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EPA Proposes New Requirements for HFCs under SNAP [US]

On October 15th, 2015, the Environmental Protection Agency (EPA) announced proposed amendments to the Clean Air Act’s refrigerant management regulations.

As part of the EPA‘s Significant New Alternatives Policy (SNAP) program, the agency is proposing additional requirements for heat-trapping hydrofluorocarbons (HFCs) used in the refrigeration and air conditioning sector.

New requirements

The EPA has announced plans to extend the existing requirements under section 608 of the Clean Air Act that currently apply to ozone-depleting substance (ODS) refrigerants to non-ozone-depleting substitute refrigerants, including HFCs.

Under the current regulations, air-conditioning and refrigeration equipment must be maintained and disposed of properly to avoid releases of  substances harmful to the ozone. The amendments would impose industry best practices, such as requiring regular leak inspections and equipment repair.

SNAP program’s aim

Established under President Obama’s Climate Action Plan, the SNAP program aims to reduce the release of ODS by identifying and approving ODS substitutes as well as prohibiting the use of certain harmful chemical alternatives.


Some industry stakeholders claim that the finalized rule’s compliance deadline of January 1st, 2016 does not provide viable alternatives or enough time to transition to any proposed alternatives.

The EPA’s extension of the SNAP program’s restrictions to HFCs and proposed additional requirements are likely to be met with more industry objection.

The EPA anticipates that the new rule will be finalized during the first half of 2016.  Following publication in the Federal Register, the EPA will accept written public comments on the proposal for 60 days.

Red-on-line EHS Legalist


Prepublication Notice: Protection of Stratospheric Ozone: Update to the Refrigerant Management Requirements under the Clean Air Act, U.S. Environmental Protection Agency, October 15th, 2015. 

Final Rule: Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the Significant New Alternatives Policy Program, Federal Register, 80 CFR 42870, July 20th, 2015.

40 CFR Part 82

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