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

February 11, 2016
Overview of Presentation

 President’s Climate Action Plan and 

Hydrofluorocarbons (HFCs)

 SNAP program actions 

• Recent actions

• Future considerations

Next Steps

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Why are HFCs a Concern? 

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 HFCs are synthetic fluorinated greenhouse gases 

 Use and emissions of HFCs are growing rapidly, because they are 

replacement for ozone-depleting substances 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
Climate Action Plan: HFCs

 President’s Climate Action Plan released June 2013

 Address HFCs 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

 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 high-GWP HFCs, address technical standards, 

and reduce emissions from HFC use 

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• 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
Recent SNAP Actions

 Issued two acceptability 

notices adding alternatives

 Includes HFO-1336mzz(Z) 

for high-pressure two-part 

spray foam only

 Published Status Change 

Rule prohibiting certain 

HFCs in certain end-uses

 Did not include rigid PU 

spray foam

 HFC Emissions Reductions: 

54-64 MMTCO2eq in 2025

Near term changes can provide 

both near and long term 

benefits

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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 has developed proposed rule, currently under interagency 

review:

 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

 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 

 Publish and take comment on proposed SNAP 

Rule to include alternatives that are:

 Acceptable with use conditions

 Unacceptable

 Changing status 
Thank you!

Contact Information:

Margaret Sheppard, SNAP Team Lead

sheppard.margaret@epa.gov

(202) 343-9163

Chenise Farquharson, SNAP Coordinator

farquharson.chenise@epa.gov

(202) 564-7768