Margaret Sheppard, Environmental Scientist Significant New Alternatives Policy (SNAP) Program Office of Atmospheric Programs U.S. Environmental Protection Agency 

# EPA Regulation of Foam Blowing Agents

October 7, 2015

# Overview of Presentation  

## President’s Climate Action Plan and Hydrofluorocarbons (HFCs)  

## SNAP program actions • 

## Recently listed alternative foam blowing agents • 

## Recent actions • 

## Future considerations  

## Next Steps 2

# Why are HFCs a Concern?

3 

###  

### HFCs are synthetic fluorinated greenhouse gases (GHGs)  

### Use and emissions of HFCs are growing rapidly, because they are replacement for ozone - depleting substances (ODS) being phased out under the Montreal Protocol  

### Globally , emissions increased by about 8% per year, 2004 to 2008; unchecked, emissions could rise to as much as 20% of total carbon 

### dioxide emissions by 2050  

### In the U.S., HFC emissions expected to triple 2005 - 2030 UNEP 2011

# What Does the President’s Climate Action

Plan Say about HFCs

# ?

4 

###  

### Continue international diplomacy  Lead negotiations under the Montreal Protocol to phase down HFCs  Global phase down could reduce over 90 gigatons of CO2eq by 2050 , equal to roughly two years worth of current global GHG emissions  Work with partners in the Climate and Clean Air Coalition to Reduce ShortLived Climate Pollutants to promote climate -friendly alternatives to highGWP HFCs, address technical standards, and reduce emissions from HFC use 

###  

### Address through domestic actions  Use existing Clean Air Act authority of Significant New Alternatives Policy (SNAP) Program to approve climate -friendly chemicals, prohibit some uses of most harmful 

### • Provide federal leadership by purchasing cleaner alternatives to HFCs whenever feasible and by transitioning to equipment using safe, more sustainable alternatives• Acceptable - those that reduce overall risk to human health & environment • Acceptable with use restrictions - if needed to ensure safe use • Unacceptable 

## Evaluates alternatives & lists alternatives as:

• Aerosols; Foams; Refrigeration and A/C; Solvents; Fire Suppression; Adhesives, Coatings, Inks, etc. 

## Sectors include:

• Ozone Depletion Potential • Global Warming Potential • Flammability • Toxicity 

## Considers: • Local Air Quality • Ecosystem Effects • Occupational & Consumer Health/Safety 5

# Recently Listed Alternative Foam Blowing Agents

6 

###  

## Methylal (dimethoxymethane)  

### ODP = 0, GWP < 3, VOC  

### Flammable, TLV = 1000 ppm  

## Trans- 1 - chloro - 3,3,3 - trifluoroprop - 1 - ene (1233zd(E))  

### ODP < 0.00034, GWP of 1 to 7, VOC exempt  

### Nonflammable, WEEL = 800 ppm  

## HFO - 1336mzz(Z) (cis- 1,1,1,4,4,4 -hexafluorobut- 2 - ene)  

### ODP=0, GWP < 9  

### VOC, petition for VOC exemption submitted to EPA  

### Nonflammable, WEEL = 500 ppm

# Recently Listed Alternative

Foam Blowing Agents

7 End-use Blowing Agent Methylal 1233zd(E) HFO - 1336mzz(Z) Spray √ √ (high-pressure two -part spray foam) Commercial Refrigeration & Sandwich Panels √ √ √ Appliance √ √ √ Slabstock √ √ √ Integral Skin √ √ √ Flexible √ √ √ Polyurethane (PU)/ Polyisocyanurate Boardstock √ √ √

# Recent SNAP Actions  

## Issued two acceptability notices adding alternatives  

## Issued new rule adding five low- GWP flammable refrigerants with use 

## conditions  

## Published Status Change Rule prohibiting certain HFCs in certain end -uses  

## HFC Emissions Reductions: 

## 54- 64 MMTCO2eq in 2025 Near term changes can provide both near and long term benefits

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# Some Key Principles

Guiding Our Thinking  

### SNAP rules will continue to consider individual end - uses  

### No across the board GWP cut offs  

### No prohibition on HFCs as a whole, or in any one sector  

### New HFCs or HFC blends may be listed if risk not greater than other available substitutes  

### Recognition that timing is a critical dimension and that each end use has unique considerations  

### Status change actions will be issued through notice and comment rulemaking 9

# July 2015: Change of Status Rule

• HFC - 125 - January 2016 • HFC - 227ea & blends - July 20, 2016 • HFC - 134a - July 20, 2016/January 1, 2018 Aerosols

• HFC - 134a in New Light- Duty Systems - MY 2021 • HCFC & HFC Containing Blends in New Light- Duty Systems - MY 2017 Motor Vehicle Air Conditioning • New Supermarket Systems - January 2017 • New Remote Condensing Units - January 2018 • New Vending Machines - January 2019 • New Stand - Alone Units (small medium - temp, large medium temp, low- temp) - January 2019/January 2020 • Retrofitted Retail Food Refrig Equipment and Vending Machines - July 20, 2016 Retail Food Refrigeration & Vending Machines

• All End - Uses, Except Rigid PU Spray Foam - Various dates between January 2017 -January 2021 Foams

# Final Changes of Status for Blowing Agents

11 End-Use Unacceptable/Restricted Substitutes Transition Date Spray Polyurethane (PU) N/A N/A Commercial Refrigeration and Sandwich Panels HFC - 134a, HFC - 245fa, HFC - 365mfc & blends thereof; Formacel TI, Formacel Z - 6 January 1, 2020* * Except January 1, 2022 only in certain military, space and aeronautics applications Appliance January 1, 2020* Marine Flotation January 1, 2020* Slabstock January 1, 2019* Integral Skin January 1, 2017* Flexible PU HFC - 134a, HFC - 245fa, HFC - 365mfc & blends thereof January 1, 2017* PU and Polyisocyanurate Boardstock January 1, 2017* All Blends of HCFC - 141b 60 days after final rule published

# Future SNAP Actions  

## EPA considering proposed rule that could include :  

## Listing acceptable alternatives with use conditions  Use conditions would mitigate risks, e.g., flammability, exposure limits 

###  

## Listing of unacceptable alternatives  Where risks cannot be mitigated sufficiently, e.g., flammability, toxicity, air quality impacts, climate 

###  

## Change of listing status from acceptable to unacceptable  EPA considering potentially later transition dates  End-uses based on stakeholder comments, EPA analysis  Refrigeration and A/C: HFCs in chillers, refrigerated food processing and dispensing, household refrigerators/freezers, cold storage warehouse, MVAC  Fire suppression  Foams: HFCs in rigid PU spray foam; various uses of methylene chloride 12

# Next Steps

13 

##  

# Continue to expand SNAP acceptable list  

# Continue to work with stakeholders  

# Develop next SNAP Notice for acceptable listings  

# Develop next SNAP Rule to include alternatives that are:  

### Acceptable with use conditions  

### Unacceptable  

### Changing status

## “Together, we have succeeded in putting the stratospheric ozone layer on the road to recovery by the middle of this century. As a result, up to 2 million cases of skin cancer may be prevented each year, along with even more avoided cases of eye cataracts.” 

## September 16: International Day for the Preservation of the Ozone Layer

UN Secretary - General Ban Ki -moon September 16, 2015 1415 

# Thank You!