Vehicle Service Industry Faces Prospect of New A/C Refrigerant

By Aaron Lowe

Summer is here and for the aftermarket that means the annual rebirth of vehicle air conditioning service. However, regulatory actions being contemplated by the Environmental Protection Agency (EPA) could mean future changes for companies that produce, sell and install vehicle air conditioning products.

A key ingredient in air conditioning is the refrigerant, which for the past several years has been R-134a. R-12, also known as Freon, was the refrigerant of choice until the early ’90s, when concerns about ozone depletion led to its elimination under the 1990 Clean Air Act Amendments. R-134a was considered a good substitute, since it required few changes to vehicle air conditioning systems both on new vehicles and those already on the road. During the 1990s, as the supply of R-12 diminished and increased in cost, many motorists who had older vehicles chose to retrofit their cars with R-134a rather than pay the high price for R-12.

While it seems like the changeover to 134a just occurred, growing concerns regarding climate change could lead to another refrigerant change in the not-too-distant future. The reason for the upcoming change is that while R-134a does not impact stratospheric ozone, it does have a sizable global warming potential (GWP). GWP is measured on a relative scale, with carbon dioxide having a GWP of one. R-134a has a GWP of 1,410, making it a substance of great concern for environmentalists and regulators.

Notwithstanding the concern, finding a substitute refrigerant that has a low GWP, requires a minimum of vehicle design changes, and does not have adverse health effects or flammability concerns has not been easy. However, Honeywell and DuPont have developed a refrigerant called 1234yf which appears to have the potential to replace R-134a if it is approved by EPA for use on vehicle air conditioning systems. 1234yf has a GWP of four and has passed government required toxicology tests. Although it has a flammability potential, that potential appears low enough to permit its use.

On October 19th, the EPA proposed to approve 1234yf as a substitute refrigerant under the Significant New Alternatives Policy (SNAP). SNAP was created by the agency in the 1990s to evaluate new substances that are developed to replace ozone depleting substances. In approving a substitute, the EPA looks at toxicity, flammability, potential for occupational and general population exposure, and environmental effects. However, the EPA did impose use conditions including requiring the vehicle manufacturers to incorporate strategies that minimize leaks into the passenger and engine compartments. Car manufacturers in comments to the agency took issues with many of the requirements, citing that the risks relative to flammability were extremely remote if not impossible. It remains to be seen whether the Agency will modify its requirements when the final rule is issued.

While the EPA appears close to approving 1234yf for use on new vehicles, the agency has yet to announce any new servicing standards for the new refrigerant, although they expect to do so in the not-too-distant future. Further, as part of its approval process, the EPA is proposing to only permit the use of the new refrigerant on new vehicles. If this is approved, the new rules would not allow the retrofitting of vehicles already on the road with the new refrigerant. Further, even if retrofitting is ultimately allowed by the EPA, the engineering strategies that are in the SNAP proposal could make the retrofitting of a current R-134a system for 1234yf cost prohibitive.

Also of concern to the retail aftermarket, the EPA is currently proposing a Significant New Use Rule (SNUR) under the Toxic Substances Control Act (TSCA) for the new refrigerant. As part of TSCA, the PA is required to make a determination as to whether 1234yf is safe, since it is a new substance that was not previously on the market, and to determine if there are any use restrictions based on toxicity concerns. Under the SNUR for 1234yf that was proposed on April 2, 2010, companies would be prohibited from selling the new refrigerant in under 20 pound containers and to only certified individuals. The reasoning is that its use outside of professional service bays may cause serious health effects for do-it-yourselfers due to toxicity concerns. This action is being opposed by AAIA and the Automotive Refrigeration Products Institute (ARPI) based on the fact that most of the data appears to show that 1234yf poses no health risk to either do-it-yourselfers or passengers.

The EPA is likely to issue final rules for both the SNAP and SNUR sometime this summer, making it critical that the repair industry keep a close eye on actions in Washington as they are dealing with the expected summer A/C business.

In order to find more information and to follow the latest development, visit: www.staycoolusa.org

AARON LOWE is vice president of Government Affairs for the Automotive Aftermarket Industry Association. For more information on government affairs initiatives, visit: www.aftermarket.org