EPA Set to Issue NPRM on AIM ACT Refrigerant Reclamation
The US EPA is set to issue a Notice of Proposed Rulemaking (NPRM) by September 30, 2023 in accordance with the requirements of the US AIM Act 42 USC 7675 subsection (h) for the purpose of maximizing reclamation and minimizing releases of certain hydrofluorocarbons (HFCs).
AIM Act
As written, the AIM Act requires the EPA to promulgate rules requiring both R-134a and R-1234yf to be reclaimed prior to transfer of ownership. These requirements would, for all practical purposes, eliminate on-site recycling of refrigerants in the automotive service bay and require that the refrigerant be returned to an EPA certified reclaimer for reprocessing to the AHRI-700 standard. While this has been the rule in commercial (EPA Section 608) applications since the mid 1990’s, automotive shops were allowed to recover and recycle refrigerants on site to the SAE J2099 standard as part of the EPA Section 609 regulations.
Among the primary differences between the AHRI and SAE purity standards is the requirement for 99.5% purity from AHRI and only 98% purity from SAE. SAE J2788, J2843 and J3030 AC Service Machines are certified to purify the recovered refrigerant to the SAE J2099 standard and as written, would not comply with the AIM Act subsection (h) requirements.
Industry associations including AHRI, MACS, SAE and others are actively working with the EPA to support the continued on-site recycling practices that have been successfully used to service customer vehicles for 30+years. The EPA does have the authority to use appropriate successor standards to the AHRI-700 requirement that could allow the current service practices to continue with little to no interruption. No final rule on the MVAC or MVAC like (EPA Section 609) applications are expected in the September NPRM however the proposed rule is expected to set the stage for future rulemaking to address the automotive applications.
Learn More
You can read more on the AIM Act subsection (h) at: https://www.epa.gov/climate-hfcs-reduction/background-information-management-hfcs-and-substitutes-under-subsection-h
At the same time, the PA, and they’re all grand wisdom of fixing the problem, supposedly in their fairytale world in their minds.
They’re about to release SNAP alternative refrigerant that will be allowed and we all know how this goes. History repeats again back in the days of 12 Refrigerant were uneducated shop owners employees, and they do it yourself just starts dropping in the SNAP refrigerants right on top of, the perfectly good 134 or 1234YF refrigerant contaminating it . We already have enough of that problem with shops that go to the Internet and get the flammable propane butane mix that we all know of and either use that with no identifying labels no unique fittings or just drop it in right on top of the existing refrigerant already a problem.
How about if we mandate with no exclusions no exceptions if you have a set of gauges in your shop and you perform any air conditioning service at all whatsoever, you must have a Refrigerant the Analyzer
Shops who contaminate customers vehicles, and are caught either by another shop or a dealer how to reimburse shop for all previous repairs and if damage was done to a compressor, the shop hast to pay the dealers bill at full price for not having a Refrigerant Analyzer, keeping or contaminated, refrigerant out of customers cars.
How about mandatory education because the automotive industry self-regulation definitely has not been working, even though we hate more government, interference and rules
What is so bad about education?
Yes, a shop owner is a multi offender of these rules, and it’s found that the shop owner himself cannot physically repair the cars and mentally capable of doing diagnosis and repairing he shall be removed from his shop. All his assets are to be sold off and donated to trade schools training technicians, and he has to be handed a job applications to McDonald’s.. I know I’m gonna get hot tarred and feathered for saying that break out the pitchforks and torches.
We have to stop making automotive industry, the industry of the lowest common denominator. Excuses and lack of responsibility without very expensive punishment and consequences.
Because business owners and corporations only listen to one thing, and one thing only
If you hurt their pocket book, they change if you give them warnings without teeth they keep doing the same thing.
Thomas Lech: We’ll unpack your comments one by one. To be clear, this law was passed and signed in 2020 under the previous administration. The EPA recognizes the challenges this law poses and is working with MACS and others to minimize the impact.
While you are correct that SNAP submission(s) are in front of the EPA, The EPA has yet to publish a disposition for these and if approved, the “Use Conditions” will be a factor in their marketability and use.
The concept of enhanced certification is being explored and we’ll reserve comment on that until additional information is available.
In the case presented, even refrigerant Analyzers that are available today would not be suitable to meet the requirements. Furthermore, like speed limits, compliance is directly proportional to enforcement.
This is classic government overreach that will affect the livelihood of thousands of automotive professionals across the country, how is epa addressing that issue?
Mark Ducham: The EPA recognizes the challenges and is actively working with MACS and other parties to take full advantage of the provisions in the law to maintain the service process as is with minimal additional cost to shop owners. Because the AIM Act is a law, modification of the law is not the path of least resistance. We will wait to see how the NPRM reads and comment further once it is public.
It’s all about not venting refrigerant, right?
Put yourself in the consumer’s shoes…
This new, proposed protocol will increase consumer outlay per repair; increase venting as the owner will try to repair themselves or seek out unqualified “recreational” technicians that do not have a RRR machine or other, HVAC related tools and skill-level.
Then, those PHEV/BEV units dependent upon HVAC for HVB temperature: Second, third, fourth gen ownership – with less expendable funds – will, again, attempt to repair themselves or unqualified recreational technician. This will most likely result with HVB issues and/or thermal management induced fires.
Hardest hit: the independent shop – where time and manpower to follow these steps and take refrigerant offsite during operating hours…well, they will probably choose to remove HVAC service from their menu and concentrate on more profitable repair areas. Again, pushing consumer to DIY for personal cost savings as the amount of centers available to service will dwindle and consumer fees rise.
Here’s an idea? How about the RRR manufacturers create an add-on filtration system -installed via inlet/outlet hose ports – that would give the refrigerant a second pass through an independent system (these machines are coded; add feature to existing machine) and to bring purity values up to EPA proposed standards; manufacturer new RRR machines to new standards. It can be accomplished if it’s profitable. And based on the RRR units sitting in warehouses, design monies, etc., this would benefit the equipment manufacturers…and shops, alike.
Pam Oakes: We agree that changing the process in a dramatic manner will be counterproductive to the Service Industry and the Environment. The concept of modifying the machines has been explored. Unfortunately, the cost to the shop owner would be excessive for a modification or new machine due to the requirements of the law. MACS has, and will, continue to expend significant resources to maintain the service process as is or with only minor adjustments.