Flammable Refrigerants Hotly Debated

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The issue of flammable refrigerants for use in residential HVAC applications has been hotly debated in the recent code development cycle which takes place every 3 years. ACCA has been actively involved in these deliberations and has gone on record to testify that it would be premature to include such coverage for the 2021 editions of the relevant codes. The proposed language that was almost adopted would have added new requirements for direct air-conditioning systems using Group A2L “mildly flammable” refrigerants for human comfort.

Provisions to add A2L refrigerants were sharply debated during the development process of the two code groups; the International Code Council (ICC) and the International Association of Plumbing and Mechanical Officials (IAPMO). During these hearings, ACCA testified that such proposals would be premature based on the issues noted below. ACCA was joined by several HVAC equipment and refrigerant manufacturers, state fire officials, and others. Some of the supporters for quick adoption included the American Society of Heating, Refrigeration, and Air-Conditioning Engineers (ASHRAE), Underwriters Laboratories (UL), and the Air-Conditioning, Heating and Refrigeration Institute (AHRI). ASHRAE and UL are standards organizations, with UL also being a third-party testing agency. Although AHRI supported these proposals, some AHRI member companies were in opposition, thereby creating a split within the industry on this issue. Based on comments and testimony during several public hearings, some of which lasted 2 hours, the code bodies rejected these proposals for their respective 2021 editions.

Industry Standards Under Development
The code proposals contained installation requirements that were based on two industry standards that arestill under development. The first is UL 2-40, the product safety standard for residential heat pumps and air-conditioners. UL 2-40 provides guidance that manufacturers are obligated to meet. The 2019 edition of UL 2-40 has now been completed and is expected to be published by the end of this year. The other standard is the draft ASHRAE Standard 15.2, the residential (safety standard for refrigeration systems which will incorporate some elements specified in UL 2-40-2019). ASHRAE Standard 15.2 is still under development and is expected to be finished in 2020. Since the UL standard is not published yet, there are no equipment manufacturers who have been tested and listed by UL as complying with that standard.

Training & Certification Programs Pending
ACCA is in the process of developing a training program for the safe handling, installation and maintenance of residential equipment that utilizes A2L refrigerants. ACCA will also offer the exam to be used for the future technician certification. The training programs and certification exams must wait until the UL and ASHRAE standards are completed and published. Additionally, ACCA is working with Congress on these issues to ensure federal HFC phasedown legislation address safety and training programs).

Other Loose Ends
Once the above standards are finished there are a few other issues that need to be resolved, including transportation and signage requirements for the flammable refrigerant. It is anticipated that US DOT or US EPA (or both) will specify the provisions for compliance.

Another issue is the new tools and equipment needed to install and service the equipment that uses the new refrigerants. There will need to be special connections and a recovery machine designed specifically for A2L refrigerants. Most standard recovery machines are designed for non-flammable refrigerants. Other instrumentation and sensors unique to such systems will also need to be available.

What’s Next?
The 2021 editions of the ICC and IAPMO codes will be published late in 2020. These editions exclude language that addresses residential systems that use A2L refrigerants. The next code change cycle for both code bodies will commence early 2021, culminating with the publication of the 2024 editions. ACCA will continue its work to promote proper training, safety protocols, and technician certification to support these products as they are introduced to the market. We will also continue our work to ensure appropriate requirements are specified by the codes.

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