Preparing for the Phase Out of R-22 (HCFC) Refrigerants

Cap on R-22 Will Fall Short by 20% of the Demand in 2010

R-22 is the most widely used refrigerant in the world. Since the 1940's R-22 has been the refrigerant gas that we use in central air-conditioning (AC) systems at home and work. It is efficient, non-toxic and easy to use. It's difficult to grasp how important R-22 is to our society.

R-22 based air-conditioning was the catalyst of southern United States growth. Without R-22 and other refrigerant gases farmers and grocers wouldn't be able to provide their product to such a diverse marketplace across the entire U.S.

R-22 is an HCFC class refrigerant containing chlorine giving it the potential to damage the ozone and therefore has been targeted since the 1990's for eventual phase out by the Montreal Protocol, an international treaty.

Most air-conditioning manufacturers introduced non-ozone depleting products that utilize non ozone depleting R-410A. Although the adoption by contractors and consumers has been slow for R-410A, the upside is that R-410A is more efficient and is chlorine free.

Phase Out of R-22 Refrigerant Gas

In 2007 and 2008, the U.S. Environmental Protection Agency (EPA) published an industry model of the expected HCFC market size and the related demand for R-22. The current and new demand for R-22 refrigerant gas will ever increase as new leaks and service events need to top off the gas. This will increase the shortage of available R-22 in the marketplace.

Based on the market demand model crafted by the EPA and published in the Federal Register, two proposed rules for meeting the 2010 phase-down called for by the Montreal Protocol of R-22 and other HCFC refrigerants emerged.

The first rule regards the 2010 allocation of production and import rights of R-22. There is a SIGNIFICANT phase down of HCFCs R-22 and other damaging refrigerant gasses in the immediate future.

The second proposal is on the ban on production, import, and sale of R-22 in new equipment post January 1st, 2010.

As of writing this article, organizations and the EPA are in a comment period where changes can be proposed and or adopted in the emerging rules. In any way you wish to look at it, these rules regarding the phase out of R-22 refrigerant gas will become effective January 1st, 2010.

Key Points of the Proposed R-22 Phase Out Legislation

By law written into the EPA legislation, HCFCs are scheduled to be phased down in 2010 by 75% of the baseline cap (set in the 1990's).

On January 1st, 2010, it will be illegal to import, produce, or sell R-22 for use in new equipment or pre-charged in new equipment of any kind. Packing a substantial punch, the R-22 phase out rules are not fully understood by many businesses operating AC/HVAC equipment.

There is an allowance (loophole) that allows equipment manufactured after 2009 to be charged with reclaimed refrigerant. The rules regarding smaller systems, say of 50 pounds of refrigerant gas or less, will also be implemented and tightened to help damaging the environment.

The EPA clarified the AC/HVAC charging rules to allow for R-22 equipment, such as window air conditioning units, manufactured before January 1st, 2010 to be sold after January 1st, 2010. This revision occurred after a lengthy comment period from equipment manufacturers, owners of AC/HVAC systems, industry groups, and distributors. This gives some breathing room for smaller businesses and home owners but it is well known that regulations regarding refrigerant gases will continue to be ratcheted down.

What the Phase Out of R-22 Means to Your Organization

Under the phase out rules for R-22 production and import, all allocations across the refrigerant industry will go from about 312 million pounds to about 110 million pounds, a 64.8% reduction across all shapes and sizes of organizations. This is the first time that R-22 has been reduced in anyway and in such a pervasive manner.

In 2003, R-22 was allocated to 100% of the allowable cap and the step down was covered by the phase out of foam blowing agents. The world and the United States in particular is about to embark on an era where R-22 refrigerant gas will be restricted and capped. This will have a far greater impact on day-to-day operations across the entire economy.

What Your Organization Should Do to Protect Against the R-22 Phase Out Risk

Keep accurate maintenance records and understand your R-22 usage and reporting requirements, and ongoing needs. This means tracking your refrigerant gases down to the individual pound across your entire organization. It is critical to track R-22 but many other refrigerant gases are regulated due to their harmful effects on the environment.

Used refrigerant must be reclaimed and re-certified by an EPA approved reclaimer before it can be sold to a third party. It can however be re-used in your own equipment without re-certification. It is best to start as soon as possible to truly understand and manage your refrigerants as they will and are turning into vital assets that should not be vented or just given away during service events.

The EPA requires leaks to be fixed within 30 days and can impose fines of up to $32,500 per day/ per unit for excessive leaks. Ignorance of these regulations is not an excuse. They were written and passed many years ago. To effect change and to get proper attention, the EPA will address large fines and legal compliance requirements against any organization that does not comply. To protect your organization, we suggest you buy virgin R-22 from certified wholesalers; fines of up to $300,000 per 30 pound cylinder are possible for illegally imported product.

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Ted Gartland, co-author of this article, has experience working with the EPA, food retailers, and refrigerant manufacturers. He offers refrigerant compliance and consulting services. The EPA proposals and a detailed summary of the R-22 phase out are located at www.CarbonIssues.com