National and Global 

Regulatory Update

February 18, 2016

Drusilla Hufford, Director

Stratospheric Protection Division

U.S. Environmental Protection Agency
 Background on HFCs 

 Climate Action Plan

 Domestic Regulatory Activity

 Significant New Alternatives Policy (SNAP) Program

 Section 608 Refrigerant Management Regulations

 Federal Procurement

 International Activity

 Questions

Overview
UNEP 2011

Why Are HFCs a Concern?

 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

 Without action, U.S. HFC emissions 

were expected to double from current 

levels by 2020, and triple by 2030

 HFCs are used in:

– Air Conditioning (A/C)

– Refrigeration

– Foam Blowing

– Fire Suppression

– Aerosols

– Solvents
Climate Action Plan: HFCs

 Continue international diplomacy

– Lead negotiations under the Montreal Protocol to phase down HFCs

• Global phase-down could reduce more than 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 short-lived 

climate pollutants to: 

• promote climate-friendly alternatives to high-GWP HFCs 

• address technical standards

• reduce emissions from HFC use 

 Address HFCs through domestic actions

– Use existing Clean Air Act authority of 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 safer, more sustainable alternatives

– Apply refrigerant management requirements to HFCs
Private Sector Commitments

 The private sector is also moving forward

 The White House announced private commitments 

at events in October 2015 and September 2014

– Actions would reduce global GHG emissions by 1 million 

metric tons CO2 equivalent by 2025

– Equal to taking 210 million cars off the road for a year

 Companies are going above and beyond the regulations 

through GreenChill and RAD
• Acceptable — those that reduce overall risk to human health & 

environment

• Acceptable with use restrictions — if needed to ensure safe use

• Unacceptable

Evaluates alternatives and lists alternatives as:

• Aerosols; Foams; Refrigeration and A/C; Solvents; Fire Suppression; 

Adhesives, Coatings, Inks, etc.

Sectors include:

• Ozone-Depleting Potential

• Global Warming Potential

• Flammability

• Toxicity

Considers (among other factors): 
 SNAP rules consider individual end uses

 No across the board GWP cutoffs; no “bright lines”

 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 

 We recognize 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

Guiding Principles
 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 MMT CO2eq in 2025

Near-term 

changes can 

provide both nearand long-term 

benefits.

Recent Actions
R-450A (HFC/HFO blend) RefAC

GWP: ~604 compared to HFC-134a: 1430

1233zd(E) heat transfer & flexible PU foams 

GWP <7 compared to alternatives:1070–4000

CO2 refrigerated transport

GWP: 1 compared to alternatives: ~1400–4000 

Methylal foam blowing end uses

GWP <3 compared to alternatives: 725–1430 

HFO-1336mzz(Z) foam blowing end uses

GWP: ~9 compared to alternatives: 725–1430

Powdered Aerosol D fire suppression

GWP <25 compared to alternatives: 0–3500

R-450A (HFC/HFO blend) RefAC

GWP: ~604 compared to HFC-134a: 1430 

R-448A (HFC/HFO blend) RefAC

GWP: 1387 compared to R-404A: 3922

R-513A (HFC/HFO blend) RefAC

GWP: 630 compared to HFC-134a: 1430

R-449A (HFC/HFO blend) RefAC

GWP:1397 compared to R-404A: 3922

HFO-1336mzz(Z) foam blowing end uses

GWP: ~9 compared to HFC-245fa: 1030

MPHE RefAC, solvent cleaning aerosols 

and adhesives/coatings

GWP <3 compared to alternatives: 0–3500

October 2014 July 2015

Acceptability Notices
 Use conditions required to address flammability

 New equipment only

* End uses are in addition to those previously listed by EPA, including those listed in 2011.

Refrigerant GWP

End Use and Application* 

Household 

Refrigerators

Retail

Refrigerator 

Stand-alone

Vending

Very Low-Temp 

Ref.

Heat Transfer

Room AC

Self-contained

Ethane 6 √ √

Isobutane 8 √ √

Propane 3 √ √ √

R-441A (HC blend) <5 √ √ √

HFC-32 675 √

2015 Low-GWP Refrigerants Rule
July 2015 Change of Status Rule

 HFC-125 — January 2016

 HFC-227ea and Blends — July 20, 2016

 HFC-134a — July 20, 2016/January 1, 2018

 HFC-134a in New Light-Duty Systems — MY 2021

 HCFC and HFC-Containing Blends in New LightDuty Systems — MY 2017

 New Supermarket Systems — January 2017

 New Remote Condensing Units — January 2018

 New Vending Machines — January 2019

 New Stand-Alone Units (small medium-temp, large medium-temp, 

low-temp) — January 2019/January 2020

 Retrofitted Retail Food Refrig. Equipment and Vending Machines — July 

20, 2016

 All End Uses, Except Rigid PU Spray Foam — Various 

Dates Between January 2017–January 2021

Motor Vehicle 

Air Conditioning

Aerosols

Retail Food 

Refrigeration and 

Vending Machines

Foams
The EPA is considering a future proposed rule that could include:

 Listing of 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 contemplating changes for equipment categories not addressed in 

July 20th final rule

– End uses based on stakeholder comments and EPA analysis could include:

• Refrigeration and A/C: e.g., chillers, refrigerated food processing and 

dispensing, household refrigerators and freezers, cold storage 

warehouses

• Rigid PU spray foam; fire suppression

September 2015 Stakeholder Meeting
Purpose of Section 608 of Clean Air Act: Reduce emissions of 

ozone-depleting substances (ODS) and substitute refrigerants during 

the maintenance, service, repair and disposal of appliances

Current requirements include:

 Prohibition against knowingly venting ODS and substitute refrigerants

 Service practices (ODS)

 Safe disposal requirements (ODS)

 Leak repair and prevention for larger appliances (ODS)

National Refrigerant 

Management Program
Service

Practice 

Requirements

Technician 

Certification

Refrigerant

Recovery and 

Recycling

Equipment

Refrigerant 

Leaks

Refrigerant

Sales 

Restrictions

Major Recordkeeping 

Requirements

Safe Disposal 

Requirements

Reclamation

Overview of Current

Requirements
Goals of 608 Updates

 Larger Context:

– Climate Action Plan

– Industry petition to create a level playing field for commonly used 

refrigerants

– Continue to reduce emissions of ozone-depleting refrigerants

 Immediate Goals:

– Extend Section 608 requirements to HFCs and other substitutes that 

are not exempt from the venting prohibition (“non-exempt substitutes”) 

– Decrease leaks from large appliances

– Enhance clarity and ease of compliance 

– Strengthen incentives that support careful management of refrigerants
If finalized, the proposal would*:

 Lower applicable leak rates 

– From 35% to 20% commercial and industrial process refrigeration 

– From 15% to 10% for comfort cooling appliances

 If leak rate exceeds applicable leak rate, owner/operator must:

– Conduct leak inspection 

– Repair all identified leaks within 30 days and verify repairs are successful

• Time extensions available

– If leaks cannot be repaired, develop retrofit/retirement plan within 30 days

– Complete appliance retrofit/retirement within one year

 Require periodic leak inspections 

 Establish a two-year leak limit of 75%

 Update recordkeeping requirements

Proposed Changes: Appliance Maintenance 

and Leak Repair

* The proposed requirements on this slide would only be applicable to appliances with 50 or more pounds of refrigerant charge.
 Currently: Technicians working on equipment containing ODS 

refrigerants must be certified and follow servicing practices, such 

as recovering refrigerant from an appliance before servicing

 Proposal extends requirements to apply to HFCs and other 

non-exempt substitutes

 Proposal would also require technicians to keep records of refrigerant 

recovered when disposing of appliances between 5–50 pounds

– Current gap in recordkeeping requirements for equipment between 

5 and 50 pounds

– Recordkeeping includes the amount of refrigerant recovered at disposal 

and the final disposition of refrigerant removed from appliances

Servicing and Disposal Practices
Other Proposed Changes to 608

Extend to 

Substitutes

 All non-exempt refrigerants in small appliances, MVACs 

must be recovered before disposal

 Technicians must be certified to purchase all non-exempt 

substitutes, with exemption for small cans

 Tech certification companies must publish lists of who 

they certify (prospective, with opt-out for privacy)

 Remove reporting requirement for ownership of recovery 

equipment; require use of recovery equipment instead

 Restructure to better group requirements and improve 

language clarity

Simplify, 

Improve

 Update AHRI 700 reclamation standard used

 Update AHRI 740 recovery equipment standard used, 

add safety parameters for flammable refrigerants 

(UL 1963, supplement SB)

Update 

Standards
If finalized as proposed, the rule would result in:

Benefits

Annual GHG 

Reductions

(MMTCO2eq)

Annual ODS 

Reductions

(ODP-weighted MT)

Annual Incremental 

Compliance Cost 

(millions)

7.5 116 $63

 7.5 MMTCO2eq of GHG emissions reductions is the same as taking 

about 1.6 million cars off the road for a year

 We anticipate the regulated community would also experience 

$52 million in cost savings related to reduced purchases of refrigerant
Outreach/Stakeholder Engagement in Rule 

Development Phase

 November 2014 stakeholder meeting, 50+ participants

 More than 50 meetings with industry, environmental 

groups, trade associations, states

Next Steps

 November 9 — Proposed rule published in Federal 

Register (80 FR 69457)

 January 25 — Deadline to submit written comments

 Currently reviewing comments and crafting a final rule

Outreach and Next Steps
HFCs and the Federal Sector

 U.S. government is a large purchaser of 

goods and services 

– Fleet inventory (owned/leased): >635,000 vehicles1

– Buildings (owned/leased): >353,000 buildings2

– Spending on supplies and equipment: nearly 

$191 billion each year

– $222 million on refrigeration and AC3

 In 2010, federal agencies reported HFC 

emissions of nearly 2.2 MMTCO2e4

1 U.S. General Services Administration (GSA) 2013. Index of Data, Federal Fleet Report 

for FY 2013. 2 U.S. GSA 2013. FY 2013 Federal Real Property Profile (FRPP) Summary Data Set. 3 Federal Procurement Data System 2007. Federal Procurement Report FY 2007. 4 Data.gov. 2011. FY2010 Federal Government Greenhouse Gas Inventory by Agency.
Federal Actions Addressing HFCs

 FAR proposed rule (May 11, 2015) addressed HFCs by directing 

the government to procure alternatives to high-GWP HFCs:

– Where feasible, substitute acceptable alternatives as identified 

by SNAP program

– Vendor reporting on use of HFCs (i.e., refrigerants)

– Final rule expected in 2016

 EO 13693 (March 19, 2015) — Planning for Federal 

Sustainability in the Next Decade 

– Direct GHG emissions reduced by at least 

40% by 2025

– Agencies to purchase sustainable products 

and services identified by EPA Programs, 

including alternatives to ODS and high-GWP 

HFCs, where feasible, as identified by SNAP
 Revamped EPA SNAP website

– http://www.epa.gov/snap

– Enhanced user friendliness for federal 

consumers to learn about acceptable 

alternatives

 Federal HFC emissions accounting tool

 Fact sheets

– General: HFCs used by federal agencies

– Sector-specific: HFC uses and alternatives

 Case studies

– Commercial refrigeration system at Lackland

Air Force Base Commissary (San Antonio, TX)

Support Materials Available
International Activities

 Since 2009, the United States, partnering with Canada 

and Mexico, have been pursuing an amendment to phase 

down HFCs under the Montreal Protocol

– Proposals would phase DOWN, not OUT, global HFC production 

and consumption

 In Nov. 2015, parties reached an agreement on the Dubai 

Pathway to work to an amendment in 2016

– An amendment would achieve substantial greenhouse gas reductions 

and could avoid up to 0.5 degrees Celsius of warming by 2100

 Amending the Montreal Protocol would pave the way for all 

countries to transition away from using high-GWP HFCs
Thank You!

DISCLAIMER

Although all statements and information contained herein are believed to be accurate and reliable, they are presented without guarantee or 

warranty of any kind, expressed or implied. Information provided herein does not relieve the user from the responsibility of carrying out its 

own tests and experiments, and the user assumes all risks and liability for use of the information and results obtained. Statements or 

suggestions concerning the use of materials and processes are made without representation or warranty that any such use is free of patent 

infringement and are not recommendations to infringe on any patents. The user should not assume that all toxicity data and safety measures 

are indicated herein or that other measures may not be required.

Questions?
BACKGROUND SLIDES
Proposed Changes: Leak Repair

Action/Topic Current Proposed Change

Appliances affected All ODS appliances with full charge of 

50 lbs or more 

All appliances with full charge of 50 lbs or 

more of non-exempt refrigerants (e.g., 

ODS, HFCs)

Leak rate

Leak rate is 35% for refrigeration 

appliances and 15% for comfort 

cooling

Lower to 20% and 10%, respectively; 

would exempt seasonal variances from 

counting toward leak rate

When leak rate exceeds 

trigger rate

Repair leaks within 30 days such that 

the leak rate is brought below the 

trigger rate

Conduct leak inspection and repair all 

identified leaks within 30 days

How to verify repairs

Initial and follow-up verification tests 

required for IPR and federally owned 

appliances

Initial and follow-up verification test 

required for all affected appliances

If owner/operator fails to 

repair within 30 days Must develop a retrofit/retirement plan Unchanged

Timeline for 

retrofit/retirement plans

Appliance must be retrofitted or retired 

within one year Unchanged
28

Proposed Changes: Repair Extensions

Action/Topic Current Proposed Change

Extensions to 30-day 

repair timeline

If appliance or isolated appliance 

component is mothballed Unchanged

Up to 120 days for an industrial process 

shutdown Unchanged

If federal, state or local regulations prohibit 

timely repairs (IPR only)

Would be extended to all affected 

appliances

If necessary parts are not available (IPR 

only)

Would be extended to all affected 

appliances but capped at 180 days

If appliance is located in an area subject to 

radiological contamination or where the 

shutting down of the appliance will directly 

lead to radiological contamination (federally 

owned only)

Would be extended to all affected 

appliances

Extension request required for all but 

mothballing and IPR shutdown Unchanged
Proposed Changes: Retrofit/Retirement

Action/Topic Current Proposed change

Extensions to the one-year 

retrofit/ retirement timeline

If appliance or isolated appliance component 

is mothballed Unchanged

If federal, state or local regulations prohibit 

timely retrofit (IPR only) Unchanged

If a suitable replacement refrigerant with a

lower ozone depletion potential is unavailable 

(IPR only)

Removed

If a critical component of a custom-built IPR 

appliance is not available on time (IPR only) Largely unchanged

If complications are presented by the federal 

agency appropriations and/or procurement 

process (federally owned only)

Unchanged

If appliance is located in an area subject to 

radiological contamination and creating a safe 

working environment will require more time 

(federally owned only)

Unchanged

Up to 18 months if replacement appliance 

uses an exempt refrigerant
 Establish a two-year leak limit

– Prohibit an appliance from leaking more than 75% of its full charge in two 

consecutive years

– If leak amount exceeded, appliance would need to be retired or mothballed

Example

– Appliance leaks 80% of its full charge between Jan. 1 and Dec. 31, 2018 

– From Jan. 1, 2019 to Dec. 31, 2019, the appliance could not leak more than 

75% of its full charge

– If above 75% in 2019, appliance would need to be retired or mothballed

 Taking comment on:

– Whether to allow for retrofit/retirement plan in lieu of mothballing

– Whether to provide an exception for unavoidable catastrophic leaks

– How the time frame should be set up: two consecutive years? Time periods 

based on calendar year or rolling?

Proposed Changes: Leak Limit
 Require regular leak inspections, unless regularly calibrated 

automatic leak detection equipment installed

– Quarterly for 500+ pound commercial refrigeration and IPR

• Annual inspections allowed if no refrigerant has been added in the past 365 days

– Annually for all other appliances with 50 or more pounds

– Proposing lower and higher charge thresholds for annual vs. quarterly

 Leak inspection would include examination of the refrigerant 

circuit of an appliance using:

– a calibrated leak detection device

– bubble tests

– visual inspection for oil residue

 Proposing to allow leak inspections be conducted by staff 

other than a certified technician

Proposed Changes: Leak Inspections
Proposed Changes: Recordkeeping

 Technicians would provide records for owners/operators that include: 

– (1) the identity and location of the appliance

– (2) the date and type of maintenance, service, repair or disposal performed, 

including the location of repairs and the results of any verification tests or leak 

inspections (if applicable)

– (3) the name and affiliation of the service technician 

– (4) the amount and type of refrigerant added to and/or removed from the 

appliance (if applicable)

– (5) the full charge of the appliance

– (6) the leak rate and the method used to determine the leak rate

 Owners/Operators would keep all service records, leak inspection 

results, full charge calculations, verification test results, 

retrofit/retirement plans, extension requests, etc. 

 EPA encourages electronic recordkeeping systems