A multi-year effort between AEM and a task force comprised of subject matter experts from its companies recently received letters of completion for all five risk analysis reports submitted to the U.S. Environmental Protection Agency (EPA) related to the proposed use of R-1234yf refrigerant in off-road mobile machinery.
The reports – completed in accordance with EPA specifications under its Significant New Alternatives Policy (SNAP) – made the case for the use of R-1234yf as a substitute for R-134a in the following five machine categories:
- Self-propelled agricultural machinery – combine, sprayer, forage harvester, windrower, floater
- Compact equipment – tractors under 40 HP and utility vehicles, compact construction equipment
- Construction, forestry, and mining equipment – excavators, dozers, wheel loaders, loader backhoes, feller benchers, log skidders and road graders, articulated trucks, excavators, loaders, sub-surface machines
- Agricultural Tractors 40 HP and above – Two Wheel Drive, MFD, Four-wheel Drive, and Track Tractors
- Utility Vehicles – Commercial Use Utility Vehicles
“With the letters of completeness, AEM member company equipment with R-1234yf can be placed on the market in North America for all of the applications listed above. This is important to our industry because HFC-134a is the refrigerant used in our equipment, and its availability will be reduced as it is phased out.”
said AEM Director of Materials Management John Wagner.
AEM’s SNAP Application Development team was formed in the summer of 2018, and the group met with EPA in mid-2019 to discuss key items that need to be included in the risk assessment reports AEM would provide on behalf of the industry.
Throughout the multi-year-long process, AEM has gained new members, Chemours, Bergstrom Engineering, and Honeywell, in large part due to its work on behalf of equipment manufacturers to propose the use of R-1234yf refrigerant in off-road mobile machinery. Other member company participants involved in the SNAP application process were: CNH Industrial, AGCO, Caterpillar, Doosan Bobcat, Red Dot, CLAAS, John Deere, Wacker Neuson, JLG, Yanmar, JCB, MacDon, Volvo Construction Equipment, and Kubota.
“It’s been great to see dedicated individuals from several member companies come together and work on behalf of our industry to help ensure there will be an EPA-approved alternative refrigerant available for use,”
“Now, with the SNAP listing of R-1234yf, our industry has the option to adopt R-1234yf as an alternative to current HFC=laden options. There is no ‘legal’ requirement to use R-1234yf. It is an EPA-approved alternative refrigerant for use in our applications.”
SNAP was established under Section 612 of the Clean Air Act to identify and evaluate substitutes for ozone-depleting substances. The program, which is overseen by EPA, looks at overall risks to human health and the environment of existing and new substitutes, publishes lists and promotes the use of acceptable substances, as well as provides the public with key, up-to-date information.
The program also reviews substitutes within a comparative risk framework in a number of industrial sectors. One of those sectors is refrigeration and air conditioning. EPA’s decision on the acceptability of new substitutes proposed by manufacturers, formulators, or users is based primarily on the potential human health and environmental risks posed by the substitutes as compared to other substitutes available for particular end-use.
EPA’s decision on the acceptability of new substitutes proposed by manufacturers, formulators, or users is based primarily on the potential human health and environmental risks posed by the substitutes, as compared to other substitutes available for particular end-use. EPA’s evaluation of each substitute in an end-user is based on the following types of information and analyses:
- Atmospheric effects
- Exposure assessments
- Releases in the workplace and in homes
- Releases to ambient air and surface water
- Releases from the management of solid wastes
- Toxicity data
- Other environmental impacts
The next – and final – step in the AEM SNAP Application Development Team’s effort to secure R-1234yf as a substitute for R-134a in certain machine categories is to be published in the Federal Register.
“We are actively monitoring this process. Once complete, R-1234yf will officially be identified as an EPA-approved alternative refrigerant for five categories of machines. While there is a small risk that some requirement could change during the publishing process, we do not expect any at this time.”