The Impact of EPA’s Proposed Refrigerant Regulations

Content sponsored by: Structural Concepts

As part of the President’s Climate Action Plan, the Environmental Protection Agency (EPA) has recently increased its push to phase out HFC refrigerants, namely R404a, by Jan. 1, 2016. This proposed legislation will have a significant impact on all commercial refrigeration equipment manufacturers and operators who use this equipment.

Reach in refrigerator unitDespite pending EPA requirements, it is not feasible for all commercial refrigeration equipment to utilize propane or CO2 safely.

“The EPA received thousands of requested comments last October on the proposed rule, and the majority of concerns were about the timeline to comply,” said Karim Amrane, senior vice president, Regulatory & International Policy, of the Air-Conditioning, Heating, and Refrigeration Institute (AHRI), Arlington, VA.

This would not only negatively impact equipment manufacturers, more than a million restaurants and other small businesses that rely on equipment affected by the proposed rule, but many in the industry have raised serious concerns about costs and safety.

Hundreds of manufacturers have warned of the near-impossibility of meeting the proposed deadlines as well as the high costs and potential risks of using alternative compounds, many of which are flammable.

The legislation proposes a move to either propane or CO2 as substitutes for refrigerant-based systems because of the lower global warming impact these alternatives have on the environment.

Unfortunately, it is not feasible for all commercial refrigeration equipment to operate safely using propane or CO2. Because propane is flammable, its use is prohibited by many building codes. Also, CO2 is not supported by refrigeration component manufacturers for self-contained condensing units.

Although limited reach-in refrigerators and other small refrigeration equipment that can operate with a propane charge less than 150 grams will operate with a propane self-contained condensing unit, propane will not work with many other types of equipment like open front grab and go refrigerated displays due to the size of the condensing unit required. If the 150 gram limit is increased to accommodate a wider spread of equipment sizes and styles, public safety would most likely be called into question.

In addition, the targeted refrigerants don’t comply with Department of Energy efficiency standards for refrigeration equipment. Among manufacturers’ concerns with the proposed regulations is that EPA’s forced switch to unproven alternatives may hamper compliance with DOE standards. This could lead to increased energy use and related emissions, making the rule environmentally counterproductive in the long run.

“The climate change focus shouldn’t just be on the type of refrigerant, but also on its life cycle climate performance, which accounts for direct emission and energy consumption,” said Amrane.

Viktor Anderson, Structural Concepts’ chief engineer, recently testified before the U.S. House Committee on Small Business on behalf of AHRI’s 315 members regarding the undue burdens faced by small businesses with the proposed regulations. He expressed the need for regulatory certainty so that companies can comply fully with regulations while making the investments necessary to grow their businesses and create new jobs.

“This proposed regulation doesn’t seem to have been well thought out in terms of how it impacts our industry and small businesses,” said Charlie Souhrada, director, member services, for the North American Association of Food Equipment Manufacturers, Chicago.

To comply with the new regulations, equipment manufacturers would need time to  research refrigerant options to analyze what’s best for their equipment and assess the risks; analyze current manufacturing facilities to see if the new refrigerant can be incorporated; figure out how to update current refrigeration systems; work with refrigerant suppliers and other vendors to source materials; test new units to see how they perform; completely update production processes and facilities; build the new equipment; test these units; educate customers and gain their buy in for this equipment; phase out or switch production lines, and possibly operate redundant lines; manage trapped inventory; and train field technicians to install, repair and maintain the new units.

“To accomplish all this, the EPA should provide at least a 10-year time frame for the conversion,” said Souhrada.