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Barrier Removal Success. Kristen Taddonio Chair, Global Barrier Removal Team 13 June 2008. Barrier Removal Status. In 2006, EC/US/Japan agreed to remove global barriers to alternative refrigerants’ adoption US EPA Team identified US barriers (indicative):

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barrier removal success

Barrier Removal Success

Kristen Taddonio

Chair, Global Barrier Removal Team

13 June 2008

barrier removal status
Barrier Removal Status
  • In 2006, EC/US/Japan agreed to remove global barriers to alternative refrigerants’ adoption
  • US EPA Team identified US barriers (indicative):
    • Department of Transportation accumulator pressure requirements
    • State bans on toxic & flammable auto A/C refrigerants
    • Occupational Safety and Health Administration (OSHA) requirements for training, personal protective equipment, safe handling, pressure relief devices, equipment inspection, worker exposure, ventilation, and refrigerant storage

- US EPA Significant New Alternative Program and Toxicity Program review

u s department of transportation waives pressure requirement
U.S. Department of Transportation Waives Pressure Requirement
  • “[Air conditioning systems] are an integral component of a motor vehicle and necessary for the operation of the vehicle”… “Based on the information you provided, the air conditioning system…is not subject to the Hazardous Materials Regulation.”

–John A. Gale, Chief of Standards Development

US Department of Transportation (DoT) Pipeline and Hazardous Materials Safety Administration

11 July 2006

osha epa sae cooperation will satisfy us health and safety requirements
OSHA, EPA, & SAE Cooperation will Satisfy US Health and Safety Requirements
  • SAE J-Standards in progress: “Recommended practice for servicing CO2, HFC-152a and HFC-1234yf mobile air conditioning systems”
  • The SAE Standards will meet Occupational Safety and Health Administration (OSHA) requirements for training, personal protective equipment, safe handling, pressure relief devices, equipment inspection, worker exposure, ventilation, and refrigerant storage
  • SAE standard are critical to compliance with OSHA Health & Safety Requirements
state barriers removed nhtsa confirms no additional barriers exist
State Barriers Removed, NHTSA Confirms No Additional Barriers Exist
  • CO2 may be used in all states if safety is demonstrated and SAE standards and recommended practices are followed
  • Flammable alternatives listed by SNAP acceptable in all but 7 states where work continues
  • The US National Highway Traffic and Safety Administration (NHTSA) confirmed EPA SNAP listed alternative refrigerants acceptable under existing rules
flammable alternatives
Flammable alternatives
  • In 2006, 18 states and the District of Columbia had laws that banned flammable refrigerants in MACs
  • Barriers removed in all but 7 states for HFC-152a, which is now listed by SNAP
remaining challenges
Remaining Challenges
  • EU has yet to confirm if there are barriers for flammable refrigerants (HFC-1234yf or HFC-152a)
  • Legislative vote needed to allow EPA SNAP listed flammable refrigerant in the remaining 7 states
  • EPA SNAP and Office of Prevention, Pesticides and Toxic Substances Review not complete for HFC-1234yf
  • R744 Final Rule for CO2
contact
Contact

For Barrier Removal, contact Kristen Taddonio: [email protected] +1-202-343-9234

www.epa.gov/cppd/mac

For SNAP, contact Karen Thundiyil:

[email protected] +1-202-343-9464

co2 state barrier removal
CO2 State Barrier Removal
  • Approach:
    • Investigate definitions of toxic in State
    • When no definition exists, identify state authority responsible for implementing the statute
    • Inform state authorities of situation, ask if CO2 would be allowed in that state
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