NAFEM Urges Members To Speak Out On SNAP Regulatory Changes

NAFEM members have until Oct. 6 to leave a comment on the proposed rule, issued by the U.S. Environmental Protection Agency, which seeks to phase out all refrigerants currently used in commercial refrigeration equipment by Jan. 1, 2016.

The EPA’s Significant New Alternatives Policy Program requires the agency to identify and approve climate-friendly chemical alternatives in lieu of those that have been linked to stratospheric ozone depletion. The proposal aims to phase out the use of hydrofluorocarbon refrigerants in compliance with the Clean Air Act and encourage the purchase of cleaner alternatives to HFCs whenever feasible by transitioning to equipment using safe, more sustainable alternatives. If approved, the proposal will phase out certain HFCs with high global warming potential, and manufacturers will have to use replacements such as ammonia, butane, CO2 and propane.

NAFEM asserts that the proposed compliance dates are unrealistic, if not impossible, for manufacturers to meet, and the impact on the industry would be significant if the SNAP rule is finalized as proposed. Potential negative consequences may include less efficient refrigeration products, limited investment in R&D, manufacturers exiting the refrigeration market, possible company closures and increased operator costs. Members speculate these scenarios may negatively impact the industry as a whole, regardless of company size, product category or supply-channel function.

All stakeholders are encouraged to attend EPA’s public hearing Aug. 27, starting at 9 a.m. in Room 1153 of EPA East (entrance from 1201 Constitution Ave.), Washington, D.C. Additional information will be provided on EPA’s Stratospheric Ozone website: epa.gov/ozone/snap.

NAFEM will submit industry comments to the EPA by the close of the comment period on or before Oct. 6. Members who want to participate directly in this process should contact Charlie Souhrada, CFSP, director-member services at csouhrada@nafem.org or 312/821-0212.

The association is urging its members to review the proposed SNAP rule and consider the potential impact to their businesses. Companies also are invited to contribute to NAFEM’s comments on behalf of the industry, by sharing analyses, especially hard engineering data in particular, with csouhrada@nafem.org by Sept. 18.

Issues manufacturers should consider commenting on include:

• Assess risks associated with the proposed, highly flammable refrigerants in manufacturing facilities and commercial kitchens during installation, use and service and repair.
• Identify number of products/percentage of your product line affected.
• Determine if product lines will be discontinued because of the proposed EPA refrigerant choices available or because of the short conversion time.
• Explain what refrigerant option your company would switch to and how that might be achieved.
• Explain upfront costs of switching, including evaluation, redesign, implementation and training (including employees and service professionals).
• Provide records regarding costs, timeline and product-line impact associated with any prior refrigerant switch by your company.
• Outline testing-lab availability—e.g., CSA, ETL, NSF, UL—and time and costs associated with switching refrigerants (if possible, provide copies of refrigeration testing invoices to demonstrate the costs of compliance).
• State number of hours needed to redesign each model.
• State number of technicians available and their collective pool of hours worked.
• Determine manufacturing/assembly-line space.
• Explain impact on research and development of new products.
• Summarize spending impact to comply with the new mandates.
• Identify functions that will be performed in-house vs. third-party consultants.
• State the estimated number of years it will take for your entire product line to be switched over to a new refrigerant and tested before you can offer it for sale.
• Identify testing schedule of other products from now to 2017.
• Explain current engineering-team schedule from now to 2017 (product development, meeting other regulatory requirements, etc.).

The EPA is particularly interested in comments about product types that were not clearly defined, e.g., automatic commercial ice makers.

Watch NAFEM online and nafem.org for advocacy updates, or contact NAFEM headquarters at 312/821-0201 for more information.