DEFINITIONS

Appliance: Any device that contains and uses a refrigerant and that is used for household or commercial purposes, including any air conditioner, refrigerator, chiller, or freezer. EPA interprets this definition to include all air-conditioning and refrigeration equipment except units designed and used exclusively for military purposes.

Azeotrope: A blend of two or more components whose equilibrium vapor phase and liquid phase compositions are the same at a given pressure. These refrigerants are given a 500 series ASHRAE designation and behave like a single refrigerant. They can be charged as a liquid or vapor.

CFC-12: dichlorodifluoromethane, (R-12).

Class I Refrigerant: CFC refrigerants such as R-12.

Class II Refrigerant: HCFC refrigerants such as R-22 and R-124.

Compound: A substance formed by a union of two or more elements in a definite proportion by weight.

Disposal: The process leading to and including any of the following:

Fractionation: The separation of a liquid mixture into separate parts by the preferential evaporation of the more volatile component.

Halocarbon: A halogenated hydrocarbon containing one or more of the three halogens: fluorine, chlorine, and bromine. Hydrogen may or may not be present.

HCFC-22: chlorodifluoromethane, (R-22).

HFC-134a: 1,1,1,2,-tetrafluoroethane, (R-134a).

High-Pressure Appliance: (prior to March 12, 2004, referred to by the EPA as higher-pressure appliance) An appliance that uses a refrigerant with a liquid phase saturation pressure between 170 psia and 355 psia at 104°F. This definition includes but is not limited to appliances using R-410A, R-22, R-401B, R-402A/B, R-404A, R-407A/B/C, R-408, R-409, R-411A/B, R-502 and R-507A.

SECTION I: Refrigerants Past, Present, and Future

MOLECULAR STRUCTURE AND TERMINOLOGY

Except for ammonia and a few other substances, most refrigerants currently in use are compounds containing carbon, fluorine, usually chlorine, and sometimes hydrogen, bromine, or iodine. When a refrigerant is referred to as a "CFC", the refrigerant contains Chlorine, Fluorine, and Carbon. When a refrigerant is referred to as a "HCFC", the refrigerant contains Hydrogen, Chlorine, Fluorine, and Carbon. When a refrigerant is referred to as a "HFC", the refrigerant contains Hydrogen, Fluorine, and Carbon. When bromine is present in place of all or part of the chlorine, the capital letter "B" after the designation for the parent compound shows the presence of the bromine (Br), for example "R-13B1". Compounds containing bromine are sometimes referred to as "BFCs" if they contain Bromine, Fluorine, and Carbon (no chlorine). That is, R-13B1 is also known as BFC-13B1. Similarly a compound such as R-30B1, which contains Hydrogen, Bromine, Chlorine, Fluorine, and Carbon, is sometimes referred to as a "HBCFC", so R-30B1 is HBCFC-30B1.

CFCs

The refrigerants heard about the most are the chlorofluorocarbons (CFCs). As the name says, these refrigerants consist of chlorine, fluorine, and carbon, thus the abbreviation "CFC". Since they contain no hydrogen, CFCs are chemically very stable, even when released into the atmosphere, but since they contain chlorine, CFCs are damaging to the ozone layer high above the Earth's surface. The ozone layer shields the Earth from excessive ultraviolet solar radiation.

The combination of these two characteristics gives CFC refrigerants a high ozone-depletion potential (ODP), and has made these refrigerants the target of legislation that has reduced their availability and use. Thus, manufacture of CFC refrigerants was discontinued after December 31, 1995. R-12 is a CFC and often referred to as CFC-12.

HCFCs

A second category of refrigerants which are currently available are the hydrochloro-fluorocarbons (HCFCs). Although they contain chlorine which is damaging to the ozone layer, they also contain hydrogen which makes them chemically less stable when they enter the atmosphere. These refrigerants decompose when released in the lower atmosphere so very little ever reaches the ozone layer. HCFCs, therefore, have a lower ozone-depletion potential. HCFC-22 also know as R-22 has been in widespread use for many years. Most residential and small commercial air conditioning systems use HCFC-22.

HFCs

Hydrofluorocarbon (HFC) refrigerants contain no chlorine at all. Although these refrigerants have an ozone-depletion potential of zero, they probably still contribute to the global warming problem. Two new HFC's that are replacing CFC-12 and HCFC-22 are HFC-134a (1,1,1,2-Tetrafluoroethane CF₃CH₂F) and HFC-410A (HFC-32 &HFC-125). Mandatory recovery is required for all refrigerants (including HFC's) before opening or disposing of appliances, because of their potential to cause global warming. No "drop-in" substitute refrigerants are available for any equipment category.

THE REFRIGERANT DESIGNATION NUMBERING SYSTEM

Because the chemical names of typical refrigerants are long and complex, DuPont developed a method of referring to refrigerants by number . The DuPont numbering system was released for general use in 1956 and has become an industry standard. A complete discussion of the number designation and safety classification of the refrigerants is presented in ASHRAE Standard 34-1992.

Briefly, the method of designating a refrigerant by number is as follows. (Note that the numbering system begins on the right.)

First digit on the right	= Number of fluorine atoms
Second digit from the right	= Number of hydrogen atoms plus one
Third digit from the right	= Number of carbon atoms minus one    (not used when equal to zero)
Fourth digit from the right	= Number of unsaturated carbon-carbon bonds in the compound    (not used when equal to zero)

When bromine is present in place of all or part of the chlorine, the same numbering rules apply except that the capital letter "B" after the designation for the parent compound shows the presence of the bromine (Br). The number following the letter "B" shows the number of Bromine atoms present.

The lower-case letter that follows the refrigeration designation refers to the form of the molecule when different forms (isomers) are possible, with the most symmetrical form indicated by the number alone. As the form becomes more and more asymmetrical, the letters a, b, and c (lower case) are appended (for example, HFC-134a).

If all of the carbon bonds are not occupied by fluorine or hydrogen atoms, the remainder are attached to chlorine.

Because the structure of a refrigerant, whether CFC, HCFC, or HFC, has become so important, it is often referred to in this way (for example, R-12 is CFC-12; R-22 is HCFC-22; R-134a is HFC-134a.) Thus, their chemical structure and their relative ozone-depletion potential are highlighted.

Example 1. CHClF₂

The refrigerant in Example 1 is designated HCFC-22. Since carbon has four bonds and the total of F and H = 3, there is one Cl atom.

Example 2. CCl₂FCClF₂

The refrigerant in Example 2 is designated CFC-113. Since two carbon atoms connected together have six bonds remaining and the total of F and H = 3, there are three Cl atoms present.

Example 3. The Designation of Refrigeration Isomers

REPLACEMENT REFRIGERANTS

EPA concerns about depletion of the Earth's protective stratospheric ozone layer and the effect of CFC on this depletion have resulted in a halt in CFC production since December 31, 1995. According to the EPA, recent ozone depletion studies indicate that the current situation is far worse than originally thought. HCFC refrigerants such as R-22 are currently scheduled for phase-out by the year 2030. However, this too will probably be accelerated before the year 2030 is actually reached. Azeotropes such as R-502 are, of course, also affected.

As stated in the last section, mixtures or blends of refrigerants can exhibit a distinct boiling point or they can exhibit a boiling range. When a refrigerant mixture exhibits a distinct boiling point, that is it behaves as a single "new" refrigerant, it is designated as an azeotropic blend and is given a 500 series ASHRAE designation. When the refrigerant mixture has a boiling range it is referred to as a non-azeotropic or zeotropic refrigerant and is given a 400 series ASHRAE designation.

Key considerations for any new refrigerant are chemical stability in the system, toxicity, flammability, thermal characteristics, efficiency, ease of detection when searching for leaks, environmental effects, compatibility with system materials, compatibility with lubricants, and cost. In general, HCFC-123 is intended to replace CFC-11, and HFC-134a has replaced CFC-12 in most applications and HFC-410A is replacing HCFC-22 in many applications.

HFCs such as R-134a do not lead to ozone depletion but do contribute to global warming due to the greenhouse effect. So refrigerant recovery and recycling are here to stay regardless of the new refrigerants developed. Recycling also makes sense economically because of the cost of the new refrigerants and taxes on the more traditional refrigerants.

Briefly, for the short term, heavy reliance will probably be placed on continued use of HCFC-22 until it is no longer allowed. As an HCFC, R-22 has only a small fraction of the ability of the CFC refrigerant to destroy stratospheric ozone. However, R-22 does contribute to global warming. Mandatory recovery is required for all refrigerants (including HFCs) before opening or disposing of appliances, because of their potential to cause global warming.

Manufacturers are beginning to offer HFC-410A air conditioning and heat pump systems as an alternative to HCFC-22 units. The EPA has established the phase out of the HCFC-22 with no production or importing beginning in 2020. However, manufacturers of air conditioning equipment must phase out the use of HCFC-22 in new equipment by January 1, 2010. In general, existing R-22 systems will probably be converted to R-407C, however new air conditioning equipment is being designed to operate on R-410A. Both R-407C and R-410A are non-azeotropic HFC refrigerant blends. Non-azeotropic blends (400 series) means that they experience a temperature glide during evaporation and condensation. In contract, a pure refrigerant or an azeotropic (500 series) refrigerant blend has a single boiling point temperature at a given pressure. However, as discussed below R-410A is a near azeotropic refrigerant.

No "drop-in" substitute refrigerants are available for any equipment category. This means that some changes in a system's equipment or materials of construction are always necessary when converting the equipment to using a replacement refrigerant. An existing refrigerant cannot simply be removed from a system and replaced with another. Usually the changes involve replacement of incompatible seals and changes in lubricant. Filter/dryers, compressors, and seals that are compatible with CFCs, HCFCs, and HFCs have been developed.

DISPOSABLE REFRIGERANT CYLINDERS

Size and Color Codes

New virgin refrigerant for use by air conditioning and refrigeration service personnel are usually packaged in disposable containers. Disposables are manufactured in three sizes: 15-, 30-, and 50-pound capacities and should never be refilled. New disposable containers use a check valve and cannot be refilled. Refrigerant manufacturers voluntarily color code cylinders for their chlorofluorocarbon products. Table 1 lists the color-coding for common chlorofluorocarbon refrigerants; however, the shade of color may vary somewhat among manufacturers.

Regulations

Disposable cylinders are manufactured to specifications established by the U.S. Department of Transportation (D.O.T). The D.O.T. has regulatory authority over all hazardous materials in commercial transportation.

Hot-weather recovery operations can result in very high storage-tank pressures and therefore disposable cylinders should never be refilled or used as a recovery tank. Rust, dents, and other damage can significantly reduce the burst pressure of disposable cylinders.

Transportation of refilled D.O.T. 39 cylinders is illegal and subject to a penalty of a fine up to $25,000 and five years imprisonment. The use of a refilled D.O.T. 39 cylinder also violates OSHA workplace regulations and may violate state laws.

Safety

Every cylinder is equipped with a safety-relief device that will vent pressure from the cylinder before it reaches the rupture point. Cylinders can become over-pressurized for several reasons. However, the primary cause is overheating. When a cylinder ruptures, the pressure drop causes the liquid refrigerant to flash into vapor and sustains the explosive behavior of the rupture until all the liquid is vaporized. The rupture of a refrigerant cylinder containing liquid refrigerant that flashes into vapor is far worse than the rupture of a compressed-air cylinder under the same pressure.

If a refrigerant cylinder reaches a full-of-liquid (no vapor space) condition, the internal pressure rises very rapidly under minor increases in temperature. If the safety valve is not able to vent this rapid increase in pressure, the cylinder will explode. Safety valves are very important. Never tamper with a cylinder safety device.

Hazards of Reuse

Disposable cylinders are manufactured from steel. Rust can eventually weaken the cylinder to the point where the cylinder wall can no longer contain the compressed refrigerant. Consequently, cylinders must be stored and transported in dry environments. Cylinders exhibiting extreme rust should be emptied of contents and properly discarded.

Disposal

Disposable cylinders should be emptied of all contents using a refrigerant recovery device. Once emptied the cylinder's valve should be opened to allow air to enter, and the cylinder should be punctured with the valve still open (rendered useless). Used cylinders can be recycled with other scrap metal. Never leave used cylinders with any residual refrigerant either outdoors or at a job site. The internal pressure of a cylinder with one ounce of liquid refrigerant is exactly the same as a full cylinder. An abandoned cylinder will eventually deteriorate and can explode if the cylinder wall weakens. Never refill a disposable cylinder.

REFILLABLE CYLINDERS

Refillable cylinders, also referred to as "recovery cylinders" or "recovery tanks", are now available for the transportation of refrigerants used in the air conditioning and refrigeration industry. These refillable cylinders are used for the same refrigerants as the disposable cylinders. In addition to disposable and returnable cylinders, refillables also are regulated in their design, fabrication, and testing by the D.O.T. for use in transportation of refrigerants.

Recovery cylinders are painted yellow in the shoulder area and 12 inches down the side; the manufacturer paints the remainder of the cylinder body gray.

D.O.T. Requirements

Refillable cylinders satisfy the requirements of either 4BA or 4BW specifications, Ref. 49 CFR 178.51 and 49 CFR 178.61, respectively. The 4BA cylinder is comprised of two deep-drawn carbon-steel heads welded together with one girth seam; the 4BW cylinder is comprised of two separate heads on opposite ends of a center cylindrical section.

The 4BA cylinders are generally sized for refrigerant capacities of 50 lb. or less, with the most widely used sizes being 15-lb., 30-lb., 37-lb., and 50-lb., respectively. The design pressure is typically 340 psig for the 15-lb. and 30-lb. unit, 302 psig for the 37-lb. unit, and 400 psig for the 50-lb. unit. Newer tanks which can accommodate R-410A must be rated for at least 400 psig. Recovery tanks rated for 400 psig are available in 15, 30, and 50 pound sizes but not every recovery tank is rated for these higher pressures. Be careful, and read the nameplate, only use recovery tanks rated for at least 400 psig with R-410A.

WARNING: According to the American Society of Mechanical Engineers Pressure Vessel Code, the pressure rating must be 285 psig or higher for R-407C and 400 psig or higher for R-410A. Do not use any storage or recovery tank with a maximum pressure rating less than 400 psig for R-410A. Recovery tanks for R-410A should be specified as DOT 4BA400 or 4BW400.

Cylinder Re-testing

The use of various refrigerants in cylinders that are exposed to the environment is reason for concern. Although the interior of these cylinders must be void of moisture, the exterior cannot avoid it. Thus, corrosion can and does occur, as well as damage due to mishandling. These are a few of the reasons why cylinders must be re-tested at five-year intervals.

The valves should be examined regularly, especially the relief valve. Check to be sure that nothing is obstructing the relief valve and that no visual deterioration or damage has occurred to the cylinder. If any damage is visible, empty the cylinder and have the tank repaired. NEVER use a cylinder with a faulty pressure-relief valve or with obvious structural impairments.

REFRIGERANT SAFETY

ASHRAE Safety Classification of Refrigerants

As stated earlier in this section, the ASHRAE standard on Refrigerant Number Designation also includes a Safety Classification of Refrigerants. Specific product safety information is always available from the manufacturer, and by law a Material Safety Data Sheet (MSDS) must accompany the delivery of all chemicals. The newer ASHRAE 34a-1992 standard includes two alphanumeric characters. The capital letter (either A-Non-Toxic or B-Toxic) indicates the toxicity and the numeral (1-non-flammable, 2-slightly-flammable, 3-highly-flammable) denotes the flammability.

Health Hazards

Skin or eye contact with fluorocarbon refrigerants can result in irritation and frostbite. Although the toxicity of traditional fluorocarbon refrigerants is low (due to their chemical stability), the possibility of injury or death always exists in unusual situations and if they are deliberately misused. The vapors are several times heavier than air. Good ventilation must be provided in areas where high concentration of the heavy vapors might accumulate and exclude oxygen. Inhalation of concentrated refrigerant vapor is dangerous and can be fatal. Exposure to levels of fluorocarbons above the recommended exposure levels can result in loss of concentration and drowsiness. Cases of fatal cardiac arrhythmia have been reported in humans that were accidentally exposed to high levels. The exposure levels for some of the new replacement refrigerants may be lower than for those with which you may be familiar. Less-stable compounds can break down more easily and can potentially form harmful substances within the body. Treat replacement refrigerants with care!

First Aid

If refrigerant vapor has been inhaled, remove the victim to fresh air. If the victim is not breathing, give artificial respiration. If breathing is difficult, give oxygen. Avoid stimulants. Do not give adrenaline (epinephrine) because this can complicate possible effects on the heart. Contact a physician.

In the case of eye contact, flush eyes promptly with plenty of water for at least 15 minutes. Contact a physician. Flush exposed skin with warm water (not hot) or use other means to warm the skin slowly.

Other Hazards

Most halogenated compounds will decompose at high temperatures such as those associated with gas flames or electric heaters. The chemicals that result under these circumstances always include hydrofluoric acid. If the compound contains chlorine, hydrochloric acid will also be formed, and if a source of water (or oxygen) is present, a smaller amount of phosgene will be formed. Fortunately, the halogen acids have a very sharp, stinging effect on the nose and can be detected by odor at concentrations below their toxic level. These acids serve as a warning that decomposition has occurred. If they are detected, the area should be evacuated until the air has been cleared of decomposition products. Some replacement refrigerants have lower exposure limits, so read the manufacturer's warnings carefully and take the precautions seriously.

REVIEW TOPICS

- Chlorofluorocarbon (CFC) refrigerants are so named because they contain the elements Chlorine, Fluorine, and Carbon.

- CFCs have the highest ozone depletion potential (ODP) and are the most harmful to stratospheric ozone.

- Hydrochlorofluorocarbon (HCFC) refrigerants contain Hydrogen, Chlorine, Fluorine, and Carbon.

- Hydrofluorocarbon (HFC) refrigerants contain Hydrogen, Fluorine, and Carbon. R-134a, also known as HFC-134a, a chlorine-free refrigerant.

- HFC refrigerants cause no harm to stratospheric ozone; they have a zero ODP. They do however contribute to global warming (like any refrigerant) and cannot be vented.

- Oils that will be used with most HFC-134a refrigeration and HFC-410A air conditioning applications are ester-based synthetic (POE) oils.

- The synthetic lubricant presently used with ternary blends is alkylbenzene.

- Ester-based synthetic oils cannot be mixed with other oils.

- A non-azeotropic (or azeotrope) refrigerant blend, sometimes referred to simply as a blend refrigerant, has a range of boiling points or condensing points throughout the evaporator and condenser, respectively; the terms used to describe this are "temperature glide" or "gliding-temperature."

- A compound pressure gauge for the low side of a refrigeration system measures pressure in psig and vacuum in inches of mercury.

- Refrigerant will travel to a compressor's crankcase because of the difference between the oil and refrigerant's vapor pressure.

- A binary blend is a two-part mixture and a ternary blend is a three-part mixture.

- When transporting cylinders containing used refrigerant, the D.O.T. requires that you attach D.O.T. classification tags.

- On a typical gauge manifold set, the high pressure gauge is color coded red and the low pressure gauge is color coded blue.

- The high pressure gauge on a service manifold set has a continuous scale, usually calibrated to read from 0 to 500 psig. This does not mean the gauge set is actually rated for use up to 500 psia. Typical ratings on older gauge sets and/or hoses is only 340 psig. When using R-410A you must use a gauge set rated for at least 800 psig (with a 4,000 psig burst pressure on the manifold and the hoses).

- Containers designated "refillable" by DOT must be used to transport recovered pressurized refrigerant to meet safety requirements.

SECTION II: Stratospheric Ozone Depletion

Stratospheric Ozone

Ozone is a gas, slightly bluish in color, with a pungent odor. It consists of three atoms of oxygen in each molecule. The oxygen we breathe contains two atoms in each molecule. Chemically, oxygen is O2, and ozone is O3. The "ozone layer" consists of ozone in the stratosphere, high above the Earth at an altitude of between 7 and 28 miles. It is formed by ultraviolet light (UV) from the sun acting on oxygen molecules. The ozone layer absorbs and scatters ultraviolet light from the sun, thus preventing harmful amounts of ultraviolet light from reaching the Earth. For this reason, it is often referred to as the Ozone Shield or the Earth's Protective Shield.

Atmospheric Ozone

Ozone is also found at times in the lower atmosphere where we breathe it. Here it is caused by ultraviolet radiation from the sun acting on smog and air pollutants on hot summer days. This situation should not be confused with the protective ozone layer in the stratosphere. Ozone at ground level is a harmful pollutant; in the stratosphere it is a protective shield.

Depletion of Stratospheric Ozone

In June 1974, Professor Sherwood Rowland and Dr. Mario Molina of the Department of Chemistry at the University of California at Irvine first proposed the theory that certain chlorine-containing compounds could pose a threat to the ozone layer above the Earth. The Rowland-Molina theory states that CFCs would ultimately cause damage to the ozone layer, which protects the Earth from harmful levels of ultraviolet radiation from the sun. What follows is a summary of the current theory held by the EPA.

Refrigerants that contain chlorine but not hydrogen are so stable that they do not break down in the lower atmosphere not even one hundred years or more after being released. These chemicals gradually float up to the stratosphere, where the chlorine or bromine reacts with ozone, causing it to change back to oxygen.

The "Ozone Hole" is a thinning in the ozone layer over Antarctica and occurs during the Antarctic spring season (autumn in the Northern Hemisphere). It occurs over the Antarctic continent due to its unique climate. Powerful winds encircle Antarctica during its winter, isolating the continent from warmer winds that would otherwise migrate from lower latitudes on the Earth's surface, and the continent is in darkness during the winter. These two effects combine to produce the coldest temperatures on Earth, colder than the Arctic.

The stratosphere is normally too dry to form clouds, except at the bitterly cold temperatures reached during the Antarctic winter. At these frigid temperatures, clouds of ice and nitric acid, called "polar stratospheric clouds" (PSCs), form in the stratosphere over the continent of Antarctica. Chemical reactions take place on the surfaces of these clouds, converting chlorine and bromine from forms that do not react with ozone to other, less stable forms that readily break up in the presence of sunlight and destroy ozone.

Both cold temperatures and sunlight are critical to the ozone depletion process. So in the spring, when the sun again rises and when the PSCs are still present, the Antarctic ozone hole is found. As the sun warms the region in the spring, the clouds dissipate.

This area is being carefully monitored for the degree to which the ozone thins because it has been found to lead to ozone depletion in other parts of the world as well. Significantly reduced ozone levels were detected in 1985, and high chlorine levels were found in 1986. Since that time, aircraft flights through the stratospheric ozone layer and ground-based instruments have indicated that the ozone depletion problem may be more serious than initially thought.

When ozone depletion occurs, more UV radiation penetrates to the Earth's surface. Moreover, because of the long atmospheric lifetimes of CFCs, it will take many decades for the ozone layer to return to past concentrations. As stated earlier, bromine-containing compounds, which are contained in typical Halon fire extinguishers, react the same way as chloride atoms in destroying the ozone. In the years since the ozone-depletion theory was first proposed, substantial scientific research has supported the general concern that an increased concentration of chlorine and bromine in the stratosphere poses substantial risks of ozone depletion, which results in harm to both human health and the environment. The EPA states that each chlorine atom has the ability to destroy 100,000 ozone molecules in the stratosphere.

The CFC refrigerants and the halons have been assigned factors that represent their relative ability to destroy stratospheric ozone, called the Ozone Depletion Factor, or Ozone Depletion Potential (ODP). This scale is based on CFC-11 having been assigned a factor of 1. CFC-12 has an ODP of 1, HCFC-22 has an ODP of 0.05, and HFC-134a has an ODP of 0.Note that the bromine-containing halons have factors many times those of the CFC refrigerants.

HEALTH AND ENVIRONMENTAL EFFECTS

Since it shields the Earth from much of the damaging part of the Sun's radiation, the ozone layer is a critical resource safeguarding life on this planet. Should the ozone layer be depleted, more of the Sun's damaging rays would penetrate to the Earth's surface. Some scientists have claimed that each 1% depletion of ozone increases exposure to damaging ultraviolet radiation by 1.5-2%. EPA's assessment of the risks from ozone depletion focus on the following areas:

   - Increase in skin cancers
   - Suppression of the human immune response system
   - Increase in cataracts
   - Damage to crops
   - Damage to aquatic organisms
   - Increases in ground-level ozone
   - Increased global warming

GLOBAL NATURE OF THE PROBLEM

Stratospheric ozone protection is a global problem. CFCs and halons are used in many nations, and because of their long atmospheric lifetimes, they become widely dispersed over time. As a result, the release of these chemicals in one country will adversely affect the stratosphere above other countries and therefore the health and welfare of their citizens. To protect the ozone layer from damage that may be caused by CFCs and halons, an international solution is critical.

REVIEW TOPICS

- Ozone in the stratosphere above the Earth consists of molecules containing 3 oxygen atoms (O3).

- Chlorine and bromine in refrigerants cause stratospheric ozone depletion.

- The EPA states that each chlorine atom has the ability to destroy 100,000 ozone molecules in the stratosphere.

- CFCs are chemically very stable; they do not dissolve or break-down in water (so they are not removed by rain). Because of this chemical stability, CFCs are able to reach the stratosphere.

- CFCs have the highest ozone depletion potential (ODP) and are the most harmful to stratospheric ozone.

- R-134a, also known as HFC-134a, is a chlorine-free refrigerant.

- HFC fluorocarbon refrigerants cause no harm to stratospheric ozone, and have a zero ODP.

- The ozone layer protects the Earth from ultraviolet radiation from the sun. Skin cancer, increased cataracts, and damage to crops are just some of the results of damage to the Earth's ozone layer.

- Actual measurements of CFCs in air samples from the stratosphere are positive evidence that CFCs are in the stratosphere.

- Chlorine in the stratosphere is believed to come primarily from CFCs rather than from natural sources such as volcanoes. The rise in the amount of chlorine measured in the stratosphere over the past 20 years has been shown to match the rise in CFCs over the same period. Samples of air taken from the stratosphere over erupting volcanoes show that volcanoes contribute only a small quantity of chlorine to the stratosphere when compared to CFCs.

- The existence of chlorine monoxide in the upper stratosphere indicates that the ozone layer is being destroyed.

- Capturing and eliminating the use of chlorofluorocarbons is being done in the United States to stop damage to the stratospheric ozone layer.

- When addressing consumer complaints regarding additional service expense caused by recovery efforts, the technician needs to explain to the customer that recovery is necessary to protect human health and the environment.

SECTION III: Regulations

INTRODUCTION

There is tremendous confusion in the refrigeration industry as to what the current regulations are. This chapter will attempt to provide the background for the regulations and to summarize the regulations in the last section, "Clean Air Act and Subsequent Amendments." If you suspect further changes in the law call the EPA Information hot-line at 800-296-1996.

The Montreal Protocol Regulations are not U.S. laws, but rather an agreement (Treaty) between nations to follow some rules. Each nation that agrees with the Montreal Protocol (termed signatory nations) must pass its own laws to enforce the protocol ideals. U.S. laws that apply to refrigeration technicians in the United States are part of the U.S. Clean Air Act and subsequent revisions to the Clean Air Act. EPA proposed rulings are rules proposed by the EPA to enforce the Clean Air Act. The EPA proposes the rules, and then, after public comment, refines these rules. Some people incorrectly assume that the proposed rulings are law; they are not. Many of the proposed rules have been modified after public input, including input by equipment manufacturers and technical groups. The actual laws that must be followed concerning stratospheric ozone protection (including venting, recovery, recycling, equipment certification, technician certification, disposal, record keeping, and enforcement). EPA Final Rule Summaries are published in the Federal Register and posted on the EPA website.

EARLY CONTROLS ON CFCs

During the early 1970s, CFCs that were used as aerosol propellants constituted over 50% of total CFC consumption in the United States. Following concerns initially raised by the Rowland-Molina theory in 1974, the EPA and the Food and Drug Administration in 1978 banned the use of CFCs as aerosol (spray can) propellants in all but a few essential (mostly medical) applications. Two new factors brought CFCs back into public concern in 1986. One was the connection between CFCs and the theory of global warming, or the greenhouse effect. The other was new scientific evidence that CFCs deplete stratospheric ozone and that a "hole" had developed in the ozone layer over Antarctica.

THE MONTREAL PROTOCOL

Recognizing the global nature of the problem, on September 16, 1987, in Montreal, Canada, 24 nations and the European Economic Community (EEC) signed the Montreal Protocol on Substances that Deplete the Ozone Layer. Most of the major CFC and Halon producing and consuming nations signed this agreement. Other nations, including the then Soviet Union, indicated that, following further consultations at home, they might possibly become signatories. On August 1, 1988, the U.S. EPA enacted the provisions of this agreement into regulations for the United States.

CLEAN AIR ACT AND SUBSEQUENT AMENDMENTS

The 1990 Amendments to the Clean Air Act were signed by former President Bush on November 15, 1990. The amendments establish a National Recycling and Emissions Reduction Program to regulate the use and disposal of substances, including CFCs and HCFCs, which are harmful to humans and the environment. Title VI of this program is titled Stratospheric Ozone Protection; Section 608 of Title VI contains the National Recycling and Emission Reduction Program. Title VII is titled Provisions Relating to Enforcement. Final EPA regulations were published on May 14, 1993 and most recently revised with the EPA's March 12, 2004 rule change..

The objectives of this program are to reduce the use and emissions of abusive substances to the lowest achievable level and to maximize the recapture and recycling of such substances. In addition, the amendments establish new standards for safe disposal of these substances and new federally mandated certification procedures for those engaged in servicing refrigeration systems. The EPA regulations also require that new refrigeration and air conditioning appliances are equipped with a servicing aperture, or similar device, to facilitate recapture of refrigerants during service and repair.

The amendments also affect personnel repairing or servicing an appliance or industrial process refrigeration. Under the statute, HVAC service personnel or any other individual may not "knowingly vent or otherwise knowingly release or dispose of any substance used as a refrigerant in such appliance in a manner which permits such substance to enter the environment." "De minimis" releases associated with good-faith attempts to recapture and recycle or safely dispose of any such substance shall not be subject to prohibition set forth in the preceding sentence. In other words, if you are attempting to minimize refrigerant losses, any minimal losses associated with recovery and recycling are allowed. This prohibition became effective July 1, 1992. The penalties and fines for violating the EPA provisions can be severe. The EPA is authorized to seek various levels of legal redress against any person who violates the above prohibitions.

   - The EPA is authorized to obtain an injunction against the offending parties prohibiting them from discharging refrigerants into the air.

   - The EPA may impose a $32,500-per-day penalty on the offender with the approval of the U.S. District Court. In addition, the EPA may seek to have criminal penalties and prison terms not exceeding five years assessed against any person who knowingly releases refrigerants into the atmosphere, and criminal fines and imprisonment may be assessed against any person who makes a false material statement or representation in any report, notice, or application required by the EPA.

   - Criminal fines and penalties may also be assessed against any person who negligently or knowingly releases into the ambient air a hazardous air pollutant and who, as a result of the release, places another person in imminent danger of death or serious bodily injury. In the case of an intentional discharge, the prison term may be a maximum of 15 years.

   - Finally, to encourage others to report violations of the act, the EPA is authorized to pay awards of up to $10,000 to any person who furnishes information that leads to a criminal conviction of another person for violation of the above prohibitions.

Since November 14, 1994, all HVAC service personnel must be fully trained in recommended service and repair procedures and techniques applicable to appliances containing refrigerants. In addition, since July 1, 1992 XE "July 1, 1992" , all individuals (service personnel, equipment owners, etc.) should be using their best efforts (good-faith procedures) to ensure that they do not permit inadvertent discharge of refrigerants into the atmosphere. A fine can be as much as $32,500 per day and per occurrence.

Refrigerant Production Phase-out--The Current Law

The restrictions on production and consumption of ozone-depleting substances under the Clean Air Act and all its amendments essentially match those of the revised Montreal Protocol. The phase-out schedule for the most common refrigerants is detailed below.

- Reduce CFCs from 1986 production levels by
          1994 75% Reduction (Production 25% of 1986 levels)
          1995 75% Reduction (Production 25% of 1986 levels)
          1996 Total Phase Out (Zero Production) 

- Reduce HCFC from 1989 production levels by
          1996 (allow 100% of 1989 ODP levels for HCFC + 3.1% of 1989 ODP levels for CFC)
          2010 65% reduction (35% of 1996 level)
          2015 90% reduction (10% of 1996 level)
          2020 99.5% reduction (0.5% of 1996 level)
          2030 Total Phase Out (Zero Production)

- Hydrobromofluorocarbons (HBFC) Phased Out by 1996

Prohibition on Venting

Effective July 1, 1992, Section 608 of the Clean Air Act prohibits individuals from knowingly venting ozone-depleting compounds used as refrigerants into the atmosphere when maintaining, servicing, repairing, or disposing of air conditioning or refrigeration equipment. Some types of releases are permitted under the prohibition.

- Technicians releasing "de minimis" quantities of refrigerant in the course of making good faith attempts to recapture and recycle or safely dispose of refrigerant are not subject to the prohibition.

- Refrigerants emitted in the course of normal operation of air conditioning and refrigeration equipment, as opposed to during the maintenance, servicing, repair, or disposal of this equipment, are NOT subject to the prohibition. Thus, emissions due to leaks and mechanical purging, which occur during normal operation of equipment, are permitted under the prohibition. However, the EPA is requiring the repair of substantial leaks on systems that are normally charged with more than 50 pounds of refrigerant (after June 14, 1993). Furthermore, substantial leaks on systems that are normally charged with more than 50 pounds of refrigerant must be repaired within 30 days after discovery of the leak.*

For the industrial process and commercial refrigeration sector, a 35% leakage rate or more (35% loss of charge/year) on a system with a normal charge of more than 50 pounds is defined as a substantial leak, while for all other refrigeration systems with a charge of 50 pounds or more, a substantial leak is defined as a leakage rate of 15% (15% loss of charge/year).

* Note: There is a proposed rule change, See the section titled: "Proposed EPA Rule Changes" near the end of this manual.

- Mixtures of nitrogen and R-22 (and only R-22-nitrogen mixtures) that are used as holding charges or as leak test gases are not subject to the prohibition because in these cases, the ozone-depleting compound is not used as a refrigerant. However, a technician may not avoid recovering refrigerant by adding nitrogen to a charged system. Before nitrogen is added, the system MUST be evacuated to the required level. Otherwise, the refrigerant-nitrogen mixture will be considered a refrigerant, and its release will be a violation of EPA regulation and subject to fine. Similarly, pure CFCs or HCFCs released from any appliance, hardware, or device, is presumed to be a refrigerant, and their release will be a violation of EPA regulations and subject to fine. When changing refrigerant being used on a recovery or recycling device, the refrigerant in the recovery or recycling machine must be recovered and cannot be vented into the air. Then evacuate the unit. Typically, filters also have to be changed.

- Mixtures of nitrogen and any other CFC or HCFC, except HCFC-22, are subject to the prohibition on venting. That means it is illegal to vent them into the atmosphere.

- Since November 15, 1995, HFCs and other refrigerants with a zero ozone depletion factor (ODP) are also subject to the restriction on venting because they are "greenhouse gases," meaning they contribute to the global warming problem and must be recovered. All refrigerants must be recovered.

- Small releases of refrigerant that results from purging hoses or from connecting or disconnecting hoses to charge or service appliances will not be considered violations of the prohibition on venting. However, recovery and recycling equipment manufactured after November 15, 1993, must be equipped with low-loss fittings.

Evacuation Requirements of Small Appliances

Since July 13, 1993, technicians have been required to evacuate air-conditioning and refrigeration equipment to established vacuum levels. When using recycling and recovery equipment manufactured on or after November 15, 1993, 90% of the refrigerant from the small appliance must be recovered if the compressor on the appliance is operational, and 80% of the refrigerant must be recovered if the compressor is not operational. When using recycling and recovery equipment manufactured before November 15, 1993, 80% of the refrigerant from the small appliance must be recovered.

Exceptions to Evacuation Requirements

The EPA has established limited exceptions to its evacuation requirements for 1) repairs to leaky equipment and 2) repairs that are NOT major and that are not followed by an evacuation of the equipment to the environment.

NOTE: "Major" repairs are those involving removal of the compressor, condenser, evaporator, or auxiliary heat exchanger coil.

1. Repairs to Leaky Equipment

     If, due to leaks, evacuation to the levels required are not attainable or would substantially contaminate the refrigerant being recovered, persons opening the appliance must

     a) isolate leaking from non-leaking components wherever possible;

     b) evacuate non-leaking components to the levels required; and

     c) evacuate the leaking components to the lowest level that can be attained without substantially contaminating the refrigerant. However, this level cannot exceed 0 psig.

2. If evacuation of the equipment to the environment is not to be performed when repairs are complete, and if the repair is NOT major, then the appliance must

     a) be evacuated to at least 0 psig before it is opened if it is a high- or very high pressure appliance; or

     b) be pressurized to 0 psig before it is opened if it is a low-pressure appliance. Methods that require subsequent purging (e.g., nitrogen) cannot be used.

Key EPA Dates to Remember

- January 1, 1992 - Mandatory use of certified recycling equipment when servicing automotive (not commercial/residential/industrial) air conditioning.

- July 1, 1992 - Prohibition against venting during refrigeration/air conditioning service, repair, and disposal.

- June 14, 1993 - Owners of equipment containing more than 50 pounds of refrigerant with substantial leaks must have such leaks repaired within 30 days after discovery. For the industrial process and commercial refrigeration sector, a 35% leakage rate or more (35% loss of charge/year) is defined as a substantial leak, while for all other refrigeration systems with a charge of 50 pounds or more, a substantial leak is defined as a leakage rate of 15% (15% loss of charge/year).

- July 13, 1993 - Safe Disposal Requirements go into effect.

- July 13, 1993 - All persons opening appliances (except for small appliances and motor vehicle A/C) for maintenance, service, or repair, and all persons disposing of appliances, except for small appliances, must have at least one piece of certified, self-contained recovery equipment available at their place of business.

- August 12, 1993 - Owners of recycling and recovery equipment must have certified to the EPA that they have acquired such equipment and are complying with the rule.

- August 12, 1993 - Reclamation Requirements to ARI-700 went into effect. Refrigerant that transfers ownership must be certified to ARI-700 purity before it can be recharged into a system of another owner. Regardless of whether the refrigerant is sold or given to the second owner, it must be certified to ARI-700 purity. Refrigerant may be returned to the appliance from which it was recovered or to another appliance owned by the same person without being recycled or reclaimed.

- November 15, 1993 - All manufactured appliances must be equipped with a service aperture or process stub. Appliances (except small appliances) manufactured after November 15, 1993, must be equipped with a service aperture. Small appliances manufactured after November 15, 1993, can be equipped with either a process stub or a service aperture. The major purpose of this requirement is to make it easier to recover refrigerant. A service aperture or process stub is used when adding or removing refrigerant from the appliance. A process stub service port is a straight piece of tubing that is entered using a piercing access valve.

- November 15, 1993 - All recycling and recovery equipment manufactured must be certified to ARI 740-1993.

- November 15, 1993 - Low-Loss Fittings are required.

- November 14, 1994 - Mandatory Technician Certification. Refrigerant sales restrictions in effect.

- November 15, 1995 - Prohibition on venting any refrigerants, went into effect. This is due to the greenhouse global warming effect of vented refrigerants.

- December 31, 1995 - CFC Production Ban went into effect. No production or importation of new CFC's. All CFC's must come from recovery, recycling, and reclamation.

- January 29, 1998 - Persons servicing MVAC-like appliances have the option of becoming certified as Section 608 Type II technicians instead of becoming certified as Section 609 MVAC technicians under subpart B. Persons servicing MVACs do not have this choice.  They must be certified as Section 609 MVAC technicians if they perform the AC service for compensation.

Record Keeping Requirements

Technicians must keep a copy of their proof of certification at their place of business.

Wholesalers who sell HCFC, CFC and HFC refrigerants must retain invoices that indicate the name of the purchaser, date of the sale, and quantity of refrigerant purchased.

Reclaimers must maintain records of the names and addresses of persons sending them material for reclamation and the quantity of material sent to them for reclamation. This information must be maintained on a transactional basis. Within 30 days after the end of the calendar year, reclaimers must report to the EPA the total quantity of material received by them for reclamation that year, the mass of refrigerant reclaimed that year, and the mass of waste products generated that year.

Reclamation

Refrigerant recovered and/or recycled can be returned to the same system or other systems owned by the same person without restriction. However, since August 12, 1993, the EPA requires that if the refrigerant changes ownership, it will have to be cleaned to the ARI-700 standard of purity AND be chemically analyzed to verify that it meets this standard. This process is referred to as reclamation, and refrigerant meeting these conditions is referred to as being reclaimed.

Several important points need to be made concerning this regulation.

First, a refrigerant is considered "reclaimed" if and only if it is certified to meet the purity standards of ARI-700. In other words, if tests on the purity of the refrigerant show the refrigerant is clean (to ARI-700 standards), it is referred to as reclaimed, no matter what process if any, was used to clean it.

Second, the refrigerant cannot be transferred from any appliance owned by one person (person here means a person, corporation, partnership, or any other legal entity) to an appliance owned by a different person; it cannot be sold or given free to a second person. The refrigerant must be certified to meet the purity requirements of ARI-700 before it can legally be put in a second owner's equipment (except recovery, recycling, and reclamation equipment). Some technicians have wrongly believed that refrigerant can be transferred into a different owner's equipment if it was not sold. This is not correct; refrigerant cannot be transferred to a new owner unless it is certified pure (to ARI-700). This rule does not apply to automotive applications; they have to meet SAE (Society of Automotive Engineers) purity standards. In other words, if tests on the purity of the refrigerant show the refrigerant is clean (to ARI- 700 standards), it is referred to as reclaimed, no matter what process, if any, was used to clean it. This rule does not apply to automotive applications; they have to meet SAE (Society of Automotive Engineers) purity standards.

Equipment Certification

The EPA has established a certification program for recovery and recycling equipment. Under this program, the EPA requires that equipment manufactured on or after November 15, 1993, be tested by an EPA-approved testing organization to ensure that it meets EPA requirements. All recovery equipment now manufactured is required to have a certification label showing that the unit is EPA approved. Recovery equipment intended for use with small appliances must be tested under either ARI-740 or Appendix C of the EPA Final Rule (May 14, 1993). The agency is requiring recovery efficiency standards that vary depending on the size and type of air-conditioning or refrigeration equipment being serviced, and since July 13, 1993, technicians have been required to evacuate air-conditioning and refrigeration equipment to established vacuum levels. For small appliances, when using recycling and recovery equipment manufactured on or after November 15, 1993, 90% of the refrigerant from the small appliance must be recovered if the compressor on the appliance is operational, and 80% of the refrigerant must be recovered if the compressor is not operational. When using recycling and recovery equipment manufactured before November 15, 1993, 80% of the refrigerant from the small appliance must be recovered.

Technician Certification

Since November 14, 1994, the EPA has required that all individuals handling refrigerants be certified. Four types of section 608 certification are available. Only certified technicians can purchase refrigerants.

Technicians receiving a passing grade on the EPA Type I (small appliance) examination are certified to recover refrigerant during the maintenance, service, or repair of packaged terminal air conditioners with 5 pounds or less of refrigerant. Only Type I or Universal certified technicians ca