R-22 Equipment Is Being Shipped 'Dry'

November 8, 2010
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The magic moment of Jan. 1, 2010 when HCFC-22 equipment would no longer be manufactured ended up being magical for only a few months.

By the middle of 2010, a number of manufacturers had begun to ramp up production of such equipment and dry-shipping them without the refrigerant. Several industry observers think the shipments are in the tens of thousands with one such observer - Ted Gartland of Allied Representatives, saying, “Millions will be sold.”

The reasons for the development - which, to many, was unexpected - include:

• The original U.S. Environmental Protection Agency (EPA) ruling of 2009 - designed to curtail use of R-22 - only said that entire systems could not be manufactured and that any replacement components for aftermarket use could not be pre-charged with the refrigerant.

• The fact that condensing units constitute a component not an entire system.

• There is still an ample supply of R-22 at fairly reasonable prices.

• A sluggish economy is helping prop up R-22 supplies.

• There is a customer demand for the less expensive R-22 components to use in repair of older R-22 components, rather than changing out to R-410A a/c equipment.

The concerns raised include:

• The continuing manufacture of entire condensing units - while not in violation of the letter of the law with regards to the EPA regulations - may not be meeting the spirit of the law even if that spirit is somewhat unclear.

• The possibility that the stepped up use of R-22 to charge on site the dry shipped equipment will increase the use of the refrigerant to the point where some R-22 equipment could become stranded and unable to be serviced with dwindling supplies of R-22.

• Some questions about the ability of service technicians to fully charge a residential air conditioner on site especially in terms of accidental venting.

FORMAL ACTIONS

The Air Conditioning, Heating and Refrigeration Institute (AHRI), a trade association representing more than 300 manufacturers of air conditioning, heating and commercial refrigeration, told The NEWS that its relevant committees and sections are reviewing the issue. “Quite frankly, we did not anticipate that R-22 units would continue to be manufactured in any significant quantity,” said Stephen Yurek, AHRI president and CEO.

“Accordingly, we had decided to remove all R-22 condensing units from our directory as discontinued. Now that most of the members who produce these products have decided to reopen their manufacturing lines, we are re-evaluating whether to certify them.” Yurek said his organization is consulting with members, the Department of Energy, and the EPA before making a decision about certification.

The confusion goes back to late 2009 when the EPA’s final ruling related to R-22 equipment focused on not having R-22 in the units rather than what could be manufactured.

Reactions among manufacturers in the industry have been rapid and frequent in the days leading up to publication of this story in The NEWS. As of press time, the new, dry R-22 condensing units being manufactured are currently outside the scope of AHRI’s certification program.

Though the possibility exists that EPA could clarify its regulations, EPA has not committed to any changes yet. If a rulemaking is required to clarify or modify the rule, a final decision could be a year or more away. At that point the supply of R-22 could be so low as to make a revised regulation a moot point.

That point was amplified by Gartland in his address in mid-September to the Food Marketing Institute Energy and Store Development Conference. While primarily highlighting legislative issues that could affect the refrigeration sector, Gartland said phase-outs of R-22 equipment and a sluggish economy was keeping supplies of R-22 adequate at a reasonable price. But the R-22 condensing unit issue that arose at mid-year could put new pressures of R-22 supplies especially with his estimate that “millions of units” will be manufactured post-Jan. 1, 2010, “to be used as replacements.”

MANUFACTURER VIEWPOINT

“Nordyne supports maintaining the availability of dry HCFC-22 units for the marketplace,” said Philip Windham, vice president of sales for Nordyne. “This is why we stand behind our business decision to produce dry (uncharged) R-22 units as an alternative component instead of a compressor change-out or other less-efficient options.

“We believe this equipment provides the consumer with a more conscientious option for the repair choice that they are already making. This choice, when made by the consumer, is more energy efficient, reliable and protects the environment due to the highest level of leak protection offered on all controlled production units. “We do not see these units displacing R-410A systems. Rather, we see dry R-22 units as an option to repairing less efficient, older R-22 units.”

According to Bill Hanesworth, VP and general manager for Rheem Heating and Cooling, “Rheem is committed to supplying its customers with replacement parts and components to service existing installations. With a replacement market three times the size of the new construction market, and with the economy being the worst in decades, Rheem is dedicated to supporting consumers who have our products installed in their homes.”

He added, “As such, Rheem will produce a limited supply of split system air conditioners that will be shipped dry (nitrogen holding charge) and require a field-supplied charge of R-22 refrigerant.”

The NEWS has learned that Carrier, Goodman, Lennox, Nordyne, and Rheem all will produce dry R-22 condensing units.

NOT UNEXPECTED

The possibility of dry-shipped condensing units was on the industry radar screen as far back as early 2008. A Feb. 11, 2008 article in The NEWS said, “A closer reading of the Environmental Protection Agency regulations regarding R-22 from several sources within the HVACR industry seems to say that equipment can no longer be pre-charged by the manufacturer with virgin R-22 as of 2010. But there does not appear to be any prohibition from manufacturers shipping R-22 units without virgin R-22, leaving it up to the buyer to figure out how to get enough R-22 to have the system later charged by a contractor.”

The article went on to quote Talbot Gee, vice president of HARDI, as saying, “Basically there is no ban on the production of R-22 equipment as long as it is not pre-charged with virgin R-22.”

CERTIFICATION

The issue of self-certification and the role of the Department of Energy (DOE) - which requires testing, verification, and labeling of products sold - were also discussed by the manufacturers responding to The NEWS’ request for comment.

Said Hanesworth, “For products that are not covered by an approved third party certification program, such as AHRI, manufacturers are to submit certification reports and compliance statements directly to the Department of Energy. Rheem will certify these products directly with DOE and, thus, meet all obligations to comply with submission of energy efficiency data.”

Said Nordyne’s Windham, “There is a process for certifying directly with the DOE. Keep in mind that the equipment was certified before and ratings were removed only three months prior to the initial scheduled removal.”

WHOLESALERS

HARDI also has become involved in the issue. According to Gee, “HARDI met with DOE enforcement and compliance staff to better understand how the appliance-standards certification process worked for residential split HVAC systems, and to determine whether HVAC distributors have a compliance obligation with respect to the sale and installation of central air conditioning and heat pump systems that may not meet federal minimum efficiency performance standards.

“Based on this information, HARDI recommends that any HVAC distributor obtain the following from the manufacturer or importer of newly-produced residential R-22 condensing units prior to taking possession of the product:

• Copies of valid Manufacturers Certificate for each unique model number purchased;

• Copies of the test data submitted to DOE showing minimum 13-SEER performance for each unique model number purchased; and

• Agreement with manufacturer or importer to take back any newly-produced residential R-22 condensing units if U.S. EPA or DOE regulations change regarding the sale and distribution of R-22 condensing units manufactured after Jan. 1, 2010.”

Gee described the problem as “frustrating with all the uncertainty. What will be the long term exposure for (HARDI) members and our contractor customers?”

Windham said, “We are telling wholesalers that the decision on whether or not to stock and sell uncharged R-22 units is entirely up to them. We encourage them to research the matter and make the decision that is best for their marketplace and their customers.”

INSTALLATION

One aspect of the issue in which there seems to be agreement is that the installation of dry-shipped R-22 condensing units should not pose a problem for service technicians. Anecdotal conversations with air-conditioning technicians point to just putting a larger amount of R-22 into a system rather than the typical topping off or taking out a bit of R-22 on site as was the case with pre-charged systems.

Added Windham, “The main difference between installing an uncharged R-22 system component versus one with a factory charge is that the contractor must first purge the dry nitrogen in the unit and then charge according to factory-supplied charging charts. It is also a more cost-effective and less-complicated install than using an R-410A outdoor component with an existing indoor R-22 indoor component. We emphasize that contractors use a standard recovery system anytime they reclaim refrigerant, as well as install a filter dryer to protect the system components.”

Hanesworth agreed. “Contractors should perform a complete system evacuation and follow the charging information included with the unit.”

Publication date: 11/08/2010

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R22 Condensers- What?

November 16, 2010
I can't believe the industry is stepping backwards on this issue. We have educated customers on 410A and successfully converted them to go with 410 systems. We always push to have "matched" systems installed for the best energy efficiency and operation. This availabilty of R22 condensers only complicates our business and allows less customer minded contractors to sell mismatched systems that will not have the performance stated. Who is the winner in this decision. It certainly won't be the consumer in the long run. The only winners will be manufacturer's that can't properly market and sell their 410A systems. This all seems to go against the policy of the EPA either written or intended.

R22 Condensers

Jim J.
November 16, 2010
Apparently the manufacturers don't care about the environment.

Okay

N Baker
November 16, 2010
aaaahhhhhHHHH...The smell of Money being Made!

r22 cond

d h v a c
November 16, 2010
looking forward to new units

R22 condensers

The Man
November 17, 2010
This will put a stop to many of the residential contractors gouging home owners for $10,000 to $15,000 for unit replacements in the name of a federal mandate. If the residential industry didn't rape and pillage the consumer they would make the change willingly in the name of efficiency.

Dry R22 Units?

November 17, 2010
Doesn't this mean that "dry" units can now be by the mfg direct to the homeowner? No need for proof of EPA certification for purchases since there is no "handling" of refrigerant. Since 1994 we've been told R22 is depleting the ozone, requiring certifications, laws & fines and "governing" of the industry. Everyone knows including the mfg's what the law "meant." If the servicing companies & techs have been trained/educated by all the mfg's re: R22 - how can they not abide by what THEY defined to the dealers?

Dry r 22 codenseing units

November 22, 2010
This is an outrage, for some time now we have been gearing up & educating customers about R410a @ how much better it is for the ozone, @ how much cleaner & safer it is for th world as a whole, which R410a has so much more to offer than R 22, R410a the efficency is 2 to 1 over R 22, & R410a has far better humidity control than R 22, with that said we have all done our job to inform our customers & now I feel that we all just got a big slap in the face, we should be steppin forward not backwards. We are not doing anyone any justice by installing a condensing unit, it will cost them more in the long run

R22

Karl McGaugh
November 25, 2010
Wake up and know the details. The ozone scare was not caused by refrigerant contamination. Volcanoes and natural soruces are the real problem. The GWP of the new refrigerants is worse for the enviroment that R22 because of the extra power being required from the electric utility. We need to use the most eficient refrigerant, R22. Stop pushing change as progress. It's a lie. Not all change is progress. The problem was the ozone hole and this is now moot. We need to conserve energy and use conservation techniques for handling refrigerants. Make laws to mandate higher efficiencies and let the free market build it.

R22 vs R410a

Loop
November 25, 2010
This all sounds like passing the "hot potatoe". A loop hole was found so everyone can interpret it as they see fit. Whoever has the authority should specifically re-define the intent of the change in the law. Leaving it up to all for their interpretation is not the answer. If this is how laws should be interpreted, then I want to drive 100 miles per hour in 100 kilometer speed zone.

R22 vs R410A

John
November 25, 2010
If I remember correctly, the refrigerant certification mentioned that refrigerant recovery was only for quantities of less than 50 lbs. Shortly before, and after the refrigerant certification, the refrigerant manufacturers bought up nearly all of the certified refrigerant recovery containers, and bought into some of the companies who started manufacturing the refrigerant recovery units. Now, it appears that there is more money to be made selling R410A than R22 because the equipment manufacturers have been telling the dealers that the indoor cooling coil has to be changed also, when changing out an R22 condenser. I smell a rat.

New R-22 equipment

JS
November 30, 2010
R-22 has been the refrigerant of choice for more than 50 years for 1 reason: it works really well. I have been involved with testing several alternate refrigerants, and in our specific application, there are serious sacrifices in capacity and efficiency. At least with a capacity shortage, you can just make the equipment larger (though customers like some of those posting here are suspicious of these claims). But when efficiency suffers, everybody suffers, and there is no compensation.

dry units

teacher
December 2, 2010
I don't see the big problem here it does offer some choices to the consumer and if approached in that way would be great. Also this would be a good chance to maybe use a alternative refrigerant which would be a double win.

R22

Jim Thornton
December 7, 2010
@ Karl McGaugh: It is amazing the number of revisionists that come out of the woodwork related to ozone depletion when they see an opportunity. Get a life guy. The ozone depletion issue was not some vast conspiracy against you. It was based upon sound science and ozone depletion is still a concern. This is going to confuse the consumers. People in the industry have been educating the consumers for several years that R22 was being phased out. Now there is news that says, wait!, we were just kidding! The residential portion of our industry already suffers a somewhat shady reputation amongst property owners. How do you think this will play? Not well, I bet.

R-22 vs R-410

Len
December 7, 2010
A lot of guys here are complaining about allowing the use of R-22. Why? If you are selling upgrades keep pushing the 410 systems, no problem. THough some people on smaller budgets want the cheapest way out to have cac. Here is the place the dry systems will be used. Nothing wrong with having a couple refrigerant choices. Plus, personally I believe r22 is a much better refrigerant than 410. Ads far as the ozone is concerned, it was r12 that reached the ozone, r22 breaks down way before it gets that high up. So chill out and sell what your customer wants, needs or can afford.

what a debacle

Terry
January 7, 2011
Two important things should come to mind for us as contractors.1-After educating our customer base for 2 plus years on the phase out of R-22,I agree that this will damage our reputations & well meant recommendations to the public about the use of a better refrigerant and higher quality equipment(410-A).2-We, as contractors, should worry about the liability of charging these dry units.Ex:It seems clear that the manufacturers have steered around any wrongdoing by selling these dry units without R-22.I am sure they have legal depts. that have cleared the way for them to skirt through this loophole.However, we should be concerned that the actual perceived tort here could be the contractor violating the "spirit" or the "future determined letter" of the law by charging a dry unit with R-22. ---Regardless of how this mess ends up, we as contractors are the ones that look bad or take the risk.The EPA and the manufacturers need to get their collective #$%@ together to try to protect the environment and the consumer.

Go GREEN with the Green Can!

Adam
January 24, 2011
The R-22 vs R-410A controversy has always and only been about the power/pocket-lining the EPA is getting from our government. R-22 can be cleaned and recycled 100 times over. While, R-410A cannot be recycled and has to be BURNED after recovery. Now which do you think is more hazardous for the environment? People try to put the fault of the equipment manufactures for going back to R-22 systems, but the fault is on the R-410A manufactures who paid-off the EPA to mandate all equipment manufactures to produce R-410A systems only. So now that R-22 is out of the picture, that can keep pumping R-410A down the throats of the equipment manufacturers, contractors, and consumers. In this economy, we need to provide consumers with the most inexpensive options to get through these hard times. But the bottom-line is that the consumer should not be forced by the government to their HVAC decisions (short-term or long-term).

R22 dry Units

hvac rep
January 24, 2011
Q: Will a 10 SEER indoor coil show as a proper match with a 13 SEER condenser? If not, won't the warranty on the brand new R22 dry charged unit be voided? Lets be honest, we all know that the majority of those who cannot afford a new system have probably been keeping their old 10 SEER system alive for the past several years. Are they going to be able to afford to replace a 2 year old compressor that is not in warranty, or repair a leak after the R22 inventory is slashed by 80% in 2015? Probably not, and the homeowner is not going to be happy. Also, is there any truth to the rumor that the dry charged units can only be charged with recycled refrigerant (no virgin refrigerant allowed).

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