH) “Flammable Refrigerant Safety Guide”, under certain circumstances it is acceptable to 

vent hydrocarbon refrigerants, if the following local and national rules and regulations permit, including:

 legislation relating to waste material;

 environmental legislation;

 Work Health and Safety (WHS) and Occupational Health & Safety (OH&S) legislation and 

regulation; and

 legislation related to hazardous substances. (AIRAH 2013)

When venting a refrigerant, a risk assessment must be performed that examines the amount of gas to 

be vented, where venting will occur, the potential for accumulation of the released gas, the implications 

to public safety, the application of gas detection and alarms, the availability of fire protection, the extent 

of any hazardous areas generated, and the required equipment. The Australian government 

recommends systems containing more than 150 grams of refrigerant should be recovered. 

Table 2 describes Australian Standards 1596 – 2002 and 1677.2 – 1998, which provide additional safety 

guidelines for the handling of hydrocarbon refrigerants. Specific standards for the recovery or disposal 

of refrigerants were not available.

Table 2: Summary of Regulations and Standards for Recovery and Disposal of Hydrocarbon 

Refrigerants in Australia

Regulation/Standard Title Description Source

Australian Standard 

1596 – 2002

LP Gas Storage and 

Handling

 Establishes safety guidelines for 

storage and handling of liquefied 

petroleum gas products, which 

include hydrocarbon refrigerants.

Hychill 2010

Australian Standard 

1677.2 – 1998

Refrigerating Systems –

Safety Requirements for 

Fixed Applications

 Includes safety procedures for all 

refrigerants, including hydrocarbons.

Hychill 2010

Best Practices for Hydrocarbon Refrigerant Recovery and Disposal

The AIRAH, and the Institute of Refrigeration, Heating and Air Conditioning Engineers New Zealand 

(IRHACE) prepared the “Refrigerant Handling Code of Practice - Part 1 and 2” to demonstrate best 

practices for handling refrigerants in self-contained refrigeration equipment (Part 1) and other systems 

(Part 2). AIRAH and IRHACE recommend proper care be taken to recover flammable refrigerants, and 
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recovery should only be performed by trained personnel using equipment designed for recovering 

flammable refrigerant (AIRAH and IRHACE 2007).

The AIRAH recommended the following procedures for recovery of flammable refrigerants in the 

“Flammable Refrigerants Safety Guide”:

 The machine used for refrigerant recovery must be suitable for use with flammable refrigerants.

It should not have any potential sources of ignition; the requirements are the same as those for 

a refrigerating system.

 The recovery cylinder must be suitable for the refrigerant used, specifically, in terms of the 

pressure rating and the compatibility of valve seals, etc., and with a Class 2.1 label (diamond).

 Refrigerants of different safety group classifications (e.g. A1, A2, and A3) must not be mixed in 

recovery cylinders. 

 Container(s) must be carefully weighed during the transfer of the refrigerant and the 

permissible fill weight of refrigerant in the container at a reference temperature of 45°C must 

not be exceeded.

 All containers are required to be marked with a tare weight and some may have an indication of 

the weight of refrigerant that can safely be contained. If there is any doubt, the weight of the 

refrigerant which can be contained should be checked. Reference should be made to cylinder 

standards such as AS/NZS 1596, AS 4332 and NZS 5807.

 Because odorant could be lost in the recovered refrigerant due to odorant fade, recovered 

refrigerant must not be transported in enclosed vehicles, nor stored in an enclosed space, and 

not be used for charging systems unless it is re-odorized (AIRAH 2013).

In addition, Heatcraft, an Australian refrigerant recovery equipment manufacturer, published a “Guide 

to Refrigerant Recovery Equipment”, in which Heatcraft recommends various best practices to ensure 

worker safety during refrigerant recovery, including hydrocarbons. Heatcraft notes there are three 

common methods for recovery; Vapor Recovery, Liquid Recovery & Push-Pull Recovery. Heatcraft 

recommends during such methods, workers should look after recovery equipment with the use of filter 

driers, particulate filters, or acid core driers, and always monitor the recovery cylinder weight, pump 

inlet pressure and certainly pump outlet pressures (Heatcraft 2014).

Furthermore, the following best practices for venting are included in the “Flammable Refrigerant Safety 

Guide”: 

 Venting to inside a building is not permissible under any circumstances.

 Venting must not be to a public area, or where people are unaware of the procedure taking 

place.

 The hose must be of sufficient length such that it will extend to at least 3m beyond the outside 

of the building.

 The venting should only take place on the certainty that the refrigerant will not get blown back 

into any adjacent buildings, and that it will not migrate to a location below ground-level.

 The hose is made of material that is compatible for use with the refrigerants and oil.

 A device is used to raise the hose discharge at least 1m above ground level and so that the 

discharge is pointed in an upwards direction (to assist with dilution).

 Ideally, there should be a type of rose on the end of the hose so that the vented refrigerant can 

discharge in different directions, with fairly small outlet orifices (to assist with dilution).

 There must be no sources of ignition near the hose discharge.
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 Flammable gas warning sign must be positioned close to the hose discharge. (AIRAH 2013)

2.1.4 Japan

Natural refrigerants, including hydrocarbons, are proposed as substitutes for the phase out of ozonedepleting substances in Japan. According to Underwriter Laboratories, isobutane (R600a) was adopted 

as a refrigerant in Japanese appliances long ago, specifically in household refrigerators and freezers (UL 

2011). Furthermore, Japan has recently encouraged investment in natural refrigerants. In 2014, 50 

million U.S.D. were allocated to support the adoption of natural refrigerants in refrigerated warehouses, 

convenience stores, and supermarkets (Shecco 2014).

Although hydrocarbon refrigerants have been used in various applications in Japan, prominent 

organizations, such as the Japan Refrigeration and Air Conditioning Industry Association (JRAIA), plan to 

further evaluate the risk of adopting flammable refrigerants in accordance with the Japanese Ministry of 

Economy, Trade, and Industry (METI) (JRAIA and JBCE 2014).

Summary of Hydrocarbon Refrigerant Recovery and Disposal Requirements

Japan’s 3R Policies, “Reduce, Reuse, Recycle” are designed to promote sustainable practices through 

various recycling policies and guidelines. The 3R Policies include the Home Appliance Recycling Law, the 

Automobile Recycling Law, and the Fluorocarbons Recovery and Destruction Law (UNEP Undated). The 

Home Appliance Recycling Law of 2001 defines a collection and recycling program, in which home 

appliance manufacturers are responsible for recycling appliances (UNEP 2008). Although the 3R policies 

only extend to fluorocarbons, they describe the widely adopted protocol for the home appliance 

recycling industry in Japan. Under the Home Appliance Recycling Law, the recovery of refrigerants is the 

responsibility of the manufacturer, not the recycling facility. 

In addition to the 3R policies, industry standards govern the recovery of refrigerant in Japan (UNEP 

2008). Several industry standards for appliances and the use of flammable refrigerants, including 

hydrocarbons, are listed in Table 3 below.

Table 3: Summary of Regulations and Standards for Recovery and Disposal of Hydrocarbon 

Refrigerants in Japan

Regulation/Standard Title Description Source

Electrical Appliances and Material Safety Act  Regulates manufacturing, import, and sales of 

electrical appliances.

AHRI 2010

High Pressure Gas Safety Act

 Regulates the handling and consumption of highpressure gases in a stationary setting.

 Requires mandatory safety training for employees 

AHRI 2010

Fire & Disaster Management Act (FDMA)  Regulates general handling of flammable 

substances.

AHRI 2010

Japanese Industrial 

Standard (JIS) B8612

Commercial 

Refrigeration 

Cabinets

 A safety standard developed by the Japanese 

Industrial Standards Committee (JISC) for 

commercial refrigeration cabinets.

AHRI 2010

Japanese Industrial 

Standard (JIS) B8620

Safety Code for 

Small Refrigerating 

Equipment

 A safety standard developed by the JISC that 

specifies construction of parts subjected to 

refrigerant pressure to ensure the safety of small 

refrigerating equipment that use a compressor.

AHRI 2010
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Regulation/Standard Title Description Source

Japanese Industrial 

Standard (JIS) B8240

Construction of 

Pressure Vessels for 

Refrigeration

 A safety standard developed by the JISC for 

refrigeration equipment that uses refrigerant with 

a boiling point lower than -150°C.

AHRI 2010

Best Practices for Hydrocarbon Refrigerant Recovery and Disposal

Best Practices for hydrocarbon refrigerant recovery and disposal are not widely available for the 

Japanese industry. The Japan Refrigeration and Air Conditioning Industries Association (JRAIA) and the 

Japanese Business Council in Europe (JBCE) note preventing leaks or releases of hydrocarbons is difficult, 

and recovery for hydrocarbons requires significant manipulations such as pipe connections and 

disconnections (JRAIA and JBCE 2014). However, venting of hydrocarbon refrigerants is allowed, as the 

Government of Japan only prohibits venting of fluorocarbon refrigerants.

The President of JRAIA, Tetsuji Okada, acknowledges the lack of training for natural refrigerants, and 

believes this absence is a barrier to the widespread adoption of natural refrigerants (R744 2014). In 

response to the lack of training for natural refrigerants, JRAIA and Japan Association of Refrigeration and 

Air Conditioning Contractors (JARAC) plan to offer training courses on various applications for existing 

refrigerants. The courses intend to support the Government of Japan’s initiative to accelerate the 

introduction of natural refrigerants (R744 2014).

2.2 Disposal of Appliances Containing Hydrocarbon Refrigerants without Prior 

Venting or Recovery

An additional concern identified by ISRI with respect to the hydrocarbon refrigerant exemption from the 

venting prohibition is associated with the disposal of appliances containing hydrocarbon refrigerants 

directly into a landfill without proper venting or recovery of the refrigerant. ISRI commented that under 

the best circumstances, recycling facilities would receive appliances for recycling only after complete 

removal or recovery of the refrigerant prior to delivery. ISRI adds that appliances devoid of refrigerant 

upon delivery would be mostly scrap metal and could be safely recycled; however, if recyclers are sent 

appliances still containing hydrocarbon refrigerants, the recycler would be responsible for removal of 

the refrigerant. Furthermore, ISRI is concerned that any disposal of hydrocarbon refrigerants, though 

allowable under EPA’s proposed exemption from the venting restriction, would still be considered 

hazardous waste despite EPA’s ruling that releases of hydrocarbon refrigerants would not pose any 

additional threat to the environment (ISRI 2014). 

Below is a summary of current regulations related to the treatment of flammable waste in the U.S., EU, 

Australia, and Japan; however, the international regulations strictly apply to flammable refrigerants only 

if they are recovered into cylinders, not if they are vented from the appliance at disposal. An assessment 

of the potential risks associated with disposing of appliances containing hydrocarbon refrigerants is also 

presented below. 

United States

In the United States, the four hydrocarbons exempted from the venting prohibition (i.e. propane, 

isobutane, R-441a, and ethane) may be considered to be hazardous waste under certain circumstances

due to their ignitability (as defined under RCRA regulations; see 40 CFR 261.21).

Specifically, household appliances are exempt from hazardous waste regulations under the household 

hazardous waste exemption at 40 CFR 261.4(b)(1). Under RCRA, a “household” includes single and 
11

multiple residences, hotels, bunkhouses, campgrounds, and other places of residence. A waste 

generated at a location other than a household cannot qualify as a household waste. For example, 

waste generated from an appliance (even if physically identical to a “household” appliance) used in a 

commercial capacity would not fall under the household hazardous waste exemption and therefore, 

would be regulated. 

EPA has clarified that the household hazardous waste exemption extends through the entire life cycle of 

the household hazardous waste including collection, management, transportation, treatment, and 

recycling and disposal. Thus, venting of hydrocarbon refrigerants from household appliances that are 

disposed would not be subject to RCRA hazardous waste requirements.

Conversely, disposal of hydrocarbon refrigerants from commercial and industrial appliances that are not 

generated by households would be regulated as hazardous waste (see 40 CFR 261.21) subject to a 

limited exception if the refrigerant is to be recycled. Note that comingling of exempt household waste 

with wastes generated from commercial or industrial activities, even if the wastes are physically 

identical, would render the entire mixture hazardous waste subject to management under the RCRA 

hazardous waste regulations (Virginia Department of Environmental Quality 2008).

If characteristic, used hydrocarbon refrigerants are considered to be hazardous wastes because they are 

classified as spent material (i.e., material that has been used and has become contaminated through use

and hence, must be reclaimed prior to reuse) (40 CFR Section 261.1(c)(1)). In cases where hydrocarbon 

refrigerants are recovered for direct reuse (i.e., no reclamation), these materials would not be classified 

as a solid or hazardous waste (40 CFR 261.2(e)). 

Incidental releases of hydrocarbon refrigerant that occur during the maintenance, service, and repair of 

commercial, industrial, and household appliances would not be subject to RCRA requirements governing 

the disposal of hazardous waste, because inadvertent releases of gaseous hydrocarbons would not 

constitute disposal of the refrigerant charge (see 79 FR 29687).

If ignitable hydrocarbon refrigerants were recovered from any appliance, whether commercial, 

industrial, or residential, but not reused, these hydrocarbons would need be disposed of in accordance 

with appropriate Federal (i.e., RCRA), State, and local regulations. According to the MSDS for propane, 

when it becomes necessary to dispose of these gases, it is preferable to do so as a vapor by burning the 

hydrocarbon in a properly designed flare or incinerator (Amerigas 2004).

European Union

Recycling and disposal of hazardous waste, which includes flammable liquid and gaseous substances, are 

subject to regulations set by the European Commission including the EU Waste Framework Directive 

2008/98/EC and the Landfill Directive 1999/31/EC. According to the EU Waste Framework Directive, the 

regulations surrounding hazardous waste require stricter controls, including labelling, record keeping, 

monitoring, and control obligations for the lifetime of the use of the material (EC 2014c). According to 

the Landfill Directive, flammable waste:

1. may not be accepted in a landfill,

2. must be labeled as such with waste product numbers, and

3. must be stored separately from other waste materials.

The Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) provides detailed 

information on the handling and storage of flammable liquids and gases which are classified as 
12

hazardous waste (University of Reading 2013). DSEAR requires employers to determine whether 

dangerous substances and fire/explosion risks exist in the workplace. Once such risks are assessed,

employers must establish control measures to either remove or mitigate risks by 1) developing 

procedures in the case of an emergency, 2) training personnel, 3) identifying and classifying areas in the 

workplace that contain atmospheres containing fire/explosive atmospheres, and 4) avoiding ignition 

sources in those areas.

In the EU, flammable refrigerants must be disposed of in accordance with regulations set by the

European Commission for hazardous waste, specifically flammable materials. Such regulations include 

stricter controls (labelling, record keeping, monitoring, and workplace controls) and ensure proper 

disposal procedures to increase safety measures for personnel and mitigate any potential fire/explosion 

risks.

Australia

Across all Australian states and territories, liquids and gases are considered hazardous. Due to their 

classification as hazardous waste, flammable refrigerants are not permitted to be landfilled. Flammable 

refrigerants should be disposed of in hazardous waste facilities, which are licensed by state regulators 

and operate on Occupational Health & Safety Standards (Toxfree 2014).

Japan

Under Japan’s Waste Disposal and Public Cleansing Law, flammable waste is considered hazardous. As a 

result, regulations require strict standards and a permit system for facilities that process flammable 

waste (UN Waste Management). Flammable refrigerants are thus required to be disposed or destroyed 

by licensed processors and processing facilities.

Potential Risks of Disposal of Appliances Containing Hydrocarbon Refrigerants without Prior 

Recovery or Venting

Hydrogen refrigerants are potentially considered to be hazardous waste in the U.S., EU, Australia, and 

Japan due to their ignitability/flammability. In the U.S., hydrocarbon refrigerants that are vented or 

otherwise released to the atmosphere in the specified uses are not considered a threat to the 

environment under regulations implementing Section 608 of the Clean Air Act, provided the specified

use conditions are followed; however, for commercial and industrial appliances, it is likely that 

flammable hydrocarbon refrigerant substitutes would be classified as hazardous waste and would need 

to be managed as hazardous waste under the RCRA regulations (40 CFR Parts 261-270). 

Because there is a potential for ignition sources to be present in a landfill or during the mechanical 

processing of the appliance for recycling (e.g., electrical sparks, static electricity) it is important that the 

hydrocarbon refrigerant is removed from the appliance before it is recycled or disposed. If recycling 

facilities receive appliances that are not devoid of refrigerant, only properly trained technicians should 

remove the refrigerant and ensure that it is done in a well-ventilated area away from ignition sources. If 

the recycling facility chooses to recover and dispose of the hydrocarbon refrigerant, rather than vent it, 

they will have to follow the proper DOT and RCRA, state and local regulations regarding proper disposal 

of ignitable waste. These recommendations are consistent with how flammable waste is treated in the 

EU (i.e., flammable waste is not accepted in a landfill) and in Australia and Japan (i.e., flammable waste 

is specially disposed of at a hazardous waste facility). Therefore, it is not anticipated that recyclers will 

be exposed to any additional risk when removing hydrocarbon refrigerants from refrigeration 

equipment prior to recycling, provided only properly trained technicians are handling the equipment 

and following best practices guidelines from relevant standards and regulations. 
13

3 Conclusions and Recommendations

Based on a review of current literature on disposal and recovery practices for appliances containing 

hydrocarbon refrigerants, it is unlikely that exempting hydrocarbons from the venting prohibition will 

result in additional risk for the recycling industry, provided the use restrictions set forth in the proposed 

rule are followed. These use restrictions set forth in EPA’s proposed rule (e.g., charge restrictions, 

labeling, color coding) and recommendations for specific training related to flammable refrigerants are 

consistent with the best practices for recovery and disposal established for the EU, Australia, and Japan. 

In addition, the restrictions and best practices for venting of hydrocarbon refrigerants in Australia are 

consistent with EPA’s use recommendations for safe handling and venting of hydrocarbon refrigerants in 

the proposed rule (e.g., ventilation, minimizing presence of potential ignition sources). 

In addition, it is not anticipated that the recycling industry will experience additional risk if appliances 

containing hydrocarbon refrigerants are sent to recycling facilities prior to being properly vented. 

Recycling facilities should vent or otherwise remove the refrigerant before any mechanical processing of 

the appliance (e.g., shredders, choppers, magnets), due to the potential presence of ignition sources. 

The ignitable refrigerant that is removed would not be considered hazardous waste if it meets the 

household waste exemption under RCRA. However, for commercial and industrial appliances, it is likely 

that ignitable hydrocarbon refrigerant substitutes would be classified as hazardous waste and would 

need to be managed as hazardous waste under the RCRA regulations (40 CFR Parts 261-270). 

Provided that proper use restrictions for refrigeration equipment containing hydrocarbon refrigerants 

are adhered to and that the recommendations for proper engineering controls and PPE in the MSDS and 

other relevant regulations and standards (e.g., OSHA, UL) are followed, additional risks to the recycling 

industry from the exemption of certain hydrocarbon refrigerants from the venting prohibition is not 

anticipated to result in any additional risk to the recycling industry. 
14

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