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Recycling of Alternative Motor Vehicle Refrigerants

This letter is provided purely for historical purposes. It has been superceded by a June, 1998 letter and a December 30, 1997 Final Rule on Handling of CFC-12 Substitutes.

It describes the legal status of recycling of alternative refrigerants used in motor vehicle air conditioning systems. It was written by Jeffrey Levy, then the refrigerants analyst for the Significant New Alternatives Policy ( SNAP) Program, as a clarification to an earlier letter containing suggested advertising language. Note that this policy does not affect the recycling of alternative refrigerants used in stationary equipment governed under section 608 of the Clean Air Act.

Dear Alternative Refrigerant Manufacturer:

I hope you found my letter to you of July 30, 1996 useful. Working together, we can ensure that advertising for alternative refrigerants for motor vehicle air conditioning (MVAC) remains accurate and informative. I am writing today to clarify one point about recycling and recovery of refrigerants.

In my earlier letter, I stated:

"The recycling of an alternative other than HFC-134a is not currently covered by a specific standard. It is currently permissible to add new fittings to recovery/recycling equipment designed for use with CFC-12 and then use that equipment with alternatives other than HFC-134a...."

After receiving several inquiries about this bullet point, I realize that my discussion was somewhat broad. EPA defines three terms related to the handling of refrigerant after it's been used in a system:

Recovery:
the use of a machine to move refrigerant directly from the car to a container. Recovered refrigerant must then either be reclaimed or destroyed. Refrigerant may not be vented. Recovery occurs in the service shop.
Recycling:
the use of a machine to remove impurities and oil and then recharge the refrigerant into either the same car or a different car. Recycled refrigerant is not as pure as reclaimed refrigerant. Recycling occurs in the service shop.
Reclamation:
the restoration of refrigerant to a state that satisfies the ARI 700 standard. Reclamation means the removal of all oil and impurities beyond that provided by on-site recycling equipment, and reclaimed refrigerant is essentially identical to new, unused refrigerant. Reclamation cannot be performed in the service shop. Rather, the shop generally sends refrigerant either back to the manufacturer or directly to a reclamation facility. EPA publishes a list of approved reclamation facilities.

I will first discuss the current situation for each process and then review how EPA's current proposed rule under section 609 of the Clean Air Act (CAA) affects the recovery and recycling of HFC-134a and the recovery of alternative refrigerants other than HFC-134a.

Recovery of Alternative Refrigerants. Under section 608 of the CAA, it is illegal to vent any MVAC refrigerant. Therefore, even in the absence of EPA regulations, technicians must, at a minimum, recover refrigerant and not release it to the atmosphere. In accordance with the use conditions required under the Significant New Alternatives Policy (SNAP) program, the recovery equipment must be dedicated to a specific refrigerant by permanently applying the fittings unique to that refrigerant. Thus, by applying the fittings, it is legal to convert a recovery machine to be used with an MVAC refrigerant other than the refrigerant the machine was originally intended to recover. This is the situation I intended to address in my original letter.

Although recovering a given refrigerant using permanently converted equipment is legal, it may not be technically desirable. Recovery machines are designed to be compatible with specific refrigerants, and incompatible materials may cause short circuits, damage to seals, and compressor failure. Technicians should check with the recovery equipment manufacturer for recommendations about the recovery of refrigerants other than the refrigerant the equipment was originally intended to recover. Conversion of recovery equipment for use with other refrigerants may invalidate any warranties offered by the equipment manufacturer.

Recycling of Alternative Refrigerants. Service shops may either recover HFC-134a or recycle it using special recycling equipment in the shop. Currently, however, it is not legal to recycle any other alternative MVAC refrigerant. EPA's policy is that until a standard for equipment designed to recycle a particular refrigerant is published and available (by EPA or an industry organization like SAE or UL), then it is illegal to recycle that refrigerant. Since SAE has developed and published a standard for recycling HFC-134a, it is legal to recycle HFC-134a in a shop by using recycling equipment that meets this standard. No EPA or established industry recycling standard exists today for any alternative refrigerant other than HFC-134a. Therefore, using a recycling machine to recycle these alternatives is not allowed.

For cars that use HFC-134a, the service technician will usually recycle the refrigerant using equipment that meets the SAE standard, although recovery followed by off-site reclamation is also an option. For cars that use a blend, however, recovery using dedicated equipment and reclamation is currently the only option. No standard exists today to provide for the recycling of blends.

In my original letter, I mentioned that the current situation could change. I was referring to EPA's proposed rule of March 6, 1996 (61 FR 9014) under section 609. This proposal includes EPA standards for recovery and recycling of HFC-134a, and an EPA standard for recovery of blends that contain hydrochlorofluorocarbons (HCFCs). It is possible that the latter will be broadened to include all alternative refrigerants, regardless of whether they contain HCFCs. Once EPA promulgates the final rule, the equipment used to recover and recycle HFC-134a, and to recover other alternative refrigerants, will need to meet the appropriate EPA standards, and technicians will be required to use that equipment. Unless EPA issues recycling standards for refrigerants other than CFC-12 and HFC-134a, it will remain illegal to recycle them.

I hope this letter clarifies the bullet point in my original letter. The other statements in the bullet regarding inappropriate advertising language remain valid.


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