Talk To NAFEM By Tomorrow On The EPA’s Refrigerant Phaseout

The foodservice equipment industry was well-represented during the Aug. 27 public hearing on the Environmental Protection Agency’s proposal phasing out all refrigerants currently used in commercial refrigeration equipment by Jan. 1, 2016. Thirteen of the 33 speakers at the hearing were NAFEM members. While all NAFEM members have until Oct. 6 to leave a comment on this critical issue, they only have until tomorrow to share data and opinions with the association.

NAFEM will be forwarding its comments to the EPA on behalf of the industry and needs to hear thoughts and opinions from member companies by tomorrow, Thursday, Sept. 18. Companies are asked to review the proposal, consider its potential impact on their business and share analyses—especially hard engineering data—with NAFEM’s Charlie Souhrada, director of member services, at csouhrada(at)nafem.org.

In its statement at the public hearing, NAFEM expressed grave concerns about the proposal. It pointed out that, “The proposal, as written, limits our industry to four refrigerant options: Ammonia, CO2, Isobutene and Propane. Considering current mandates originating out of the DOE regarding energy efficiency, combined with the toxicity, flammability and costs of these alternatives, the industry is facing lengthy research and engineering challenges.”

The association asserts that the proposed compliance dates are unrealistic, if not impossible, for manufacturers to meet and the impact on the foodservice equipment industry would be significant if the rule is finalized as proposed. NAFEM stated:

“Through careful consideration of previous refrigerant transitions and the amount of time necessary to safely introduce different/flammable refrigerants into the manufacturing process, NAFEM members assert the proposed timeline does not allow adequate time to:

• research refrigerant options;
• assess risks;
• analyze current manufacturing facilities;
• update existing refrigeration systems;
• work with suppliers to select appropriate compressors and components;
• build test units in a controlled lab environment;
• test the beta units;
• complete production and facility updates and internal training;
• build pre-production units;
• conduct field tests;
• educate customers and gain their approval;
• phase out or switch existing production lines;
• manage trapped inventory; and
• train customer service and field technicians to safely install, repair and maintain these units.

Based on the transition experience of European manufacturers and prior changes within the domestic industry, NAFEM is urging the EPA to provide at least a 10-year timeframe for its proposed conversion.