Many new alternative refrigerants marketed for use in the motor vehicle and stationary/commercial sectors are being touted by their
manufacturers and distributors. Whether you're a nationwide distribution chain or a one-man service shop, you should take the time to determine how well an alternative will work and whether it may pose any problems for
your customers or liability for you. Consider asking your supplier, whether it is the refrigerant manufacturer or a distributor, the following questions.1. Is the refrigerant on the EPA's SNAP
(Significant New Alternatives Policy) Program list of acceptable substitutes, and therefore legal to use as a substitute for a CFC refrigerant? If so, are there any restrictions on how the refrigerant can be used? EPA's SNAP program determines what risk alternatives to CFC or HCFC refrigerants pose to human health and the environment. EPA evaluates the alternative refrigerant's ozone-depleting potential, global
warming potential, flammability, and toxicity. The SNAP evaluation, however, does not determine whether the alternative will provide adequate performance or will be compatible with the components of an A/C or
refrigeration system. Call the Hotline number listed above for the SNAP fact sheet on alternative refrigerants and for lists of refrigerants accepted under SNAP, or download a version of the current list.
EPA may place conditions or restrictions on how an alternative can be used. For example, using a motor vehicle A/C refrigerant accepted under SNAP as a CFC-12 substitute requires, among other things, the use of a new
label and new fittings unique to the alternative, and the CFC-12 must first be removed from the system. Note that there is no do-it-yourself (DIY) exemption from SNAP requirements. Both service technicians and DIYers
who use alternatives found unacceptable under SNAP or ignore use conditions have violated the Clean Air Act. A fact sheet explains the current status of all refrigerants reviewed so far for motor vehicle air
conditioning. 2. How much will the alternative refrigerant cost? Many manufacturers and distributors of alternative refrigerants may point out how much less expensive their product is
than the refrigerant it is substituting for. Potential purchasers, however, should compare the cost of the product with the cost of other substitutes. For example, if you are considering purchasing a blend refrigerant
that substitutes for CFC-12, consider its cost relative to the cost of HFC-134a, which is generally considerably less expensive than blend refrigerants.3. What does the system manufacturer have to say about this
refrigerant and whether it is compatible with system components? Will using a particular refrigerant void any warranties on the system the refrigerant is used in? Because of the wide range in equipment
types and designs, EPA does not issue retrofit procedures. The best source of information on how a given substitute will perform in a system is the manufacturer of the system and its components. Note that lab data has
indicated that HCFC-22 refrigerant is not compatible with XH-5 or XH-7 desiccant, and that HCFC-22 can also damage NBR nitrile and HNBR rubber hoses and O-rings. If you are considering using a blend refrigerant that
includes HCFC-22 as a major component, then you should ask about these issues before you purchase the refrigerant. In addition to questions about the alternative's performance in a particular end use, you
should determine whether charging a system with a new refrigerant will void any warranty. Many component manufacturers have stated that their warranties will be voided if any refrigerant other than R-12 or R-134a is
charged into the system. 4. What recycling and/or reclamation standards apply to the refrigerant? Can the refrigerant be recycled or reclaimed to those standards? The Clean Air Act
requires that EPA establish standards for the recovery, on-site recycling and off-site reclamation of refrigerants, including alternatives accepted under SNAP. The Agency's standards for recovering and recycling
refrigerants in motor vehicles are generally based on Society of Automotive Engineers (SAE) standards. EPA's standards for reclaiming refrigerants from motor vehicles and from stationary/commercial A/C and refrigeration
systems are generally based on ARI (Air-Conditioning and Refrigeration Institute) standards. If these standards have not been published by EPA for a particular alternative, then they may be under development by EPA, SAE
or ARI. Check to make sure that the refrigerant manufacturer intends to work with these organizations to develop uniform methods for extraction, recycling and reclamation. You can call the Hotline number (800-296-1996)
listed above to determine the status of EPA standards and requirements. 5. What equipment must be used with the alternative refrigerant? Equipment that is used by a facility to service
R-12 or R-134a A/C systems may not be used to charge, recover or recharge a blend refrigerant. Technicians must therefore dedicate newly purchased equipment to that blend. Alternatively, a shop may convert a piece of
R-12 or R-134a equipment for permanent use with the blend refrigerant. For more information on equipment requirements, see the EPA document "Just the Facts for MVACs." 6. Has the alternative
refrigerant been evaluated by ARI (the Air-Conditioning and Refrigeration Institute)? If an alternative is to be reclaimed, will it be reclaimed to ARI's 700 standard? If not, then how will the purity of the reclaimed
alternative refrigerant be assured? ARI, and A/C and refrigeration manufacturers' trade association, develops standards for the industry. ARI's 700 standard specifies acceptable levels of refrigerant
purity for fluorocarbon refrigerants including R-12, R-22, R-134a, R-500, and R-502 and for certain refrigerant blends. The purpose of the 700 standard is to enable users to evaluate and accept or reject refrigerants,
whether virgin, reclaimed or repackaged. Reclamation of these refrigerants in both the motor vehicle and stationary/commercial sectors must follow the 700 standard.
7. Is the alternative refrigerant flammable? Both ASHRAE (the American Society of Heating, Refrigerating and Air-Conditioning Engineers) and EPA evaluate refrigerant flammability. As part of its SNAP
review, EPA requires that a new refrigerant be tested according to the American Society of Testing Materials (ASTM) E-681 testing method. E-681 is used to determine the concentrations in air at which a substance is
flammable, at normal atmospheric pressure. In addition to testing the refrigerant itself, if a blend contains a flammable component, EPA requires leak testing to ensure that the composition does not change and become
flammable. EPA prohibits the use of any flammable CFC-12 substitutes in motor vehicle A/Cs. If a substitute is flammable, EPA requires a comprehensive risk assessment for each proposed end-use. This risk
assessment estimates the likelihood of fire and the potential results if a fire were to occur, in addition to suggesting measures to mitigate this risk. State governments, fire marshals, building code organizations, and
other local authorities may have issued prohibitions or other regulations related to flammable refrigerants. Check with them before buying, selling, or using a flammable refrigerant.
8. Is the refrigerant readily and widely available? If an automotive service technician charges a system with an alternative refrigerant that later becomes unavailable, or that is not available
nationwide, then at the next servicing, the system may have to be retrofitted to another appropriate substitute. The customer may be unwilling to pay for the retrofit, or may be unhappy that his vehicle cannot be
Therese serviced at the facility he chooses. 9. What is my liability if I sell an alternative not yet listed as acceptable by EPA or if I put it in a customer's system? Under EPA
regulations, a refrigerant manufacturer must submit information on a new refrigerant for SNAP review at least 90 days before marketing the product. This 90-day period is required by Section 612 of the Clean Air Act, but
the Act did not prohibit sale and use of that refrigerant after the 90-day period. Thus, if the Agency is still engaged in its review when the 90 days elapses, the product can be sold and used, even though it is not
"EPA acceptable." However, EPA may later determine that the product is unacceptable under SNAP. It makes sense, then, to determine whether SNAP review is complete -- if not, it may be only temporarily legal to
use the alternative refrigerant. If you purchased the refrigerant during the SNAP review, and EPA later determines that it is unacceptable, you may be stuck with a large inventory of refrigerant no one can legally use!
The Clean Air Act only granted EPA the authority to regulate the use of alternative refrigerants, not the sale of them. Even if EPA determines that an alternative is unacceptable, it is still legal to sell
it. However, putting it in a customer's A/C or refrigeration system is considered use, not sale, so a service technician who charges a system with an unacceptable refrigerant may be subject to a $25,000 fine and up to
five years' jail time. 10. Are any alternative refrigerants more environmentally beneficial than others? HFC-134a does not contain chlorine and therefore does not contribute to ozone
depletion, although like other HFCs, it contributes to global warming. HCFC-22 and all other HCFCs contribute to both ozone depletion and global warming. All blend refrigerants listed as acceptable for motor vehicle use
contain HCFCs. R-134a Rationing? According to a recent article in the March 15, 1999, issue of The NEWS magazine, there may not be enough HFC-134a (R-134a) to go around.Jay Kestenbaum
of Refron, a Long Island refrigerant distributor, believes that this summer mobile A/C technicians may experience a shortage in R-134a. Early warnings from the European market have begun, where supplies have tightened
severely, according to Kestenbaum. This situation could easily spill over into the US mobile A/C market, where demand is very strong. An estimated 50 million cars will need supplies of R-134a and R-12 to
keep their cooling systems operating between now and 2006, according to a federal study. Another indicator of this situation is the recent price hike of R-134a. With an anticipated shortage, the price has gone up by 50%
over last year's prices. The shortage can be traced back to a problem with the supply of precursor chemicals like trichlorethylene in the manufacture of the refrigerant, said Kestenbaum. HVAC markets may
not experience the same shortage as the MVAC market where many chiller manufacturers have contracts with R-134a suppliers. Composition of Refrigerant Blends & The Neutronics Fingerprint Chart More Information About Alternative Refrigerants The "ACTUAL" table below shows the
percentages of gases within refrigerant blends which have been found "acceptable for use" as a substitute for CFC-12 (R-12). The "FINGERPRINT" chart is a list of possible refrigerant readings you may
see when using the Neutronics Refrigerant Diagnostic Tool. The ACTUAL composition of Alternative Refrigerant Blends
Trade Name |
ASHRAE Number |
HCFCs 22 124 142b |
HFCs 134a 152a 227ea |
butane HCs isobutane R-600 R-600a |
MP-39 |
401A |
53% 34% |
13% |
|
MP-66 |
401B |
61% 28% |
11% |
|
GHG |
406A |
55% 41% |
|
4% |
FX-56 |
409A |
60% 25% 15% |
|
|
FRIGC |
FR-12 |
39% |
59% |
2% |
Free Zone (2% is lubricant) |
19% |
79% |
|
GHG-HP |
|
65% 31% |
|
4% |
Hot Shot |
414B |
50% 39% 9.5% |
|
1.5% |
GHG-X4 |
414A |
51% 28.5% 16.5% |
|
4% |
Freeze 12 |
|
20% |
80% |
|
GHG-X5 |
|
41% 15% |
40% |
4% |
The "FINGERPRINT"of select Alternative Refrigerant Blends
Trade Name |
ASHRAE Number |
HCFCs 22 124 142b |
HFCs 134a 152a 227ea |
CFCs R-12 |
HCs |
FRIGC FR-12 |
|
3% |
69% |
26% |
2% |
Free Zone (2% is lubricant) |
|
90% |
10% |
|
Hot Shot |
414B |
56% |
7% |
34% |
3% |
GHG-X4 |
414A |
57% |
10% |
29% |
4% |
Freeze 12 |
|
|
87% |
10% |
|
| |
|
|
|
|
|
Where to Send Contaminated Refrigerant Getting rid of your contaminated refrigerant can be a confusing chore for most shops. A small hand-full of
companies make this chore easy and, in some cases, profitable. These companies will accept contaminated
refrigerant from you - and in some cases - will actually pay you for the shipping or for the volume of refrigerant you
have. Typically a shop can expect to pay between $1 and $4 per pound for disposal, which, over the course of a
year, can equal hundreds of dollars for a small shop. Avoid these charges by contacting one of the companies listed below. They make EPA compliance easier. RemTec International 6150 Merger Dr. Holland, OH 43528 888-873-6832 Full Circle (with 11 Regional Offices) 121 S. Norwood Dr. Hurst, TX 76053 817-282-0022 (x220) Refrigerant Reclaim 805 Tile Dr. Red Wing, MN 55066 860-651-6114 or 800-235-0705 EPA List of Reclaimers 800-296-1996 Ozone 101: The Problem of CFCs
So you've learned how to handle R-12, you know how to retrofit an A/C system, and you even know about the "SNAP" Rules, but why? Why can't we still produce R-12? Why can't we vent it? What's the big deal? Well, for
those of you who are asking these questions, here's your chance to get some quick answers and to understand the impact of chlorofluorocarbons, CFCs, on our world.
Since the early 1970s scientists have been watching a hole in the ozone layer grow. And because of this ozone
problem, over 150 countries agreed to stop the production of CFCs. This agreement, signed in the late 1980s, is
known as the Montreal Protocol. In 1990, President Bush signed the Clean Air Act which empowered the EPA to set forth and enforce rules and regulations regarding CFCs.
CFCs destroy the ozone layer. The ozone layer (in the stratosphere, between 10 – 30 miles above earth's surface)
keeps 95 – 99% of the sun's ultraviolet radiation (UV) from striking the earth. The ozone layer is made up of O3
molecules (three oxygen molecules bound together). When one CFC (R-12) molecule is struck by sunlight, it releases
a chlorine atom. The chlorine atom and ozone molecules set off a chain reaction. Once the reaction is complete, that one chlorine atom has just destroyed 100,000 molecules of ozone from our atmosphere.
When the protective ozone is destroyed, UV rays become stronger and more harmful to plants and animals. Increased exposure to UV radiation is partially responsible for the alarming increase in skin cancer – the rate of
which is tenfold higher today than it was in the 1950s. And according to the National Academy of Sciences, for each
1 percent decline in ozone levels, humans will suffer as much as 2 to 3 percent increase in the incidence of certain skin cancers. Remember, no refrigerant can be vented! It's against the law! 609 Certification, SNAP & The EPA— What do they mean? If you've been performing A/C service for over 5 years, chances are you haven't heard of a set of rules for handling
refrigerants called the "SNAP PROGRAM" (Significant New Alternatives Policy). The EPA has mandated that you follow the rules of this program completely.
According to the EPAs "How to Survive a EPA Clean Air Act Title VI Refrigerant Regulations Compliance Inspection" document, if you break any one of these rules and are convicted, here's what you can expect:
1. Civil penalties of $27,500 per day of violation. 2. Criminal penalties up to 5 years of federal imprisonment for knowing or willful violations, and 2 years
imprisonment for submission of false records.
How does the EPA catch you? The EPA routinely conducts surprise or unannounced inspections to verify
compliance requirements. In addition, EPA pays up to $10,000 reward to individuals reporting violations that result in successful court cases and/or convictions under "Citizen Award Program."
What a technician must know:
1. Topping off like A/C systems with the same refrigerant already installed is perfectly legal. However, you
cannot top off any A/C system refrigerant with another A/C refrigerant. It is illegal to mix any refrigerants. 2. Only SNAP "Acceptable subject to use conditions" refrigerants can be used in cars. 3. Unique fittings and labels are required. The "subject to use conditions" wording in the EPA regulations
refers to the mandatory use of separate and unique fittings and labels for each and every new SNAP acceptable refrigerant. As part of the EPA "acceptable for use" criteria, the refrigerant manufacturers must
prove they have created unique fittings and labels to support the sale and use of their product. 4. No refrigerant can be vented! Even R-134a. The EPA is proposing that the only refrigerant that can be
vented is 100% hydrocarbons. If a system is identified as having 100% hydrocarbons, the system could legally be vented. Recovery in this situation would pose too much of a human hazard. For more information
see Federal Register/Vol. 63, No. 112. 5. "Recycling" of blends is now legal, however transfer of ownership is not (except in fleets). And the
technician must use dedicated recycling equipment for each refrigerant used in the shop, and it must meet the new UL (Underwriters Laboratories) Standard. 6. Hydrocarbons are illegal to use in cars!
Additionally, Section 609 Certification covers new blends, no new certification is required. However if you were
certified 5+ years ago, you may not know or remember these rules.
What else should you be doing to protect yourself from an EPA audit? Records should be maintained on refrigerant
handling from point of purchase through final usage or disposal. This includes maintaining records for ALL service
work performed on vehicles regardless of size, quantity or refrigerant. You should maintain information on file for three years. To learn more, contact EPA at www.EPA.gov. It's Now O.K. to Recycle Blends
Contaminated refrigerants – it's a problem that will only get worse. For those who choose to deal with this potential
headache, there are rewards: Profits. Turning the handling of contaminated refrigerant into its own profit center in your shop could be the raise you've been looking for. But first you'll need to know few things…
- Identify the refrigerant. Use a refrigerant identifier with 98%+ accuracy.
- Recover the contaminated refrigerant. Dedicate an R-12 recovery-only machine, or buy a special machine for this purpose.
- Store the refrigerant in an 'approved' cylinder, a standard DOT-certified grey w/yellow top tank.
- Dispose of the contaminated refrigerant.
Identify the Refrigerant
Checking refrigerant pressures does not help you recognize refrigerants, especially if the refrigerant is contaminated
or is a brand that is unfamiliar with you. Using a refrigerant identifier can help pinpoint many refrigerant
identification problems, and EPA strongly recommends (but does not require) that techs obtain this equipment. A
unit that can help you identify the chemical composition of the refrigerant more specifically can be an important
diagnostic tool, so that the extra cost may be well worth it. Finally, using this tool may build your customer's
confidence in your diagnostic abilities. Be certain when purchasing your identifier that it meets the SAEJ1771 standard, which is an indication that the unit accurately identifies refrigerants.
Recover the Contaminated Refrigerant
As a first step, the contaminated or unfamiliar refrigerant must be recovered. EPA prohibits venting any automotive
refrigerants (including unacceptable refrigerants) no matter what combination of chemicals is in the refrigerant. The
best way today that a tech can recover contaminated or unfamiliar refrigerant is to dedicate a recover-only unit to
anything that is not pure R-12 or pure R-134a. Some equipment manufacturers are also marketing new types of recover only stations specifically designed to remove these refrigerants. If the refrigerant you extract into a recovery unit contains a high level of flammable substances such as propane or
butane, a fire hazard may result if the refrigerant comes into contact with an ignition source within the equipment.
Whether you are purchasing a new piece of equipment to handle your contaminated and unfamiliar refrigerants, or
you are converting a piece of existing equipment for this purpose, make sure you talk to your sales representative about what features have been incorporated into the equipment to guard against risks of ignition.
Store the refrigerant in an approved cylinderRefrigerant should be recovered into the standard DOT-certified, gray-with-yellow-top recovery tank, and if the tank
is not equipped with a float valve (which serves as overfill protection), make sure it never gets filled beyond 60% of its gross weighted capacity, as specified in the SAE J1989 and J2211 standards.
Dispose of the contaminated refrigerant
Once the refrigerant has been recovered, if you can't recycle it, what do you do with it? The answer, naturally, is that
it depends. If the refrigerant in your "junk" tank contains significant amounts of flammable substances, it may be considered hazardous and you should make sure you follow any local ordinances that govern the storage of
combustible mixtures. In addition, if your shop generates over 100 kilograms (220 pounds) of hazardous wastes per
month (including used coolant, paint, rust, removers, solvents, degreasers, and battery acids), then your shop must
meet certain storage and transportation requirements under the Resource, Conservation and Recovery Act (RCRA).
For more details, call the RCRA Hotline at 800-424-9346 and ask for EPA publication 530-K-95-001, the 1996 update of
"Understanding the Hazardous Waste Rules—A handbook for Small Businesses." You may also wish to check out the World Wide Web site of the Coordinating Committee for Automotive Repair at www.ccar-greenlink.org.
If the refrigerant in your "junk" recovery tank is a chemical "soup" – wither contaminated R-12 and R-134a, or a
mixture of those contaminated refrigerants and some blend refrigerants that you are familiar with, then the contents
should be destroyed. If you have a contract in place with a waste hauler, contact the hauler to see if they can handle
the material. Waste haulers may require that the contents be identified first and may charge you for this
identification procedure. They are most likely to send the tank to an incinerator for destruction. You may also want o
contact one or more reclaimers, who will send the refrigerant off-site either for destruction, or for reclamation, which involves breaking it up into its chemical components and purifying each of the components. Some reclaimers can handle tanks sent to them from anywhere in the nation. A reclaimer does not necessarily have
to be located in your area.EPA maintains a list of reclaimers that is available through the Hotline at 800-296-1996. EPA will update this fact
sheet in the event that the Agency receives more specific information about which reclaimers will accept mystery mixtures of refrigerant.
If you have questions about disposing of specific blend refrigerants, call the refrigerant manufacturer. Most
manufacturers of blend refrigerants have made arrangements with specific reclaimers to handle their used refrigerant.
For a list of these telephone numbers, see the EPA fact sheet "Choosing and Using Alternative Refrigerants," available from the Hotline. |