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Another Contentious Code Hearing on A2L Flammable Refrigerants for Residential Use

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In past blogs and articles, I’ve reported on hotly debated issues related to mechanical code proposals allowing residential use of Group A2L “mildly flammable” refrigerants. This debate has raged during the International Code Council’s (ICC) current code change cycle for the 2021 editions of the International Mechanical Code (IMC) and International Fire Code (IFC). Proposals to add such coverage to those codes have been rejected over the past 2 years partly in response to opposition from several equipment and refrigerant manufacturers, fire officials and ACCA. ACCA has testified that its contractor training programs for handling, installing and maintaining A2L residential HVAC systems need to be completed and implemented, but that we are still waiting for the applicable product and installation standards to be completed and published. ACCA’s goal is to provide information and training to our members to ensure safety for contractors and customers alike. Recently national and state fire official organizations have become aware of the planned use of this refrigerant in residences and have expressed their desire to become part of the dialogue to address their own fire and life safety concerns.

The Latest Round in the Code Arena

On Wednesday, October 23, 2019, I attended the 2019 ICC public comment hearings representing ACCA. One item contained proposed standards reference updates in the Administrative Section for the 2021 edition of the International Residential Code (IRC). Normally, updating a standard referenced in the code to the latest edition is a fairly benign issue. However, the standard that was being updated was the Underwriters Laboratories (UL) product safety standard for “household” air conditioners and heat pumps, or as we call it “UL 2-40”. The update would be to reference the 2019 edition, which now covers testing and listing residential products using A2L flammable refrigerants. Once again testimony from equipment and refrigerant manufacturers was split on whether such products were ready to reference in the IRC or whether more research and standards development was needed before they are allowed by the 2021 IRC, which is scheduled for publication in the last quarter of 2020.

Having been involved in the codes arena for several decades representing HVAC interests (and now for ACCA), it was unfortunate to see manufacturers battling each other over safety issues in front of a large room full of code officials. At times the debate was contentious and a bit personal. Something like this should be avoided at all cost, as it makes our industry look divided on a safety issue. No matter which side of the issue we’re on, the common denominator is always safety. (I’ll get off my soapbox now.) After all the testimonies a vote was taken by the ICC membership and the proposal to update of the UL standard to the 2019 edition for the 2021 IRC failed. Thus ends (for now) the contentious debate related to code coverage for A2L residential systems. ACCA’s only concern with this topic was always focused on getting the information needed to ensure that our training programs for A2L refrigerants in residential applications keep our members and their customers well informed and safe. Although UL Standard 2-40 – 2019 is pending publication in the near future, a proposed safety standard for HVAC systems in residential applications is still under development by a committee under the American Society of Heating, Refrigeration and Air-Conditioning Engineers (ASHRAE). The proposed standard, ASHRAE 15.2, has yet to go out for public review, etc. ACCA plans to launch a contractor-focused training and certification program as soon as industry standards come into focus.

Lessons Learned?

As with any conflict there should be lessons learned for the future. ACCA is involved on your behalf to ensure that our contractors are prepared to handle the next refrigerant phase-out and the alternative refrigerants that will be involved. It’s all about safety!

David Bixby

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