Possible approval of HFO-1234yf in USA worries Automotive Recyclers
[ added 10 February, 2010 ]
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The Automotive Recyclers Association expressed concerns regarding the refrigerant HFO-1234yf intended for use in automobile air conditioning after the U.S. EPA announced the second extension of the consultation period for the 1234yf SNAP (Significant New Alternatives) approval.
HFO-1234yf is proposed by the chemical industry as a replacement for the chemical refrigerant R-1234a in mobile air conditioning. For this reason, the U.S. Environmental Protection Agency has opened a consultation on the approval of this substance under the Significant New Alternatives Policy (SNAP) Programme. The consultation period has been extended for the second time by the EPA since it was opened in order to incorporate toxicity results from the Premanufacture Notice (PMN) published recently and has invited further comments from the public.
The U.S. Automotive Recyclers Association (ARA) has used this opportunity to submit comments to the EPA, expressing concern over the recyclability, safety and feasibility of HFO-1234yf as refrigerant in regard to the environment, employees working in automotive recycling and the general public.
Under the SNAP Program, the EPA is evaluating and regulating substitutes for the ozone-depleting chemicals that are scheduled for phase-out under the stratospheric ozone protection provisions of the Clean Air Act. The ARA warns, however, that the total lifecycle of the fluid has not been considered and ramifications occurring from the use and disposal of HFO-1234yf must not be overlooked.
The ARA is especially concerned about storage, disposal, occupational hazard, internal cost caused by specialised equipment, impact on air quality, and storm-water run-off requirements.
Indeed, the proposed rule by the EPA states that “based on test data on HFO-1234yf, EPA has human health concerns for developmental toxicity and lethality via inhalation exposure”. This concern is however dismissed by pointing out that significant industrial or commercial worker exposure is unlikely due to the application of regulations on certified refrigerant handling equipment and other protective measures. However, the exposure of employees to HFO-1234yf during the dismantling process of an end-of-life vehicle and associated occupational risks are not addressed.
BeyondHFCs also preoccupied with HFO approval
BeyondHFCs supports the Automotive Recyclers Association in their demand for further information and in-depth research on the end-of-lifecycle handling of HFO-1234yf and associated occupational dangers, environmental impact and potential costs. BeyondHFCs welcomes the announcement made by the EPA who will look into these issues as it moves closer to administering a final rule.
BeyondHFCs is convinced that further study of HFO-1234yf will reveal more potential threats to environmental and human safety. In the same vein, we urge the EPA to seriously consider market ready, economically proven alternatives, namely carbon dioxide and hydrocarbons. In reality, there is no need to introduce HFO in the supply chain for mobile air conditioning: HFO is nothing but a next-generation HFC and very likely to bear the produce unpleasant surprises like HCFCs and HFCs showed in the past.
Links:
Federal Register/Vol. 75, No. 20/Monday, February 1, 2010/Rules and Regulations
Federal Register/Vol. 74. No. 200/October 19, 2009/Proposed rule
