Over the past few years, the U.S. Environmental Protection Agency (EPA) has faced challenges in implementing regulations relative to HFC refrigerants. These regulatory issues have caused uncertainty throughout the HVAC (Heating, Ventilation, and Air Conditioning) industry as shifts have been made toward more environmentally friendly refrigerant options. The landscape continues to change as the EPA pushes toward a phase-down of HFC production and usage.
Given the uncertainty at the federal level, states like California took the lead. In 2018, the California Cooling Act went into effect, implementing SNAP 20/21 which prohibited HFC refrigerants containing higher global warming potentials (GWP). Other states followed California, adopting SNAP 20/21 into their own state regulations. Relative to HVAC end uses, SNAP 21 prohibits the use of R-410A and R-134a in chillers as of January 1, 2024.
In December 2020 the federal AIM Act was signed into law, giving the EPA the authority to regulate HFCs, hopefully pulling refrigerant regulation back to the federal level and avoiding the complexity of a state-by-state approach. The AIM Act provides enough time for industries to prepare for the transition from high- to low-GWP equipment without adverse effects.
AIM Act – What is it?
The AIM Act grants the EPA the ability to regulate HFCs, which are commonly used as refrigerants, among other applications. HFCs have been widely used as substitutes for legacy refrigerants such as R-22 that harmed the ozone layer. Under the Clean Air Act, these chemical substances were successfully phased out of new equipment a decade ago. Now the focus is moving away from high GWP refrigerants, which are recognized as a contributor to climate change. Globally, the HFC phase-down has been under consideration for some time and in 2016 the Kigali Amendment phasing down HFC production and consumption was finalized.
The AIM Act aligns with the phase-down limits contained in the Kigali Amendment and restores the EPA’s authority to regulate the consumption and production of HFCs and establish sector-based GWP limits.
AIM Act – How It Will Affect Facilities
Facility managers need to be aware that new equipment purchased after 2024 Chillers/2025 AC will likely contain new lower GWP refrigerants. Many of these are classified as A2L mildly flammable refrigerants, requiring facility managers to be educated on the new safety features built into the system to mitigate flammability concerns.
The question that arises is whether the new refrigerant can be used in older equipment already in use. The answer is that A2L refrigerant is not designed to be utilized in low-GWP equipment that previously used R-410A or other legacy materials. Safety is a primary focus as changes are implemented, making the new regulations and standards vitally important to understand and follow.
There are several options for HFC replacements considered by North American companies, including R-32, R-454B, and others. They are evaluated for efficiency, capacity, and cost among other factors in order to provide the best performance possible.
Older equipment should not be stranded as the phase down is designed to preserve enough refrigerant to service existing systems. R-410A will continue to remain available for those with older systems. However, the benefits of switching to a low-GWP alternative (positive environmental impact, efficient energy solution, etc.) may be strong influencers in the decision to make the transition sooner than later.
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