Twists & Turns

by Katie Lee

After years of complicated phaseouts and alternatives, today is a turning point for your heating and cooling equipment.

By Elizabeth Ortlieb

New regulations are impacting your heating and cooling equipment. In fact, some new requirements are already in effect, and other requirements will be soon.

Yes, from new use conditions for certain flammable hydrocarbon refrigerants to new recordkeeping requirements for many types of refrigerants, 2018, 2019 and 2020 are busy years for the industry. Owners, operators, managers, and technicians must pay heed to the environmental, health and safety aspects of HVAC/R.

Phaseout deadlines are looming; the next generation of refrigerants are gaining ground; and numerous compliance dates are hanging overhead. Not to mention, some new systems have both flammable insulations that limit density of use in an area, and soon they will contain small but measurable quantities of flammable refrigerants.

The world of refrigerants is as fast-changing and complex as ever, and those who do not pay attention are taking a big risk. It’s a turning point for your heating and cooling equipment, and it’s best to be in the know.

Looming Phaseouts & Expanding Alternatives

It’s a known fact that the most common refrigerants in use today are environmentally harmful.

Specifically, hydrochlorofluorocarbon (HCFC) refrigerants (the second generation of refrigerants) are ozone depleting and have a high global warming potential (high-GWP). Importantly, they are under an internationally supported phaseout.

For example, HCFC-22 (or R-22) is one of the most popular HCFC refrigerants in use, and it will reach its final phaseout on January 1, 2020. On that date, new or imported R-22 will no longer be allowed in the United States.

To complicate matters further, hydrofluorocarbon (HFC) refrigerants (the third generation of refrigerants) — once thought to be a good substitute for HCFCs — have also come under increased international scrutiny for their high-GWP, which explains the growing support for the Kigali Amendment. They, too, are now slated for phaseout.

As you can see, system owners and operators are looking for long-term options, and that’s why many of them are turning to next-generation refrigerants, such as hydrofluoroolefin (HFO) (fifth generation) and natural (fourth generation) refrigerants.

And one group of natural refrigerants in particular has been gaining ground: hydrocarbons.

Spotlight on Hydrocarbon Refrigerants

Just recently, on August 8, 2018, the U.S. Environmental Protection Agency (EPA)’s Significant New Alternatives Policy (SNAP) program published a new rule — namely, SNAP Rule 22 — that puts flammable hydrocarbon refrigerants in the spotlight.

SNAP Rule 22 changes the use conditions for three hydrocarbon refrigerants in new domestic fridges and freezers: isobutane (R-600a), propane (R-290) and R-441A. Notably, the rule increases the charge size limit for these refrigerants from 57 grams (2.01 oz) to 150 grams (5.29 oz).

For much of the HVAC/R world, this rule had been long anticipated and now welcomed with open arms. Because, no doubt, it makes the move to environmentally friendly refrigerants much easier.

However, the fact that these refrigerants have flammable properties changes the game. It means new service requirements and potential flammability hazards that you need to be aware of. Even more, the health and safety aspects of HVAC/R will become a larger concern.

Maintaining Your HVAC/R Equipment Isn’t That Easy

As you can see, we’re at a turning point with heating and cooling equipment, and this makes servicing your HVAC/R equipment not as easy. Some refrigerants are going away, while many others have new requirements.

For instance, just this year, on January 1, 2018, a new disposal recordkeeping requirement per the EPA 608 Update took effect for mid-sized appliances containing controlled refrigerants (e.g., HCFCs, HFCs, HFOs, etc.). Before you dispose of these appliances, you now must keep records of proper refrigerant disposal.

The point here is, you can’t just purchase a piece of equipment and forget about it from that point on. An “out of sight, out of mind” approach to refrigerants won’t work, so don’t act or make a decision hastily.

Now regulations require you to know when refrigerant is used, what kind is used, and where it goes at the end of its life. Plus, new service actions are required with limits on how much refrigerant is used.

So, just keep in mind that some systems might not be repairable and may need to be replaced before their useful life has elapsed; new records must be kept; and flammable refrigerants will require attention to safety responsibilities.

Ultimately, no matter which refrigerants you choose, one thing is for certain: you must follow best practices and regulatory requirements throughout the life cycle. It’s all part of the turn.


— With an extensive background in public affairs and communications, Elizabeth Ortlieb serves as the policy & content manager at Trakref, where she tracks HVAC/R policy trends and provides updates to multi-level stakeholders. For more information, visit

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