Ensuring a Smooth Transition on Refrigerants

When the U.S. Environmental Protection Agency and Canada’s Ministry of Environment and Climate Change began considering banning the use of common HFC refrigerants used in home appliances due to their high global warming potential, AHAM immediately began working to ensure the necessary pieces are in place for the industry to make a smooth transition to the next generation of refrigerants. The actions of the top climate agencies in the U.S. and Canada are but two ingredients in a regulatory stew brewing in North America that also includes the California Air Resources Board and legislature and U.S. federal courts. AHAM is leading a voluntary effort to afford industry sufficient time to make the transition and to address the major concerns of policy makers.

This transition, which affects both refrigerants and foam insulation, is requiring a major investment from appliance manufacturers to develop appliances that utilize newer refrigerants. Its impact extends across multiple home appliance categories, including refrigerators, freezers, portable and room air conditioners and dehumidifiers. A proper regulatory structure is critical to support the substantial investment manufacturers are making in the transition.

The North American transition to alternative refrigerants and foam-blowing agents required changes to safety standards and in particular to the maximum allowable refrigerant charge size for isobutane used in refrigerators.

Part of AHAM’s work happened through the Council for Harmonization of Electrotechnical Standards of the Nations in the Americas (CANENA) Technical Committee 61C (Safety Requirements for Household Refrigerators and Freezers) of which AHAM is the Technical Harmonization Committee (THC) secretary. AHAM members compiled the data and technical rationale to permit the use of larger hydrocarbon refrigerant charge sizes and amending the CANENA refrigerator-freezer safety standard (60335-2-24). The standard has been adopted and published by both UL and CSA for the U.S. and Canada markets, respectively. AHAM has also been supporting the UL/CSA safety standard work in UL/CSA 60335-2-40 for flammable refrigerants in portable and room air conditioners and dehumidifiers.

At the U.S. federal level, the transition to hydrocarbon refrigerants also requires technical changes to EPA’s regulations so that the maximum permitted refrigerant charge size is in line with the CANENA safety standard limit. AHAM has worked extensively with U.S. regulators to secure such an increase in the federally allowed charge size for isobutane to 150g.

While recent U.S. court cases have created uncertainty concerning the EPA’s use and authority under the Significant New Alternatives Policy (SNAP) to ban the use of certain HFC compounds, AHAM is seeking near-term guidance or direction from EPA to provide certainty as quickly as possible. AHAM has brought the industry’s need for certainty on refrigerants to the top levels of the EPA. During recent meetings with AHAM members and staff, a top EPA official, Sarah Dunham, acting administrator of the EPA’s Office of Air and Radiation, said that EPA is working on near-term guidance on the court decisions. The agency is also working on addressing how to move forward on addressing the charge size allowance of isobutane.

The Ministry of Environment and Climate Change Canada promulgated regulations under the Canadian Environmental Protection Act that will prohibit the use of foam blowing agents and refrigerants in home refrigerators and freezers that have a GWP of greater than 150. Compliance with the foam blowing regulations commences on Jan. 1, 2021 and refrigerant gases regulations commences on Jan. 1, 2025.

AHAM has also advocated for the industry on refrigerant policy at the state level. The California Air Resources Board is pursuing regulatory actions on HFC prohibitions for refrigerators, freezers, room air conditioners and possibly portable air conditioners, and the California legislature is considering a bill prohibiting HFCs in refrigerators and freezers. AHAM has spoken for the industry to make sure states do not move ahead of actions at the federal level.

The transition to newer refrigerants will also require changes in appliance maintenance and repair. AHAM has laid the foundation for changes with its guidance document, “Safe Servicing of Cold Appliances with Flammable Refrigerants,” which details the steps service providers must take to mitigate the risks associated with the higher flammability of the refrigerants.