SNAP Application

An AEM taskforce comprised of member companies recently submitted the first of six planned risk analysis reports related to the proposed use of R-1234yf refrigerant in off-road mobile machinery.

The submitted report makes the case for R-1234yf as a viable substitute for R-134a in new agricultural tractors (greater than 40 HP, including 2-wheel drive, 4-wheel drive and mechanical front-wheel drive and track) and was completed in accordance with U.S. EPA specifications under its Significant New Alternatives Policy (SNAP).

“The efforts of AEM’s SNAP Application Development team serve as an example of equipment industry stakeholders from a variety of competing companies coming together and proactively asking for a change that will very positively impact the environment and significantly reduce global warming potential of the refrigerant,” said AEM Director of Materials Management John Wagner.

The availability of R-1234a is rapidly being restricted. This refrigerant is being phased out in many markets. Without a suitable alternative, the availability of cab refrigerant will become more of a challenge.  AEM is in a unique position to draft and submit this SNAP application for a broad group of mobile equipment on behalf of its members. 

SNAP was established under Section 612 of the Clean Air Act to identify and evaluate substitutes for ozone-depleting substances. The program, which is overseen by EPA, looks at overall risks to human health and the environment of existing and new substitutes, publishes lists and promotes the use of acceptable substances, as well as provides the public with key, up-to-date information.

The program also reviews substitutes within a comparative risk framework in a number of industrial sectors. One of those sectors is refrigeration and air conditioning. EPA's decision on the acceptability of new substitutes proposed by manufacturers, formulators, or users is based primarily on the potential human health and environmental risks posed by the substitutes as compared other substitutes available for a particular end use.

Once EPA receives a risk analysis report submission for a proposed substitute, it evaluates whether or not the submission is complete. Once it’s deemed complete, a period of 90 days must pass before the proposed substitute can be used for a specified end use.

In total, AEM’s six planned risk analysis reports propose the use of R-1234yf as a substitute for R-134a in agricultural tractors and the following five machine categories:

  • Self-propelled agricultural machinery -- combine, sprayer, forage harvester, windrower, floater
  • Compact utility and turf equipment -- tractors under 40 HP and utility vehicles
  • Construction and forestry equipment -- excavators, dozers, wheel loaders, loader backhoes, feller benchers, log skidders and road graders
  • Compact construction equipment -- mini-excavators, skid steers, mini-wheel loaders
  • Mining equipment -- articulated trucks, excavators, loaders, sub-surface machines

“The environmental impact difference between the current one (R-134a) and the one we’re proposing (R-1234yf) is quite substantial,” said Wagner.

While a significant portion of all six risk analysis reports being sent to EPA is the same from one to the next, what does change is the actual risk analysis assessment of the particular machine type specified in each submission.

“Those calculations are being run as we speak,” said Wagner. “When they are done, we’ll put them into the proper format and submit them.”

According to Wagner, all six risk analysis reports are expected to be received by EPA by early 2020.

AEM’s SNAP Application Development team was formed in the summer of 2018, and the group met with EPA earlier this year to learn the critical items that need to be included in the risk assessment reports AEM would submit. Throughout the year-and-a-half-long process, the association has gained members due to its efforts on behalf of the equipment manufacturing industry to propose the use of R-1234yf refrigerant in off-road mobile machinery.

“The open and honest communication about systems and how they work, and the willingness of our members to share sensitive information on sales figures and warranty that AEM was able to organize, consolidate and present, was the only way this SNAP application submission effort could be conducted as efficiently and effectively as it was,” said Wagner.

AEM members looking for more information should contact AEM’s John Wagner at jwagner@aem.org.

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