Trakref recently made a public comment about EPA's proposal to revise the Section 608 update.
Yes, this issue of possibly rescinding part of the EPA 608 Update has got the attention of many, including us. Here's what we commented to the EPA:
At Trakref, we have been helping clients manage their refrigerant needs since 1994, and we are pleased to submit comments on the EPA’s Revisions to the Refrigerant Management Program’s Extension to Substitutes. 83 Fed. Reg. 49332 (October 1, 2018).
Harmonization of policies as they relate to required actions, access to hardware and allowable fluids to operate are essential building blocks that empower and enable commercial businesses to perform work in an affordable and consistent manner.
The present action suggested to “roll back” regulations would effectively add new regulatory responsibilities (which seems to be the opposite of the intentions of removing regulations) by requiring that managers/owners of equipment qualify the maintenance of HVAC/R appliances by refrigerant type. Confusion already exists amongst multi-tenant property owners/managers in the US, as most are unaware of which is an ODS or non-ODS material. Owners/managers will have to track multiple policies and the evolution of multiple laws and requirements and support various training and activity for each region, which is costly and cumbersome. Additionally, smaller manufacturers are struggling with a path forward because they don’t have the resources to build different types of machines to accommodate various states or regional policies, and they are unsure about the magnitude of demand and need to know the most reliable path forward.
Throughout the year, we work with thousands of sites with hundreds of thousands of HVAC/R systems of various vintages, containing a vast variety of different refrigerants of various sizes. All of these sites strive to perform maintenance in the very same way regardless of the system and if the EPA were to return to a two Policy program, the service workforce would be conflicted. These different sets of rules would confuse a workforce short on training and struggling to win new applicants, and they would likely select the policy that is easiest to meet. Therefore, how will owners/managers know if a gas being vented is a CFC (or HCFC) or an HFC?
Already the EPA has access to evidence that HFC handling and maintenance policies are a well-established part of the marketplace. Each year the reclaim industry reports total amount of material they collect and process (to the EPA). In 2017, HFCs accounted for 42% of total reclaim, an astounding 8,345,000 LBS were collected and processed during that calendar year—a time frame when compliance was not required but the marketplace was preparing for the regulations. This reclaim industry has heavily invested in the resources to test, process, collect, store, recycle and resell these HFCs. The investment they have made is significant and takes time to prepare and time to gain a return on the investment. Rolling back the regulations would harm these investments and jeopardize their futures since nearly ½ of their capacity (and growing) is reliant on HFCs.
Owners, managers, suppliers, service providers and manufacturers are already in the midst of a massive industry shift that has expanded refrigerant handling practices from ODS to include high GWP refrigerants. This transformation evolved in hundreds of meetings over many years, and we (as an industry) arrived here today in cooperation and not conflict with the EPA.
US companies have been and will likely remain to be the pioneers that developed the solutions that the world is relying on for this transition. The industry has made investments that have lead to advancements in recycling and separation technologies, new material handling tools for HFCs and other non-ODS materials and new practices and technology to track and manage the flow of materials and activity. Many of these technologies and processes are patented and provide jobs and opportunity to a US workforce. If a roll back occurs, a likely scenario would involve US companies manufacturing for export with little or no use or application for the technologies and tools here in the US.
The EPA adjustment to Section 608 refrigerant management in November 2016 was the result of years of meetings with thousands of industry stakeholders providing input, which reached the outcome of a consistent policy to ODS and high-GWP refrigerants (namely HFCs). For this and many reasons, we encourage the EPA to continue to support the transition and leave the existing regulations in place.
1. We support leak management requirements being extended to HFCs and other substitute refrigerants and that they be exactly the same as it is for ODS materials.
2. We support the harmonization of maintenance practices between ODS and non-ODS materials.
3. We support refrigerant leak management regulations extension to ODS substitutes.
Because we believe in remaining a part of a profitable, world leading, innovative and resilient workforce (industry) intent on maintaining the comfort, environment and quality of life, here and abroad, we urge the EPA to remain in support of the job growth and massive industry investment already begun and well underway.
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