Questions and Answers About R-22a Safety
1. What is R-22a?
R-22a, also known as 22a refrigerant, is a hydrocarbon refrigerant blend, with primary components including flammable substances such as propane and butane; in some cases, it may also contain small amounts of other hydrocarbons or a pine-scented odorant. This refrigerant is a highly flammable, colorless gas that is heavier than air.
2. What are the potential safety risks of R-22a?
Because R-22a is flammable, it can burn or explode if there is enough product concentrated in one space and the refrigerant comes in contact with an ignition source.
3. Has EPA determined whether R-22a can be used safely as a refrigerant in air-conditioning equipment designed for use with HCFC-22?
EPA recently issued a proposed rule that would list refrigerant products sold as 22a and all refrigerants identified as flammability Class 3 in ANSI/ASHRAE Standard 34–2013 as unacceptable for retrofitting residential and light commercial AC and heat pumps—unitary split AC systems and heat pumps—that is, for use with existing central air conditioning systems. EPA will review the comments received on the proposal before deciding whether to issue a final determination.
For more information, see SNAP Rule 21.
4. Is it legal to sell R-22a for use as a refrigerant in air-conditioning equipment designed for use with HCFC-22?
No. R-22a has not been submitted to EPA for review under the SNAP program. The CAA and EPA’s regulations prohibit the introduction into interstate commerce of substitutes that have not been submitted to EPA for review under 40 CFR 82.176(a).
5. What actions is EPA taking against the illegal use of R-22a?
EPA cannot comment on any specific enforcement actions that it may be undertaking or that are in the early stages of investigation. However, EPA has settled with companies over allegations of illegal activity regarding the sale of R-22a as a refrigerant and will continue to take enforcement actions where appropriate. Some examples of past enforcement actions include:
- EnviroSafe (2015)
In a settlement with EPA, Enviro-Safe Refrigerants, Inc., of Pekin, Illinois, agreed to pay a $300,000 civil penalty and cease marketing and sale of unapproved flammable hydrocarbon refrigerants as substitutes for ozone-depleting substances. Enviro-Safe allegedly violated Clean Air Act requirements through the marketing and sale of three flammable hydrocarbon refrigerant products, HC-12a, HC-22a and HC-502a, as substitutes for ozone-depleting substances without providing the requisite information to EPA for review and approval.
- Northcutt (2016)
In a settlement with EPA, Northcutt, Inc., of Wichita, Kansas, agreed to discontinue domestic marketing and sales of unapproved flammable hydrocarbon refrigerants as substitutes for an ozone-depleting substitute, send a warning letter to past domestic purchasers of the substitutes, and pay a $100,000 civil penalty. Northcutt allegedly violated Clean Air Act requirements through the marketing and sale of two flammable hydrocarbon refrigerant products, ES 22a and ES 502a, as substitutes for ozone-depleting substances without providing the requisite information to EPA for review and approval.
6. Has EPA identified other flammable hydrocarbons or blends that can be safely used in air-conditioning equipment designed for use with HCFC-22?
No. EPA has not found any flammable hydrocarbon refrigerants acceptable for use in existing air-conditioning systems designed for use with HCFC-22. Use of flammable refrigerants as a retrofit in equipment that was designed for nonflammable materials presents risks to consumers, equipment, and service technicians who may not be prepared for handling flammable refrigerants. Further, EPA is aware that in some cases, use of flammable refrigerants to replace materials used by the manufacturer in the equipment’s original charge will void the warranty.
EPA has prohibited the use of Hydrocarbon Blend A (sold under the name OZ-12®) and Hydrocarbon Blend B (sold under the names DURACOOL 12a® and HC-12a®) in air-conditioning systems, and has recently proposed to do the same for “22a” and “R-22a” in existing central air conditioning systems. These refrigerants have never been submitted to EPA for the required health, safety, and environmental review and are not approved for use in air-conditioning systems.
7. Which refrigerants are allowed to be used in air-conditioning systems for air-conditioning equipment designed for use with HCFC-22?
The list of acceptable refrigerants for use in home air conditioning is available at this link: Acceptable Substitutes in Household and Light Commercial Air Conditioning. You can find EPA’s lists of acceptable refrigerants for other uses here.
8. Has EPA identified other flammable hydrocarbons or blends that can be used safely as refrigerants in new refrigeration and air-conditioning equipment?
The Agency has not found hydrocarbon refrigerants acceptable for use in refrigeration and air-conditioning equipment that were originally made for a different, non-flammable refrigerant. However, EPA has listed a number of flammable hydrocarbon refrigerants or refrigerant blends as acceptable substitutes for use in various types of new refrigeration and air-conditioning equipment. EPA notes that the listings for household and commercial refrigerators and freezers and room air conditioning units apply only to new equipment that was specifically designed to be used with that refrigerant.
EPA expects the list of acceptable substitutes, including flammable hydrocarbon refrigerants or hydrocarbon refrigerant blends, to expand. The current lists of acceptable refrigerants for use in refrigeration and air conditioning can be found in the Refrigeration and Air Conditioning section.
These determinations were based on detailed assessments of the risks posed by each flammable refrigerant in the particular application or type of equipment to be used. In addition, in many instances EPA’s regulations adopt the results of safety reviews by industry standards-setting bodies as mandatory use conditions. Thus, EPA’s rules further reduce risk by setting requirements for the amount of refrigerant used, design and testing of equipment, and warning labels, among other things.