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Last Remaining Barriers

Last Remaining Barriers. Kristen Taddonio Chair, Global Barrier Removal Team 9 December 2008. 2008 Choices. Refrigerants: R744 R1234yf Barriers based on: Flammability Acute toxicity Pressure. We’ve Come a Long Way.

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Last Remaining Barriers

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  1. Last Remaining Barriers Kristen Taddonio Chair, Global Barrier Removal Team 9 December 2008

  2. 2008 Choices • Refrigerants: • R744 • R1234yf • Barriers based on: • Flammability • Acute toxicity • Pressure

  3. We’ve Come a Long Way • 2006: Global barrier removal team formed to remove global barriers to alternative refrigerants’ adoption • 2006: US barriers identified at national level and in 18 states • 2006: U.S. Department of Transportation waives pressure requirement for MAC accumulators, enabling R744 solution • 2007: HFC152a Tiger Team releases report confirming secondary loop safety • 2007: Many state barriers removed • 2007: US National Highway Traffic and Safety Administration (NHTSA) confirms EPA SNAP listed alternative refrigerants acceptable under existing rules • 2008: R744 safety tiger team formed • 2008: US EPA SNAP lists HFC-152a as acceptable with use conditions

  4. Remaining Resolvable Regulatory Challenges • R744: • US venting prohibition • EPA SNAP revision proposed and suspended • EU limits on refrigerant in passenger cabin • US State acceptance conditional on safety standards • R1234yf: • Resolve REACH for 1234yf • EPA SNAP review in progress • EU limits on refrigerant in passenger cabin • Legislative vote pending in 7 states that would allow EPA SNAP listed flammable refrigerants

  5. CO2

  6. Refrigerant Venting • The Clean Air Act prohibits venting of all refrigerants, including R744. • As of yet, no company has requested an exemption. • US EPA Stratospheric Protection Division responsible authority.

  7. Significant New Alternatives Program (SNAP) • US EPA Stratospheric Protection Division responsible authority (Drusilla Hufford and Karen Thundiyil) • EPA initiated review of R152a and CO2, and proposed use requirements • R152a final rule issued 2008 • Final rule did not include CO2

  8. EU Limits on Refrigerant in Occupied Space • EU limits refrigerant that can be discharged into occupied space of passenger cabin • Current systems do not meet requirements • 134a • R744 • Several European companies lobbying to change EN 378 to exempt MACS

  9. States Where CO2 Contingent on Safety

  10. R1234yf

  11. EPA Significant New Alternatives Program (SNAP) • SNAP application submitted 2008 • Requires review in EPA office of Toxics • R152a final rule issued 2008 • US EPA Stratospheric Protection Division responsible authority

  12. REACH & EU Limits on Refrigerant in Occupied Space • Does R1234yf met REACH acceptability? • EU limits refrigerant that can be discharged into occupied space of passenger cabin – same challenge as for R744 • Several European companies lobbying to change EN 378 to exempt MACS

  13. States Where Flammability is an Issue

  14. R-1234yf and HFC-152a: Other States

  15. EPA Contacts Barrier Removal Chair Kristen Taddonio taddonio.kristen@epa.gov +1-202-343-9234 Mobile A/C Climate Protection Partnership Stephen O. Andersen, Director Andersen.Stephen@epa.gov + 1-202-343-9069 SNAP Approval Or Refrigerant Venting Karen Thundiyil, Manager Thundiyil.Karen@epa.gov +1-202-343-9464 Drusilla Hufford, Division Director Hufford.Drusilla@epa.gov + 1-202-343-9101

  16. Back – Up Slides

  17. U.S. Department of Transportation Waives Pressure Requirement • “[Air conditioning systems] are an integral component of a motor vehicle and necessary for the operation of the vehicle”… “Based on the information you provided, the air conditioning system…is not subject to the Hazardous Materials Regulation.” –John A. Gale, Chief of Standards Development US Department of Transportation (DoT) Pipeline and Hazardous Materials Safety Administration 11 July 2006

  18. OSHA, EPA, & SAE Cooperation will Satisfy US Health and Safety Requirements • SAE J-Standards in progress: “Recommended practice for servicing CO2, HFC-152a and R-1234yf mobile air conditioning systems” • The SAE Standards will meet Occupational Safety and Health Administration (OSHA) requirements for training, personal protective equipment, safe handling, pressure relief devices, equipment inspection, worker exposure, ventilation, and refrigerant storage • SAE standard are critical to compliance with OSHA Health & Safety Requirements

  19. States that ban toxic refrigerants

  20. CO2 State Barrier Removal • Investigate definitions of toxic in State • When no definition exists, identify state authority responsible for implementing the statute • Inform state authorities of situation, ask if CO2 would be allowed in that state • Provide information on system safety strategies and pending SAE standards

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