Capitol Insights: Refrigerant Transition Update, ACCA Opposes Troubling Department of Labor Nomination

Posted on:

August 11, 2023

EPA Updates Refrigerant Policies

The EPA’s Significant New Alternatives Policy (SNAP) program is a regulatory program that evaluates alternatives to ozone-depleting substances (ODSs). As it relates to the phasedown of HFC refrigerants under the AIM Act, the SNAP program has identified a number of alternative refrigerants that have a lower GWP than traditional HFC refrigerants. These alternative refrigerants are being used to replace HFC refrigerants in a variety of applications, including refrigeration, air conditioning, and heat pumps. EPA recently published a finalized SNAP 25 rule and proposed a new SNAP 26 rule, summarized below. 

Most of the affected end uses are very specific in nature, but it’s worth noting that SNAP 25 does allow for the use of R-32 (a mildly flammable A2L refrigerant) for residential and light commercial applications as well as heat pumps. With that said, it only allows for its use in equipment specifically designed for R-32.  

Earlier this year, EPA published a final rule for SNAP 25 

For the end use of residential and light commercial air conditioning and heat pumps (self-contained room air conditioners only), the rule allows for the use of R-32, a mildly flammable A2L refrigerant. This is only acceptable for use in new equipment specifically designed for R-32 

The refrigerants included as acceptable (subject to use conditions) for end uses of centrifugal chillers, positive displacement chillers, industrial process air conditioning using a chiller, and residential dehumidifiers include the following (all of which are mildly flammable A2L refrigerants): R-32, R-1234yf, R-452B, R-454A, R-454B, R-454C.

SNAP 25 allows R-1150 (ethylene) for the end use of very low-temperature refrigeration in equipment designed to reach temperatures lower than -80 degrees C (-122 degrees F). R-1150 is a flammable A3 refrigerant. 

EPA also recently proposed SNAP 26, which covers additional end uses and refrigerants listed below (acceptable subject to use conditions). All refrigerants listed under SNAP 26 are mildly flammable A2Ls unless stated otherwise.  

Commercial Ice Machines: R-32, R-1234yf, R-454A, R-454B, R-454C, R-455A, R-457A, R-516A  

Industrial Process Refrigeration: R-32 (only in chillers), R-1234yf, R-1234ze(E), R-454A (only in chillers, in equipment with a refrigerant charge capacity less than 200 lbs, or in the high-temperature side of a cascade system, for industrial process refrigeration), R-454B (only in chillers), R-454C, R-455A, R-457A, R-516A  

Cold Storage Warehouses: R-1234yf, R-1234ze(E), R-454A (only in equipment with a refrigerant charge capacity less than 200 lbs., or in the high-temperature side of a cascade system), R-454C, R-455A, R-457A, R-516A  

Ice Skating Rinks: R-1234yf, R-1234ze(E), R-454C, R-455A, R-457A, R-516A  

Retail Food Refrigeration – Refrigerated Food Processing and Dispensing Equipment: R-290 (propane, flammable A3 refrigerant)  

Retail Food Refrigeration – Supermarket Systems and Remote Condensing Units: R-1234yf, R1234ze(E), R-454A (only in equipment with a refrigerant charge capacity less than 200 lbs, or in the high-temperature side of a cascade system), R-454C, R-455A, R-457A, R-516A

SNAP 26 would also allow for the use of R-290 (propane, flammable A3 refrigerant) in the end use of self-contained commercial ice machine units and stand-alone retail food refrigeration units. R-290/propane would only be acceptable for use in new units specifically designed for R-290 that comply with UL Standard 60445-2-89 2nd Edition. 

Since SNAP 26 has not yet been finalized, the stipulations listed above are subject to change. 

As mentioned above, these rules allow for the use of A2L (mildly flammable), as well as A3 (flammable) refrigerants for applicable end-use applications.  

Make sure you take the proper steps to prepare yourself, your company, and your employees for A2L and A3 refrigerants: Invest in training, like the course that ACCA offers, that emphasizes ignition prevention and safe handling. Use the right equipment. Follow manufacturer guidelines. Exercise your best judgement. 

If you have questions about SNAP 25 and/or SNAP 26 email govt@acca.org or call 703-575-4477. 

ACCA Raises Concerns over Julie Su’s Nomination for Secretary of Labor

In a recent communication to Chairman Bernie Sanders and Ranking Member Bill Cassidy of the Senate Committee on Health, Education, Labor and Pensions, Barton James, ACCA president & CEO, expressed the association’s opposition to the nomination of Acting Secretary Julie Su as the new head of the Department of Labor. ACCA cited concerns about Su’s track record during her tenure at the California Labor and Workforce Development Agency.

Under Su’s leadership, the California Labor and Workforce Development Agency supported initiatives that posed a threat to the business models that have fostered prosperity for millions of workers and entrepreneurs. Notably, Su played a pivotal role in the passage of A.B. 5, legislation that caused uncertainty among many self-employed individuals regarding their employment status. This resulted in controversy and chaos, with over 200 industries and occupations seeking exemptions from the law.

Another concerning initiative supported by Su was the Fast-Food Accountability and Standards Recovery Act (FAST Act). This legislation granted unelected individuals complete autonomy over the fast-food industry, allowing them to determine wages, establish employment conditions, and create new regulations. The opposition from the state’s Department of Finance, which highlighted increased government costs and a potential fragmented regulatory environment, further underscored the problematic nature of this law.

Additionally, Su oversaw the implementation of California’s emergency COVID-19 workplace safety rule. This rule placed undue liability on employers for circumstances they neither caused nor created. Employers were required to provide weekly testing to all employees and offer unlimited paid leave to any employee who tested positive for the virus, regardless of whether the infection occurred in the workplace or not.

ACCA will continue to fight this nomination on behalf of contractors and small businesses and keep you up-to-date on any changes.