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

September 22, 2014

# Overview of Presentation  

## Hydrochlorofluorocarbon (HCFC) Phase Out and 

## Labeling  

## President’s Climate Action Plan and Hydrofluorocarbons  

## Significant New Alternative Policy (SNAP) status change regulation  

## On -going review of alternative foam blowing agents 2

# HCFC Phase Out and Labeling • 

### Jan. 1, 2015 : Use and introduction into interstate commerce prohibited for all HCFCs used in foam blowing • Imported products may still contain HCFCs in cells of blown foam 

### • 

### Jan. 1, 2015 : Products containing or manufactured with HCFCs must be labeled prior to introduction into interstate commerce • Closed cell foam blown with an HCFC is a product “containing” an HCFC • Label needed for U.S. Customs clearance • Wording: “Warning: Contains/Manufactured with [insert name of substance], a substance which harms public health and environment by destroying ozone in the upper atmosphere” • Label may be on the product, on the outer packaging or somewhere else conspicuous where the purchaser can see it • Specific requirements are at 40 CFR 82.100

– 82.124 3

# Why are HFCs a Concern?

4 

###  

### 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

# ?

5 

###  

### 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

# EPA Took Immediate Steps to Developed

New Proposed Rulemakings

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###  

## Sought deeper understanding of the range of alternatives, 

## ongoing transitions, where & why options are limited and more  

## Engaged with stakeholders:  

### Held two large stakeholder meetings to discuss initial thinking  

### Held seven sector - specific workshops  

### Held numerous other meetings with individual stakeholders  

## Evaluated the potential benefits from various options  

## Developed two proposed rules under EPA’s SNAP program:  

### First proposes to expand the list of alternatives  

### Second proposes to find certain HFCs unacceptable for specific uses

# SNAP Program

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###  

## Evaluates substitutes that reduce overall risk to human health & environment in industrial sectors  

### Aerosols, Foams, Refrigeration and A/C, Solvents, Fire Suppression, Adhesives, Coatings, Inks, etc  

## Since 1994 400+ substitutes reviewed considering:  

### Ozone Depletion Potential  

### Global Warming Potential  

### Local Air Quality  

### Ecosystem Effects  

### Flammability  

### Toxicity  

### Occupational & Consumer Health/Safety

.

# Status Change Proposed Rule

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###  

### Proposes certain HFCs unacceptable for specific end - uses starting over the next few years  

### Sectors include: aerosols, foams, motor vehicle air - conditioning and 

### commercial refrigeration  

### Emissions reductions estimated 31 -42 MMTCO 2 

### eq in 2020  

### SNAP principles maintained and include:  

### SNAP rules 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 (e.g., HFC/HFO blends) may be listed if risk not greater than other available substitutes  

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

### Seeking comments on technical challenges such as availability of alternatives, need for changes to manufacturing processes, safety upgrades and the ability to meet the proposed compliance dates

# Proposed Changes to SNAP List

9 Change of Status Rule: End-Use/ Proposed Date Proposed Change Aerosols January 2016  HFC - 134a unacceptable except for some technical and medical aerosols including MDIs  HFC - 125, - 227ea (except MDIs) unacceptable Motor vehicle A/C Model year 2021  HFC - 134a unacceptable Foams January 2017  HFC - 134a and blends thereof unacceptable  HFC - 245fa and HFC - 365mfc and HFC blends unacceptable in all foam blowing end - uses except for spray foam applications Supermarket systems: remote condensing units, new (& retrofits from ODS) January 2016  Certain HFCs unacceptable: HFC - 227ea, R -404A, R -407B, R -421B, R -422A, R -422C, R -422D, R -428A, R -434A, and R - 507A Stand - alone retail food refrigeration , vending machines: new January 2016  Certain HFCs unacceptable: HFC - 134a, R -404A, R -407A, R -407C, R- 507A, other blends Stand - alone retail food refrigeration, vending machines: retrofits from ODS January 2016  Certain HFCs unacceptable: R -404A and R - 507A

# HFC Emissions Reductions

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### Near term changes can provide both near and long term benefits 

### Emissions reductions from proposal estimated 31 -42 MMTCO2eq in 2020

## Focus on Polyurethane (PU) Foam Blowing Agents

11 End-Use Proposed Unacceptable/Restricted Substitutes Proposed Transition Date Spray HFC - 134a, Formacel TI 

### January 1, 2017 (Except January 1, 2022 only in certain military, space and aeronautics applications) Commercial Refrigeration and Sandwich Panels HFC - 134a, HFC - 245fa, HFC 365mfc & blends thereof; Formacel TI, Formacel Z - 6 Appliance Slabstock Integral Skin Flexible PU HFC - 134a, HFC - 245fa, HFC 365mfc & blends thereof Rigid PU and Polyisocyanurate Boardstock All Blends of HCFC - 141b 60 days after final rule published

# Alternative Foam Blowing Agents

under EPA Review

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###  

## EPA currently reviewing both fluorinated and non fluorinated foam blowing agents  

## Some of the end- uses under evaluation:  

### PU spray foam, commercial refrigeration and sandwich panels, appliance, slabstock , integral skin, PU and PIR laminated boardstock , flexible PU, phenolic  

## EPA expects to issue listings of acceptable substitutes both this fall and next year

# Next Steps

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##  

# Develop final regulations  

## Status Change Rule  

### NRPM published August 6  

### Public comment period to close October 20, 2014 

##  

# Continue to consider the SNAP list  

## Additional alternatives under evaluation  

### Notices and proposed rules  

## These rules should be seen as part of a series  

## Continue to engage with stakeholders14 

# Thank You!