HCFC-141b Questions and Answers
What is HCFC-141b?
HCFC-141b is a hydrochlorofluorocarbon (HCFC). Its chemical name is 1,1-dichloro-1-fluoroethane and its Chemical Abstracts Registry Number is 1717-00-6. HCFC-141b has been used as a solvent and as a foam blowing agent in the manufacture of diverse products ranging from refrigerators to building insulation. Under the U.S. Clean Air Act (Title VI, Section 602), HCFC-141b is a class II ozone-depleting substance (ODS). Under the Montreal Protocol, the group of HCFCs are listed as Annex C, Group I controlled substances.
Why did EPA phase out HCFC-141b?
Under the Montreal Protocol, industrialized countries, including the United States, agreed to the eventual phaseout of HCFC production by 2030, beginning with a 35% reduction in 2004, followed by a reduction of 75% by 2010. In 1993, as authorized by Section 606 of the Clean Air Act, to meet these obligations the U.S. EPA established a chemical-specific phaseout schedule that would eliminate production of HCFCs in order of their ozone depleting potential. HCFC-141b has the highest ozone depleting potential of any HCFC and was targeted in 1993 for phaseout beginning January, 2003.
May I use HCFC-141b after January 1, 2003?
It depends on the use. HCFC-141b is an unacceptable substitute for CFCs in foam blowing end uses and is an unacceptable substitute for CFC-113 and methyl chloroform for cleaning with solvent cleaning equipment. Therefore, you may not use HCFC-141b in those uses. However, you may use HCFC-141b as an aerosol solvent in certain specific uses such as for aircraft maintenance or for cleaning electrical equipment and electronics. A complete list of permissible aerosol uses is in EPA’s regulations implementing the nonessential products ban in Section 610 of the Clean Air Act.
This decision does not in any way affect the January 1, 2003, phaseout deadline for the production and import of HCFC-141b.
What are the EPA acceptable alternatives for HCFC-141b?
What is EPA's Significant New Alternatives Policy (SNAP) program?
SNAP implements section 612 of the Clean Air Act which requires EPA to evaluate substitutes for ODSs to reduce overall risk to human health and the environment. The intended effect of the SNAP program is to expedite movement away from ozone-depleting compounds while avoiding a shift into substitutes posing other environmental or health problems. On March 18, 1994, EPA promulgated the initial SNAP rule establishing the program for evaluating and regulating substitutes for ozone depleting chemicals (59 FR 13044), and has since issued decisions on the acceptability and unacceptability of a number of substitutes.
How did EPA respond to the petition from the spray foam industry asking for relief from the January 1, 2003, phaseout of HCFC-141b?
EPA agrees there may be legitimate needs for limited HCFC-141b production and import beyond January 1, 2003. The Agency incorporated into the final Allowance Allocation Rule for Controlling HCFC Production, Import and Export, a limited exemption process for HCFC-141b users who can demonstrate that they have insufficient access to stockpiles of HCFC-141b and cannot transition to fully developed alternatives by the January 1, 2003, phaseout deadline. This petition process is still in effect.
What is required in a petition for HCFC-141b exemption allowances?
Petitioners must provide clear justification for needing access to HCFC-141b production or import beyond January 1, 2003, as well as proof that they are investigating alternatives to transition from HCFC-141b. Documentation from individual HCFC formulators (e.g., systems houses) would be required to support individual petitions, specifying their HCFC-141b needs, and detailing why alternatives are not technically viable and why stockpiled HCFC-141b is not available to meet transitional needs.
How does EPA review the petitions?
EPA considers the technical merits of each petition as well as industry-wide data on the availability of HCFC-141b and viability of alternatives.
May I import finished products and blended systems containing HCFC-141b into the U.S. after 2003?
The Montreal Protocol does not prohibit import of "products" containing HCFCs into the U.S. Blended systems qualify as "products" under the Montreal Protocol. The U.S. phaseout regulations at 40 CFR Part 82 provide similar treatment. The SNAP program prohibition on HCFC-141b as a substitute for CFCs applies to the act of blowing foam, and does not apply to the import of products. Therefore, currently it is legal to import finished products and blended systems containing HCFC-141b into the U.S. However, if imports of products and systems containing HCFC-141b become a significant issue that either impedes the overall transition from HCFC-141b or disadvantages businesses that have made good faith investments and efforts to develop and use alternatives, EPA will exercise its authorities to require labeling of products containing or made with an HCFC to address polyurethane pre-polymers specifically. Such labeling is required as of January 1, 2015.