SNAP: Change of Status Rule- SNAP: Change of Status Rule-

Overview Briefing

February 11, 2016
Scope of Briefing

U.S. Government Internal & Deliberative

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 SNAP and President’s Climate Action Plan Overview of Next SNAP Change of Status Rule

 Proposed actions and end-uses Other proposed changes

 Outreach Discussion
• Acceptable - those that reduce overall risk to human health & envir

• 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 3
Climate Action Plan: 

Hydrofluorocarbons (HFCs)

U.S. Government Internal & Deliberative

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 Use and emissions of HFCs are growing rapidly because they are 

replacements for ozone-depleting substances (ODS) being phased the Montreal Protocol and there is a global expansion of refrigera

 Climate Action Plan: address HFCs through continuing internatio

domestic actions

 Lead negotiations under the Montreal Protocol to phase down HFCs Use existing Clean Air Act authority of Significant New Alternatives P

Program to approve climate-friendly chemicals, prohibit some uses of m

 SNAP actions since 2014:

 Two SNAP notices and a final rule issued expanding acceptable alternativ SNAP Change of Status Rule-1 published July 2015: HFC emissions avoid

MMTCO2eq in 2025

 SNAP Change of Status Rule-2: Proposed changes of status estimat

emissions of approx. 6-7 MMTCO2eq in 2025 and 10-12 MMTCO2eq 
SNAP Rule Overview

USG Internal & Deliberative

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 What 

 NPRM includes proposed listings:

 Acceptable subject to use conditions Unacceptable; and  Changes of status

 Other proposed changes

 Which sectors are included

 Refrigeration and air conditioning Foam blowing Fire suppression
Acceptable List: Proposed listing

with use ith use conditions conditions

End-Use (New Equipment) Alternatives

to Add

Key Points

Retail Food Refrigeration & Stationary AC

• Commercial ice machines • Water coolers • Very low temperature 

refrigeration equipment 

Propane 

-Much lower GWP than what is in use-Industry indicates better energy efficiency-Flammability can be addressed similar to ot- Propose to exempt from 608 no venting reconsistent with past rules

Motor Vehicle Air Conditioning 

• Medium-duty passenger 

vehicles

• Heavy-duty pickup trucks • Complete heavy-duty vans

HFO1234yf

-HFO-1234yf already acceptable for newly-mpassenger cars and LD trucks-These vehicle types are very similar or iden-Does not affect use of existing credits unde-Exclude incomplete HD vans since MVAC saltered by a secondary manufacturer

Fire Suppression

• Total flooding (engine nacelles 

and APUs on aircraft only)

• Streaming (handheld

extinguishers in aircraft only)

2-BTP -Total flooding limited to unoccupiable spac

-Halon is still primary agent used but ICAO 

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Unacceptable List: Proposed Listing

End-Use Alternative Key P

Refrigeration and Air Conditioning

Residential and light commercial AC: unitary split and heat pumps (retrofit)

Class 3 flammable refrigerants by ASHRAE standards -Extremely flammable 

evidence showing they 

R-22a and similar liquified petroleum equipment designed fogases

Residential and light commercial AC and heat pumps, commercial comfort AC and cold storage warehouses(new)

Propylene and R-443A 

-High photochemical rquality concern-Toxicity concern in eqconsumer uses

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Proposed Status Changes: Status Changes: 

Refrigeration & Air Conditioning

End-Use

Predominantly Used 

Alternatives Proposed for 

Status Change*

Proposed 

Change of 

Status Date Key Poin

Centrifugalchillers HFC-134a

January 1, 2022

-Lower-GWP refrigerants a

HFC/HFO blends, HCFO-Under phaseout of ozone-d(ODS), HCFC-123 will be achillers until 1/1/2020 Positive displacement 

chillers 

HFC-134a, R-407C, and R410A

*Would change status for various HFCs and HFC refrigerant blends with GWPs ranging from about 900 to 9,810

U.S. Government Int

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Proposed Status Changes: Proposed Status Changes: 

Refrigeration & Air Conditioning (Cont.)

End-Use

Predominantly 

Used 

Alternatives 

Proposed for 

Status Change*

Proposed 

Change of 

Status Date Key Points

Refrigerated food processing and dispensing**

R-404A and R410A January 1, 2021 -Lower-GWP refrigerants available: e.g., HFC/HFO blend

Household refrigerators and freezers R-134a January 1, 2021 -Lower-GWP refrigerants available: e.g., HFC/HFO blends and HCsCold storage warehouses 

R-404A and R410A January 1, 2023 -Lower-GWP refrigerants available: e.g., H

blends, HFO/HFC blends, ammonia 

*Would change status for various HFCs and HFC refrigerant blends with GWPs ranging from about 900 to 4,000

**Separate end-use category within retail food refrigeration end-use

U.S. Government Int

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Proposed Status Changes: Foams

End-Use

Predominantly Used 

Alternatives 

Proposed for Status 

Change*

Proposed 

Change of 

Status Date

Key P

Rigid Polyurethane(PU)

spray foam

Onecomponent foam sealants

HFC-134a, HFC-245fa

January 1, 2020 -Lower GWP alternati

both flammable (e.g., e

flammable (e.g., HFO--Since July rule, severaannounced transitions foam and one company 

-Proposal allows more 

pressure to overcome t

Highpressure twocomponent January 1, 2020**

Low-pressure 

twocomponent January 1, 2021**

Flexible PU Methylene chloride 30 days after publication -Due to its relatively hi

-Hazardous Air Pollutaprohibit use in flexible manufacturing facilitie-Change of status dates polyolefin aligned with 

Integral skin PU Methylene chloride January 1, 2017Polyolefin Methylene chloride January 1, 2020*Would change status for various HFCs and HFC blends with GWPs about 740-1,430**Narrowed use limit for military/space/aeronautics until January 1, 2022

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End-Use Alternative

Proposed 

Change of 

Status Date

Key Poin

Total Flooding PFCs (C3F8 and C4F10) One year after publication

-Based on high-GWP (8,830-8atmospheric lifetimes (2,600 y-Not aware of any current uses-Range of acceptable alternativ

Requesting comment only

SF6, HFC-23, HFC-125, and HFC-227ea No change proposed -Requesting advance comments an

in order to consider potential futu

Proposed Status Changes: Proposed Status Changes:

Fire Suppression 

U.S. Government Int

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Other Proposed Changes

USG Internal & Deliberative 12 Closed cell foam products

 The unacceptability determination of foam blowing a

would apply to use of closed cell foam products and pthat contain closed cell foam where the products are manufactured on or after the change of status date

 Fire suppression

 Clean up one listing to match actions taken by Notice 

broadened the acceptability listing from only unoccu

to include occupied spaces
Outreach

USG Internal & Deliberative 13• Ongoing individual meetings with industry and • Workshops/Conferences:

• SNAP sector workshops 

• Heavy-duty MVAC (November 2015)• Fire suppression (December 2015)

• Food Cold Chain in Montreal (November 2015)• ASHRAE (January 2016)• 360 Refrigerant Forum (February 2016)• Mobile Air Conditioning Society (February 2016)• Spray Foam (February 2016)
Discussion

USG Internal & Deliberative 14