In a letter to the U.S. EPA earlier this year, the Automotive Service Association (ASA) expressed concern with the substitution of HFO-1234yf because it poses some risk to those persons handling the product, particularly nonprofessionals or do-it-yourself (DIY) consumers. ASA asked that the EPA include both a certification process and an equipment requirement for any purchasers of HFO-1234fy due to the flammability of the proposed substitute.
The EPA significant new use rule states that the substance is to be used only as a refrigerant in new motor vehicles, and that any other use must first be approved by the EPA. The agency is also considering a proposed rule that falls under the Significant New Alternatives Policy (SNAP) that would allow for the use of 1234yf as a substitute for R-12 in new motor vehicles.
Currently, the Clean Air Act requires the EPA to review alternatives for ozone-depleting substances and to approve of substitutes that do not present a risk more significant than other alternatives that are available. Under that authority, the SNAP program proposes to expand the list of acceptable substitutes for ozone-depleting substances (ODS). The proposed substitute is a non-ozone-depleting gas and consequently does not contribute to ozone depletion.To view the full text of the final rule, visit ASA's legislative website at www.TakingTheHill.com.