Preparing for the R-22 (HCFC) Phase Out Starting in 2010

"Production and import cap could be 20% short of 2010 market demand", predicts Ted Gartland of Verisae, Inc.

The HCFC refrigerant gas called R-22 is the most pervasive refrigerant in everyday use around 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. In the absence of R-22 and many of the other popular refrigerants, the economy would not have supported such a diversity of products across the 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.

The vast majority of AC/HVAC manufacturers began building and selling non-ozone damaging systems that leverage non-ozone depleting R-410A refrigerant gas. 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. Including supply of virgin R-22 product, the on-going demand for this refrigerant gas in relation to service events and the recycling of existing systems is incredibly high relative to what is available 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 can't be stressed enough how important it is to track R-22. It is also important to manage and inventory all refrigerant gases due to regulations written to address their effects on the environment.

Dirty refrigerant gas needs to be cleaned and re-certified by an EPA approved reclaimer so that it can be recycled or re-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. The protocols and regulations, like the Montreal Protocol, were put in place decades 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; penalties of up to $300K per 30 pound cylinder of refrigerant gas can be assets for improper or illegal imported gas.

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Comments

Thu, 5 Feb 2009 at 2:57 PM, by Greg Canniff
I understand the move away from R-22, but cannot see the rush toward the replacement(410a) that is HIGHER in GWP (global warming potential) than the refrigerant it is replacing. Logic says that the replacement will be also phased out sooner than later, thus the contractors will have to do another changeover? Done not make sense to me.

Thu, 5 Feb 2009 at 5:32 PM, by Ted Gartland
Greg, R-410A has a direct IPCC4 GWP of 2,088 vs Ozone Depleting R-22 of 1,810. Because R-410A is higher pressure the effects of pressure drop are significantly lower and the heat transfer is higher leading to better overall efficiency. On top of that you can use smaller diameter tubing and a smaller overall equipment & a LOWER charge size.

The overall environmental effect over the life of the equipment is much better.

Some of the new "clean sheet of paper" designs in heat pumps are astounding! (By the way I don't sell R-410A or equipment.)

R-410A is NOT designed for retrofitting existing equipment.

Thu, 30 Apr 2009 at 5:51 PM, by Charles E. Williamson
I have a question. Can Split Systems AC or
Heat Pumps with R22 manufactured before
12/31/09 be installed in new construction
housing after Jan. 1, 2010?

Thanks, for your reply.

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