This article was published in ASHRAE Journal,October 2010.

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Global Regulations and Standards

Ultra-Low GWP Refrigerants

By William Goetzler, Member ASHRAE; Javier Burgos, Associate Member ASHRAE; Timothy Sutherland

oncerns about the global warming potential (GWP) of fluorocarbon refrigerants have stimulated interest in low-GWP refrigerants, including carbon

dioxide (CO2), ammonia, hydrocarbons, and low flammability refrigerants that meet ASHRAE Standard 34-2007 criteria for A2L status. However, these refrigerants face many regulatory barriers, limiting their widespread adoption. Flammability and toxicity are two key issues. Table 1 shows the refrigerant safety group classifications in ASHRAE Standard 34-2007 Addendum ak. Differences in regulations among regions and applications create uncertainty and complexity for manufacturers who wish to implement these refrigerants. This article highlights the main findings of a comprehensive review1 of standards and regulations in the United States (U.S.), European Union (EU), and Japan affecting the application of the emerging low-GWP refrigerants shown in Table 2. The results include the identification of key regulatory
34 ASHRAE Journal

barriers and recommendations on how to overcome them to facilitate the implementation of low-GWP refrigerants. The review examined stationary refrigeration, stationary air conditioning, and mobile vehicle air-conditioning applications within each region.

Carbon Dioxide
United States Carbon dioxide operates at higher pressures than other commonly used refrigerants and can be lethal at high concentrations. However, CO2 is considashrae.org

ered a low-toxicity and non-flammable refrigerant (ASHRAE Class A1), and avoids many regulatory barriers affecting toxic and flammable refrigerants. The U.S. Environmental Protection Agency (EPA) Significant New Alternatives Policy (SNAP) program approves the use of substitute refrigerants. Achieving SNAP approval represents the first significant milestone for adopting CO2 refrigerants in new applications. EPA has granted SNAP approval for CO2 in mobile air conditioning in cars and trucks, retail food refrigeration, cold storage warehouses, and industrial refrigeration, but has not approved its use for any air-conditioning applications. EPA has also allowed vending machine manufacturers to test and collect data About the Authors
William Goetzler is a director, and Javier Burgos and Timothy Sutherland are senior consultants in the Energy Practice of Navigant Consulting, Inc., in Burlington, Mass.

October 2010

on prototype vending machines using carbon dioxide,2 which should provide a path for eventual SNAP approval. Safety standards requiring high mechanical safety factors represent another barrier, because trans-critical systems using CO2 operate at higher pressures than other refrigerants. For example, Underwriters Laboratories (UL) Standard 984 requires pressure safety factors as high as five times the design pressure, which may make designs expensive or infeasible because it necessitates much thicker walls for components. Changes to UL 471 and ASHRAE Standard 15-2007 have begun to address this issue by lowering the safety factor required for carbon dioxide used in secondary loops.

based on its relatively lower flammability compared to other Class 2 refrigerants. Ammonia is used primarily in industrial plants with stringent safety measures. Ammonia has achieved EPA SNAP approval in many refrigeration and stationary air conditioning applications, but several restrictions apply. In Standard 15-2007, ammonia is subject to additional specific safety requirements, while exempted from others. National standards often prescribe specific requirements for ammonia systems. Generally, these additional requirements do not impose insurmountable barriers to the use of ammonia systems; however, they can create a large burden on manufacturers and facilities. For users of large amounts of ammonia, the additional oversight required to satisfy EPA and Occupational Safety and Health AdEurope ministration (OSHA) requirements can create a significant burden. In Europe, equipment using carbon dioxide may fall within Most requirements are aimed at mitigating major catastrophes the scope of the Pressure Equipment in the case of major leaks. Satisfying Safety Group Directive (PED). The PED categorizthese regulations requires special safety es equipment based on pressure and Higher Flammability equipment and procedures. Keeping A3 B3 volume. Due to the high pressures, ammonia on premises also requires A2 B2 carbon dioxide systems are subject Lower Flammability developing a risk management proB2L* A2L* to additional reporting and safety gram and a project safety management A1 B1 assessments. While this is not an in- No Flame Propogation program. surmountable hurdle, it has deterred Lower Toxicity Higher Toxicity some component manufacturers from * A2L and B2L are lower flammability refrigerants with a maximum burning Europe investing in these products. There velocity of 10 cm/s. Ammonia is considered a toxic does not appear to be any other major Table 1: ASHRAE Standard 34-2007 Addendum ak, substance in the EU. For equipment EU-wide barriers to implementing refrigerant safety group classifications. using flammable and/or toxic refrigCO2 as a refrigerant. erants, the PED limits the pressure and volume levels more than for non-flammable refrigerants. Japan IEC 60335-2-40, which applies to much of the EU, places A regulatory gap may exist for safety standards pertaining charge limits on air-conditioning equipment containing flamto refrigerants in transportation-related applications. The High mable refrigerants such as ammonia. These restrictions depend Pressure Gas Safety Act (HPGSA) does not cover mobile ap- on the lower flammability limit of the refrigerant, the size of the plications. This is particularly relevant to carbon dioxide, due room in which the equipment is installed, and the ventilation to its high operating pressure. provided. These restrictions may not be problematic for small, self-contained products, but can present a barrier for larger Ammonia residential or commercial equipment. United States European standard EN 378 contains requirements for maAmmonia is a flammable and toxic refrigerant. ASHRAE chine rooms using ammonia, which include installation of a 34-2007 classifies ammonia as class B2, whereas the recent catchment system and emergency washing facilities. Other ISO 817 draft classifies ammonia as flammability subclass 2L, requirements state that ammonia must not come into contact
ASHRAE 34 Designation Carbon Dioxide Ammonia Hydrocarbons A2L Fluids
1 By

ASHRAE 34 Safety Global Warming Group Classification Potential (100 Year) A1 B2 A3 A2 (Future A2L) 11 02 <53 4,4 6,5 6756

Current Applications MVAC, Small Stand-Alone Refrigeration, Supermarket Systems Large Industrial Systems, Supermarket Systems, Chillers, Indirect Air Conditioning Small Commercial Refrigeration, Small Residential and Commercial Air Conditioning, Supermarket Systems, Chillers MVAC, Residential and Commercial Air Conditioning (Possible Future Applications)

R-744 R-717 R-290, R-600, R-600a, etc. R-1234yf, R-1234ze, R-32

definition; 2 International Institute of Ammonia Refrigeration; 3 IPCC Fourth Assessment Report, Working Group 1 Report, Table 2.15; 4 Dupont. Development and Evaluation of High Performance, Low GWP Refrigerants for Stationary AC and Refrigeration, Feb. 17, 2010; 5 Honeywell HFO-1234ze Data Sheet; 6 IPCC Fourth Assessment Report, Working Group 1 Report, Table 2.14.

Table 2: Summary of low-GWP refrigerant characteristics and current applications.

October 2010 ASHRAE Journal 35

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with materials such as zinc. EN 378 also contains allowances that exempt equipment using ammonia from certain requirements for flammable systems. For example, unlike other flammable refrigerants, equipment using ammonia is not required to seal potential ignition sources. Japan As mentioned previously, the HPGSA does not cover mobile applications, and there is uncertainty in how to regulate the use of flammable refrigerants in these applications. The HPGSA applies to stationary applications such as air conditioning and refrigeration. It references several ministry ordinances, including the refrigeration safety standards, container safety standards and general safety standards, which contain additional safety measures for flammable and toxic refrigerants. These requirements may present an additional burden on manufacturers, but are not likely to be prohibitive. However, ammonia applications will be required to satisfy certain additional safety measures, such as the explosion-proof structure requirement in the general safety standards.

amount will leak during a leak event. There remains much uncertainty about how to acceptably measure the safety risk from leakage of flammable refrigerant. A proposed change to UL 250 would establish a strict limit on the amount of charge, regardless of leakage protection measures. Achieving UL certification for

hydrocarbon refrigerants use may help to overcome the EPA SNAP barrier. Hydrocarbons have not yet been approved by EPA SNAP as an acceptable substitute for any air-conditioning or refrigeration application, outside of industrial applications. EPA has proposed SNAP approval to find several hydrocar-

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Hydrocarbons
United States Propane and isobutane are the most commonly used hydrocarbon refrigerants in refrigeration and air conditioning applications. Hydrocarbon refrigerants face restrictions because of their high flammability. Hydrocarbons are designated as Class 3 by ASHRAE Standard 34-2007. The main concern is the potential for refrigerant leakage and subsequent ignition. Consequently, flammable refrigerants have additional regulatory requirements for safety, leakage, and fire suppression. UL standards permit small amounts of hydrocarbon refrigerant in some applications, but the charge limits may present a barrier to the expanded use of hydrocarbons. UL 250 limits the charge to 50 g (1.7 oz) for domestic refrigerators, and UL 471 limits the charge to 150 g (5 oz) for small commercial refrigeration equipment. UL 250 and UL 471 currently permit larger amounts of flammable refrigerant, provided that only a certain
October 2010 ASHRAE Journal 37

bon refrigerants acceptable with use conditions in new household refrigerators and freezers and combination refrigerator and freezers with a charge of 57 g (2 oz) or less. EPA also has proposed propane as acceptable with use conditions in standalone retail food refrigerators and freezers with a charge of 150 g (5 oz) or less. Current standards restrict hydrocarbons for comfort conditioning applications. Standard 15-2007 limits non-A1 refrigerants to 3 kg (7 lb) for residential occupancies and 10 kg (22 lb) for commercial occupancies. It also states that Group A3 and B3 refrigerants shall not be used except where approved by the authority having jurisdiction, with some exceptions. The 2006 International Mechanical Code (IMC) and 2006 Uniform Mechanical Code (UMC) building codes also have adopted Standard 15-2007 charge limits. These restrictions may prove burdensome for manufacturers, especially for equipment that is too large to meet the charge limits in these standards. Several states have recently modified state regulations that previously banned the use of flammable refrigerants in mobile air-conditioning applications. These new regulations reference the EPA SNAP list or Society of Automotive Engineers (SAE) standard J639 as the basis for defining acceptable refrigerants in mobile air conditioning. However, six states currently ban all

flammable refrigerants in mobile air conditioning. Three of these states are expected to modify these bans as explained previously, leaving Louisiana, North Dakota, and Oklahoma as states with blanket bans in place.3 In addition, Iowa and Wisconsin ban the use of certain hydrocarbons in mobile air conditioning. Europe Regulations for hydrocarbon refrigerants are less restrictive in Europe than in the U.S. Safety has been addressed primarily through the use of charge limits and safety requirements for each application, which permit the use of hydrocarbons in nearly all applications. EN 378 contains strict requirements that may pose a barrier to using hydrocarbons in residential and commercial packaged air-conditioning applications. In particular, floor-standing units currently face charge limits that make low-level comfort units impractical.4 Currently, EN 378 establishes charge limits based on the height of the equipment, with more restrictive limits reserved for low-standing units. The current standards favor ceiling and elevated systems. IEC standards establish a universal charge limit of 150 g (5 oz) for commercial refrigeration systems and domestic refrigerators. This limit can potentially pose a barrier to using hydrocarbons in larger commercial refrigeration systems.

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ASHRAE Journal

October 2010

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As with carbon dioxide and ammonia, the PED places stricter limits on the pressure and volume levels of flammable and/or toxic refrigerants. The additional reporting requirements and safety assessments required by manufacturers may deter investment in these products. Japan Hydrocarbon applications will be required to satisfy certain additional safety measures, such as the incorporation of explosion-proof structures. As mentioned previously, the HPGSA currently does not cover mobile applications, and there is uncertainty in how to regulate the use of flammable refrigerants in mobile air-conditioning applications.

A2L Fluids
United States Standard 34-2007 Addendum ak recently added a 2L subclass to the existing class 2 flammability classification, covering Class 2 refrigerants with a burning velocity less than or equal to 10 cm/s. Flammability is the main safety concern that must be addressed before A2L fluids are introduced. Revisions to Standard 15-2007 based on the 2L subclass are still under negotiation. Standard 15-2007 contains special allowances for equipment using ammonia; this could provide a precedent for incorporating A2L fluids as a separate class as well. The 2006 UMC also contains these restrictions on A2 refrigerant use in human comfort systems, although the 2006 IMC does not. Safety standards such as UL Standards 471 and 1995 are unlikely to consider using the 2L subclassification until revisions to Standard 15-2007 are complete. Current draft revisions to ISO Standard 817 and Standard 5149 incorporate the 2L subclass and provide specific allowances for equipment using 2L refrigerants. Some HFO refrigerants such as R-1234yf 5 are considered candidates to achieve the new 2L subclassification in Standard 34-2007.6 They are classified by Standard 34 as flammability Class A2 and, consequently, face a variety of restrictions. The mobile vehicle air conditioning industry exemplifies how development and adoption of national regulations and standards such as the EPA SNAP list and SAE J639 can assist in the removal of many barriers to implementation. In recent years, a number of states have replaced previous laws that ban flammable refrigerants in mobile air conditioning applications with laws referencing the EPA SNAP list or the SAE standard. R-1234yf has been approved for use by the EPA SNAP program and incorporated into SAE J639.3 Europe Harmonized standards such as EN 378 have not considered any changes to incorporate the use of the A2L charge limits. IEC standards may present a barrier to using A2L fluids in larger refrigeration applications. These standards set a limit of 225 g (8 lb) of A2 refrigerants in refrigeration products, which may prohibit the use of A2L refrigerants in large or extremely cold applications. Large equipment using A2L fluids may fall within the scope of the PED, which limits the pressure and volume levels of
40 ASHRAE Journal October 2010

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United States EPA Significant New Alternatives Policy Carbon Dioxide Ammonia Hydrocarbons A2L fluids P P P P Pressure Equipment Directive Carbon Dioxide Ammonia Hydrocarbons A2L fluids D, R D, R D, R D, R D D D D D D D P, D P, D D D European Union IEC 60335-2-40 IEC 60335-2-75 IEC 60335-2-89 EN 378 UL Standards D R P, D P, D P, D P, D P P Japan High Pressure Gas Safety Act D D D D OSHA ASHRAE Standard 15-2007 Model Codes State Regulations for Mobile AC

P Prohibition of certain types of refrigerants in certain applications. D Design implications, such as charge limits or safety requirements. R Reporting requirements to ensure health and safety.

Table 3: Summary of key regulatory barriers to implementing low-GWP refrigerants. flammable and/or toxic refrigerants. A2L fluids would likely be considered flammable substances by the PED, which would require additional reporting requirements and safety assessments by manufacturers. Japan In Japan, the automobile industry is recommending re-evaluation of the HPGSA as it applies to HFO-1234yf. Currently, the HPGSA does not cover mobile applications, and uncertainty exists regarding how to regulate the use of flammable refrigerants in mobile air-conditioning applications. For all other applications, systems using A2L fluids will be required to satisfy certain additional safety measures, such as the incorporation of explosion-proof structures. standards and regulations permit small amounts of hydrocarbon refrigerant, but these charge limits are sufficient only for domestic refrigeration and possibly small commercial applications. Significant research into the safety of hydrocarbons will be required to overcome the regulatory barriers to implementation in larger equipment. Regulations in the EU are less restrictive and not fully dependent on charge limits. However, current standards still pose a barrier to using hydrocarbons in direct expansion air-conditioning and refrigeration systems. The A2L classification has gained increased acceptance with the new ASHRAE designation, ISO Standard 817 draft changes, and EPA SNAP approval of A2L fluids for mobile applications. It is likely that A2L fluids will be favored over traditional A2 fluids, due to their lower flammability. However, modification of equipment safety standards and building codes to incorporate the A2L subclass is still required to propel further adoption of A2L fluids. A2L fluids have made the most progress in the U.S. and Japan. Europe has not yet incorporated the A2L classification into its regulations.

Conclusions
This article outlines the major barriers to implementing carbon dioxide, ammonia, hydrocarbons, and A2L refrigerant in the U.S., European Union, and Japan. Table 3 summarizes the regulations and standards that present the key barriers. There do not appear to be any major regulatory barriers limiting the adoption of carbon dioxide refrigerant in any of the three regions. In the U.S., manufacturers must submit the necessary applications to achieve EPA SNAP approval for stationary refrigeration and air conditioning applications. Also, because of the required higher operating pressure, CO2 systems may face certain design challenges due to existing safety requirements. However, these remaining barriers are not expected to pose major hurdles to adoption. Ammonia has been used as a refrigerant for decades, and its use is limited largely to industrial applications with stringent safety measures in place. The toxicity of ammonia presents a major concern and poses a significant barrier to its widespread adoption. Hydrocarbons face some significant hurdles to widespread adoption in the U.S. due to their high flammability. Current
October 2010

References
1. Air Conditioning and Refrigeration Technology Institute. 2010. ARTI Report No. 09001-01, Review of Regulations and Standards for the Use of Refrigerants with GWP Values Less than 20 in HVAC&R Applications. 2. Adams, L. 2009. Cooling technologies: alternative refrigerants attract attention. Appliance Design (4):12 16. 3. Taddonio, K. 2008. Last remaining barriers. EPA presentation. www.epa.gov/cppd/mac/6%20Taddonio.ppt. 4. Cox, N. 2009. Replacing R-22 with HCspractical experience. Presentation at Atmosphere 2009. 5. Brown, J.S. HFOs: new, low global warming potential refrigerants. ASHRAE Journal 51(8):22 29. 6. Fleischer, R. 2009. Advances in Environmentally Sustainable Refrigerants and Blowing Agents. Honeywell. EEDAL. www.eedal. eu/fileadmin/eedal2009/presentations/Cold_Appliances_II/105_ Bowman_Fleischer.pdf. ASHRAE Journal 43