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

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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 

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Why are HFCs a Concern? 

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 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
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 MMTCO2eq 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

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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

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End-Use Proposed 

Unacceptable/Restricted 

Substitutes

Proposed Transition 

Date

Spray HFC-134a, FormacelTI January 1, 2017 

(Except January 1, 

2022 only in certain 

military, space and 

aeronautics 

applications)

Commercial Refrigeration 

and Sandwich Panels

HFC-134a, HFC-245fa, HFC365mfc & blends thereof; 

FormacelTI, Formacel Z-6

Appliance

Slabstock

Integral Skin

Flexible PU HFC-134a, HFC-245fa, HFC365mfc & 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 nonfluorinated 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 stakeholders 
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Thank You!