Good and bad in 1234yf

Jan. 1, 2020
The good news is that the EPA has finally cleared use of the new air conditioning refrigerant HFO-1234yf, which new car manufacturers have been clambering for because of its low Global Warming Potential (GWP).

The good news is that the EPA has finally cleared use of the new air conditioning refrigerant HFO-1234yf, which new car manufacturers have been clambering for because of its low Global Warming Potential (GWP). The bad news is that the final rule the EPA published on October 27 refuses to allow aftermarket sales of the refrigerant in small containers unless a number of conditions are met.

Lynn L. Bergeson, the Washington attorney for the Automotive Aftermarket Industry Association (AAIA), says the EPA's continuing concern about toxicity risks from aftermarket use are based on faulty data, including some on which the EPA relied on at the last moment, making it impossible for the AAIA to refute the information. "We continue to be disappointed with the EPA's excessive use of risk factors and unreasonable assumptions on which its analysis is based," she says. AAIA is considering a legal challenge to the EPA final rule based on possible violations of the Administrative Procedures Act. But Bergeson acknowledges that the bigger issue is the perception left by the final rule that HFO-1234yf is unsafe when used by a consumer in his garage.

The aftermarket use requirements don't hurt retailers immediately since GM, Ford and the others will only now start using the greener AC refrigerant in new cars. But the EPA estimates that there are about 11 million do-it-yourselfer (DIYer) auto recharges performed every year. So that will be a lot of consumer demand for small containers of HFO-1234yf in the not too distant future.

That is why the perception left by the EPA in the language of its final rule — that HFO-1234yf may be a toxicity or fire hazard when used in a residential garage — is something retailers must deal with now. The EPA has that concern, and until it is persuaded otherwise, it will not approve aftermarket sales, ever.

In the final rule, the EPA did back away from some earlier, troublesome proposals. The EPA had originally proposed to limit sales of HFO-1234yf to containers larger than 20 lbs. This would have essentially prevented aftermarket sales. AAIA thought the fire and toxicity possibilities were overstated; but it urged the EPA, if it continued to have concerns in that area, to eliminate the 20 lb. ceiling and simply require manufacturers to ship containers of HFO-1234yf to aftermarket retailers with self-sealing valves of the type already required in California.

The EPA, when it issued its final rule on October 27, rejected that argument. It said that data from the California Air Resources Board (CARB) indicated that 10 percent of DIY consumers released 100 g or more of refrigerant during servicing, including 2 percent releasing more than 500 g, and another 15 percent of DIY consumers released 50 to 100 g during servicing, due to faulty recharging equipment and poor technique. "Both these percentages and the overall number of DIY consumer recharging events indicate that a substantial number of events could have significant leaks," the agency said.

It then referred to the California DIYer container requirements, which went into effect last March, and argued that there was no evidence that they will be effective, arguing that AAIA provided "insufficient information on these approaches for EPA to assess whether, for HFO-1234yf, they would reduce exposures during DIY consumer use and thus eliminate the potential toxicity risk."

The EPA now says it could conceivably approve the retail sale of small containers of HFO=1234yf if manufacturers submit data that shows valves prohibit worrisome leaks.

The good news is that the EPA has finally cleared use of the new air conditioning refrigerant HFO-1234yf, which new car manufacturers have been clambering for because of its low Global Warming Potential (GWP). The bad news is that the final rule the EPA published on October 27 refuses to allow aftermarket sales of the refrigerant in small containers unless a number of conditions are met.

Lynn L. Bergeson, the Washington attorney for the Automotive Aftermarket Industry Association (AAIA), says the EPA's continuing concern about toxicity risks from aftermarket use are based on faulty data, including some on which the EPA relied on at the last moment, making it impossible for the AAIA to refute the information. "We continue to be disappointed with the EPA's excessive use of risk factors and unreasonable assumptions on which its analysis is based," she says. AAIA is considering a legal challenge to the EPA final rule based on possible violations of the Administrative Procedures Act. But Bergeson acknowledges that the bigger issue is the perception left by the final rule that HFO-1234yf is unsafe when used by a consumer in his garage.

The aftermarket use requirements don't hurt retailers immediately since GM, Ford and the others will only now start using the greener AC refrigerant in new cars. But the EPA estimates that there are about 11 million do-it-yourselfer (DIYer) auto recharges performed every year. So that will be a lot of consumer demand for small containers of HFO-1234yf in the not too distant future.

That is why the perception left by the EPA in the language of its final rule — that HFO-1234yf may be a toxicity or fire hazard when used in a residential garage — is something retailers must deal with now. The EPA has that concern, and until it is persuaded otherwise, it will not approve aftermarket sales, ever.

In the final rule, the EPA did back away from some earlier, troublesome proposals. The EPA had originally proposed to limit sales of HFO-1234yf to containers larger than 20 lbs. This would have essentially prevented aftermarket sales. AAIA thought the fire and toxicity possibilities were overstated; but it urged the EPA, if it continued to have concerns in that area, to eliminate the 20 lb. ceiling and simply require manufacturers to ship containers of HFO-1234yf to aftermarket retailers with self-sealing valves of the type already required in California.

The EPA, when it issued its final rule on October 27, rejected that argument. It said that data from the California Air Resources Board (CARB) indicated that 10 percent of DIY consumers released 100 g or more of refrigerant during servicing, including 2 percent releasing more than 500 g, and another 15 percent of DIY consumers released 50 to 100 g during servicing, due to faulty recharging equipment and poor technique. "Both these percentages and the overall number of DIY consumer recharging events indicate that a substantial number of events could have significant leaks," the agency said.

It then referred to the California DIYer container requirements, which went into effect last March, and argued that there was no evidence that they will be effective, arguing that AAIA provided "insufficient information on these approaches for EPA to assess whether, for HFO-1234yf, they would reduce exposures during DIY consumer use and thus eliminate the potential toxicity risk."

The EPA now says it could conceivably approve the retail sale of small containers of HFO=1234yf if manufacturers submit data that shows valves prohibit worrisome leaks.

About the Author

Stephen Barlas

Stephen Barlas has been a full-time freelance Washington editor since 1981, reporting for trade, professional magazines and newspapers on regulatory agency, congressional and White House actions and issues. He also does a column for Automotive Engineering, the monthly publication from the Society of Automotive Engineers. He covers the full range of auto industry issues unfolding in Washington, from regulatory rulings on and tax incentives for ethanol fuel to DOE research and development aid for electric plug-ins and lithium ion battery commercialization to congressional changes in CAFE standards to NHTSA safety rulings on such things as roof crush standards and data recorders.

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