All I Want for Christmas is a Final Rule

The EPA has released a new final ruling on HCFC reduction for Christmas! I know you are probably thinking that is not much of a Christmas present, but it really is. First, the HCFC allocations were due to expire, so without a new ruling spelling out HCFC allocations, all R-22 manufacturing and importing would have ceased January 1, 2010. A new ruling setting allocations of HCFCs has been released, fixing this potential train wreck. You can download a copy of the ruling and read all the details on the EPA website

Next, the details of exactly when you may and may not install “new” equipment which uses HCFC refrigerant have been clarified. You may recall that last December the EPA shocked our industry by announcing that they considered systems which are field installed and charged to be “manufactured” when the refrigeration system was complete and the final charge added. For split systems, this would be when the system is installed. Most people in our industry were well aware of the manufacturing cutoff of January 1, 2010, but we assumed the more common definition of manufacturing date: when the equipment is made in the factory. The EPA is sticking with their definition of manufacturing, but that does not mean all R-22 inventory becomes rubbish on January 1, 2010. Packaged equipment like window units, PTACS, and packaged air conditioning equipment can all be legally sold and installed as new provided it is manufactured (in the factory) prior to January 1, 2010. You are allowed to sell and install pre-charged R-22 component parts made before January 1, 2010 to replace parts in existing systems. So you may swap out condensing units, evaporator coils, or even both in an existing system. Replacing both the condensing unit and evaporator coil on an existing system is legal. Another interesting twist is that manufacturers may ship component system parts with a nitrogen holding charge instead of refrigerant. These “dry” components can then legally be assembled into a new system provided the system is then charged with reclaimed refrigerant and not virgin refrigerant. The impact of these regulations will be minimized by the fact that most manufacturers reduced or eliminated their R-22 equipment manufacturing the past few years. Contractors have also widely accepted R-410A and few still install new R-22 systems now. R-22 production will be reduced to 41.9% of the baseline production, but that will probably be enough. With no manufacturers using it and no new systems being installed, I believe that R-22 will still be available for servicing existing systems.

I do not believe replacing an existing R-22 system with a new R-22 system is really in the customer’s best interest. Why would someone want a system that uses a refrigerant which is scheduled for extinction? Also, all new high efficiency equipment uses HFC refrigerant, not R-22. We still need R-22 equipment in schools simply because our students need to know how to work on it. You cannot assume that every call will be on a system with the latest technology. In fact, you can almost assume the opposite. Our students will continue to see R-22, so we need to teach it. However, we need to teach toward the future and not stay stuck in the past. Your lab should have many pieces of equipment with HFC refrigerant, like R-410A. You should have recovery equipment and gauges manufactured specifically for R-410A. Your texts, manufacturer’s literature, and technical literature should all support the newer refrigerants. One of our focuses in Fundamentals of HVAC/R is support for new refrigerants such as R-410A. The newer refrigerants are not only covered in the refrigerants section, but throughout the book with detailed examples using R-410A. You can learn more about Fundamentals of HVAC/R at Pearson’s site.