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

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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?

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 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 

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 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 

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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

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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 mediumtemp, 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

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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; FormacelTI, 

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

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Next Steps

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 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 

14 September 16, 2015
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Thank You!