How would you like to have to pay the Environmental Protection Agency (EPA) $10,000 just for having a large piece of mechanical refrigeration equipment running on R-22 — even if it wasn’t leaking?

That’s the situation facing the baking industry and its several hundred industrial processing refrigeration appliances used for temperature control.

It’s a situation that may ignite a faster phaseout of HCFC-22 in that sector than is required by law, resulting in a quicker switch to HFCs.

The motivation for all the action was a major fine in 2000 against a baker’s facilities in five states. The EPA levied $3.5 million in penalties because the company “continued to add refrigerant and operate equipment without making repairs even where the leak rates were greater than 58%.” The baker was also cited for not doing leak checks, maintaining complete service records, or developing retrofit or replacement plans.


Fearing similar action on a wider basis, the baking industry decided to reach an accord with the EPA. This resulted in the EPA and the bakery industry entering into what it called “a voluntary bakery partnership program for equipment containing ozone-depleting substances at industrial bakeries.”

Bakers will need to notify their willingness to participate in the agreement by April 26 of this year. There is a one-time charge of $10,000 per industrial process appliance containing 50 lb or more of a CFC or HCFC, as well as stepped-up record keeping and accountability.

The agreement pushes for the phaseout of EPA-designated Class I refrigerants. CFCs, for example, have to be completely eliminated by July 15, 2003.

And, according to the American Bakers Association (ABA), there is motivation to do away with so-called Class II refrigerants such as R-22. “Appliances using Class II substances…must be audited. Owners may elect to convert to nonozone-depleting substances to avoid paying fees for higher leaks,” the association stated.

Dr. Anne Giesecke, ABA’s vice president for environmental activities, said the industry is in discussion with refrigerant manufacturers and suppliers about the use of HFCs. In the baking industry, refrigerants are used in cooling systems needed to maintain temperatures in applications such as pre-paring dough, she said. Primary- and secondary-loop technology is employed. Also, she said some manufacturers that prepare frozen dough use ammonia systems.

Publication date: 04/01/2002