• A requirement that technicians be certified to install, service, or dispose of HFC-containing appliances.

• Updates to EPA Section 608 certification test questions to reflect the changes in the regulations.

Both Donaldson and Hall-Jordan stressed that the agency has not proposed a regulation at this point. Right now it is simply seeking input from stakeholders to determine what changes, if any, should be considered, and their feasibility.

“We’re meeting with stakeholders attending industry conferences, and meeting with interested parties at the EPA to collect good ideas, and our challenge going forward is to take all the ideas we hear and decide what should go into a proposed rule,” Donaldson said.

He added that changes to the rules could potentially benefit HVACR technicians by providing greater clarity to the regulations and helping technicians easily understand how the regulations apply to different types of refrigerants.  

Hall-Jordan said that it would take some time for the agency to move from the current pre-rule phase to an actual rule. 

He explained that in the pre-rule phase the agency seeks input and considers what might or might not be included in a proposal. Next, EPA issues a draft proposal for other federal agencies to review, which can take anywhere from three to six months. At the end of that process a proposal is issued. There is then typically a one- to three-month public comment period. All public comments are read and considered, the proposed rule is modified as appropriate to reflect those comments, and then a final rule is issued. 

“Typically it takes about nine to 12 months between when a proposal comes out and the final rule comes out. So we’re trying to get a proposal out this year and then a final rule out sometime in mid- to late-2016,” Hall-Jordan said.

He added that interested parties do not have to wait for the public comment period to share their thoughts and ideas with the EPA. 

“The agency is very much in an active discussion and listening phase, so if folks are interested we would very much welcome hearing from them,” he said.  

To provide input, contact the EPA by visiting www.epa.gov/ozone/comments.htm.

Donaldson said that the agency is working closely with a number of industry groups as it proceeds, including groups representing HVACR contractors, approved technician certifiers, refrigerant reclaimers, environmental organizations, supermarket trade associations, equipment manufacturers, and other organizations affected by the 608 regulations.

One of the issues raised to date concerns the possible recertification of technicians. According to Hall-Jordan, as with other issues EPA is considering, the agency has made no decision on whether to propose requiring technicians that are currently certified under Section 608 to recertify. If the agency proposes to require recertification, EPA could, as has been suggested by some, propose that recertification happen over time rather than immediately. In any event, the agency would take public comment from technicians and others into consideration on this, and other issues, before finalizing a rule. 

Adding costs for contractors is not one of the agency’s intentions. “One of the things we’re very mindful of when we establish a new regulation is how the affected industry will experience it as far as cost of doing business,” Donaldson said. 

In other EPA news, as expected, EPA, through its Significant New Alternatives Policy (SNAP) Program, has approved the following low-GWP hydrocarbon refrigerants, subject to use conditions, in the following refrigeration and air conditioning applications:

• Ethane in very low temperature refrigeration and in non-mechanical heat transfer;

• Isobutane in retail food refrigeration (stand-alone commercial refrigerators and freezers) and in vending machines;

• Propane in household refrigerators, freezers, or combination refrigerators and freezers, in vending machines, and in room air conditioning units; 

• The hydrocarbon blend R-441A in retail food refrigeration (stand-alone commercial refrigerators and freezers), in vending machines and in room air conditioning units; and

• HFC-32 (difluoromethane) in room air conditioning units. HFC-32 has one-third the GWP of the conventional refrigerants currently being used in room air conditioning units.

In addition to adding these climate-friendly alternatives, EPA is also exempting all of these substances, except HFC-32, from the Clean Air Act venting prohibition, as current evidence suggests that their venting, release, or disposal does not pose a threat to the environment. 

“Today’s rule is an example of how we can turn the challenge of climate change into an opportunity to innovate our way to a better future,” said EPA Administrator Gina McCarthy. “By working together, businesses and EPA are bringing new, climate-friendly refrigerants to market that better protect our health and the environment.” 

For more information, visit http://www.epa.gov/ozone/snap/index.html.