The agency is addressing a potential HCFC allocation system for U.S. producers in the event that the United States reaches its consumption cap. At present, no mechanism is in place to ensure that the United States remains in compliance with the international agreement. Industry s projections to date have been reliable. The EPA is expected to issue a proposed rule by midsummer that may contain a provision for emergency, immediate implementation if the cap level is threatened. Steven H. Bernhardt of du Pont provided an overview of the considerations that are a part of the decision-making process.
Several options are under consideration including allowances of various types.
The agency will take care to not disturb the marketplace. Several considerations need to be accounted for in policy determinations. Also, a labeling program option could have some impact on HCFC use. HCFC Activities in the EU Europe is much less dependent on HCFCs in its air-conditioning and refrigeration systems than is the United States, and therefore, the EU has different perspectives on HCFCs than does the United States. Recent activities in Europe were reported by Thomas Werkema of Elf Atochem.