EPA issues final rule on HFCs used in RAC and MVAC systems
By Steve Schaeber, MACS Technical Editor
On September 20, 2024, US EPA Administrator Michael S. Regan signed a final rule implementing certain provisions of the American Innovation and Manufacturing Act (AIM Act) of 2020.
Primarily, this rule establishes a new ER&R (emissions reduction and reclamation) program, which aims to minimize the release of HFCs (hydrofluorocarbons) from refrigeration and air conditioning equipment by requiring leak repair and the use of automatic leak detection systems throughout the lifespan of such equipment. It also requires the service and/or repair of certain equipment to be done with recycled HFCs as opposed to virgin refrigerant.
Technician training, recordkeeping, reporting and labeling requirements are also included.
While much of the rule focuses on stationary refrigeration, the EPA addressed a few key points related to MVAC (motor vehicle air conditioning), which are of interest to MACS members.
Last year MACS published an article in ACtion Magazine (Recycle vs Reclaim, https://macsmobileairclimate.org/2023/05/17/recycle-vs-reclaim/ ) where we discussed the difference between the industrial-based “reclaim” process (where recovered refrigerants are processed and returned to their near-virgin state of 99.5% purity as specified in AHRI standards), and the shop-based “recycle” process (where recovered refrigerants are processed to the 98% service-spec based on SAE standard J2099).
One of the major issues we saw with requiring reclaim as opposed to our current recycling procedure was the massive environmental impact of transporting all the recovered refrigerant from shops across the country to reclamation facilities to be processed to the AHRI standard (and then back to shops for recharging vehicles).
And we think the EPA saw this as an issue, too.
In this final rule, the EPA stated they did not propose and are not establishing requirements for service facilities that currently reclaim or recycle recovered MVAC refrigerants. In support of their decision, the EPA acknowledged that regulations under Section 609 of the Clean Air Act already require that section 609-certified technicians use EPA-approved equipment designed to both recover and recycle refrigerant to meet SAE J2099. Due to the longstanding practice, many in our industry questioned the need to reclaim to the AHRI standard, when the SAE standard provides the same level of performance and durability as virgin refrigerant for the purposes of use in MVACs.
The EPA also acknowledged that SAE has consulted with AHRI, MACS and other industry stakeholders to develop a more appropriate, MVAC-focused standard. Although the EPA could consider adopting such a standard in the future, that day is not today.
Here’s a link to the EPA’s press release about this final rule: https://www.epa.gov/newsreleases/epa-finalizes-rule-accelerate-american-leadership-cutting-climate-damaging
Want to learn more about this final rule and read the full text of the pre-published document? Here’s a link to the EPA’s website: https://www.epa.gov/climate-hfcs-reduction
About the author: Steve Schaeber is technical editor and manager of service training at MACS, the Mobile Air Climate Systems Association, where he engages with industry and government stakeholders. Steve’s focus is on refrigerant lifecycle management in the mobile air conditioning and thermal management sector through training and best service practices, including the use of proper tools and equipment to recycle refrigerant and minimize its release into the atmosphere. Steve serves as vice chairman of the SAE Interior Climate Control Service Committee and secretary of SAE HFTC6.
You can reach Steve at sschaeber@macsmobileairclimate.org
