Foodservice Equipment Reports

NAFEM, Refrigeration Makers Fight EPA Refrigerant Phase-out Deadline

Since the 1987 Montreal Protocol first addressed and banned substances that deplete the earth’s ozone layer, phasing out refrigerants and chemicals deemed harmful to the environment has been an ongoing issue for refrigeration manufacturers. Today, the industry is facing the most sweeping, most accelerated and, according to NAFEM and the 155 refrigeration manufacturers it represents, most impossible-to-achieve change ever considered.

A proposed rule announced on July 10 by the U.S. Environmental Protection Agency would terminate the use of certain hydrofluorocarbons (HFCs) with high global-warming (GWP) potential.  The EPA’s proposal would phase out all currently used refrigerants (R134a, R404A, R407A, R407C, R410A, R507A, R12-22-502 and other blends) in manufacturing and the aftermarket within 18 months. The ban would go into effect Jan. 1, 2016, and leave only a handful of options for keeping food cold (and homes and businesses cool). Commercial refrigeration manufacturing is just one of the industries that rely on the affected HFCs, but it has the earliest deadline for the changeover.

Replacement refrigerants included in current discussions include ethane, isobutane, propane, R441A (HC blend) and HFC-32. Because these refrigerants are flammable, the EPA also is planning to propose “appropriate use” conditions. None comes close to ideal; all are either flammable, dangerous or create difficult design challenges.

The issue, however, is not whether low-GWP refrigerants make sense but the 2016 compliance date, which NAFEM and refrigeration manufacturers say is unrealistic and unworkable. NAFEM has been deeply involved with discussions on the proposed status change, urging the EPA to consider the technical and economic feasibility of transitioning from the HFCs to the substitute chemicals as well as a realistic timetable to make the transition. NAFEM has gone on record protesting that the proposed rule dramatically and suddenly reduces the variety of refrigeration options and products in the marketplace. Additionally, the elimination of R134a as a blowing agent in insulation means a costly conversion process, which limits a manufacturer’s ability to manufacture custom products. 

As stated on its website, NAFEM maintains the proposed rule creates a number of safety and business concerns:

  • Causes flammability, affects factories, service and operators and may conflict with local codes.
  • Places undue burden on small businesses, including but not limited to cost increases that must be passed on to operators, such as research and development, listing, plant retrofit, insurance, distribution and employee training.
  • Increases operators’ desire to extend the lifetime of older products.
  • Limits a manufacturer’s ability to conduct product-quality reviews and develop new products.


Most importantly, NAFEM maintains that at a minimum, the EPA should consider extending the compliance time to accommodate small businesses, because a manufacturer with hundreds of products, whether specialized and customized, could require at least 10 years to design a product complaint with the EPA’s Significant New Alternatives Policy (SNAP). 

Adding to the issue is the proposal’s variance with new Energy Star standards from the U.S. Department of Energy. In a final rule issued in late March, the DOE issued updated standards for commercial refrigeration equipment first set in 2009 and outlined more stringent energy-conservation standards. In June, NAFEM filed a petition for review in the U.S. Court of Appeals against the DOE’s final rule.

The association met in April with the EPA’s SNAP team to discuss the industry’s position and concerns and had seats at the Small Business Association’s Advocacy Environmental Roundtable on Aug. 1. The NAFEM delegation, led by Refrigeration Chair Mary Dane, stated that—in consideration of normal product-development cycles and the lack of commercially available components and refrigerants and the 2017-18 DOE requirements, as well as the European Union’s 10-year head start on engineering, formulating refrigerants, testing and training—that the timeframe for the changeover be adjusted and set for 2025.

The EPA is now developing final regulations for its low GWP refrigerants rule. NAFEM's website is the proper channel for finding more advocacy information on these issues. If more detailed information is needed, contact Charlie Souhrada, NAFEM’s director-member services, at csouhrada@nafem.org

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