A multi-year effort between AEM and a taskforce comprised of subject matter experts from its member companies recently led to the U.S. EPA signing a rule authorizing the use of HFO-1234yf as a refrigerant in off-road vehicles.

AEM guided the development of risk assessment reports – completed in accordance with EPA’s Significant New Alternatives Policy (SNAP) specifications – proposing the use of HFO-1234yf as a substitute for R-134a in the following five machine categories:

  • Self-propelled agricultural machinery – combine, sprayer, forage harvester, windrower, floater
  • Compact equipment – tractors under 40 HP and utility vehicles, compact construction equipment
  • Construction, forestry and mining equipment – excavators, dozers, wheel loaders, loader backhoes, feller benchers, log skidders and road graders, articulated trucks, excavators, loaders, sub-surface machines
  • Agricultural Tractors 40 HP and above – Two Wheel Drive, MFD, Four wheel Drive and Track Tractors
  •  Utility Vehicles – Commercial Use Utility Vehicles

“The work done by AEM and its members have provided the industry with an alternative refrigerant that  has a significant and positive impact on the environment,” said AEM Director of Materials Management John Wagner, who led the association’s SNAP Application Development team. “The process by which we conducted our efforts may also serve as a guide for how AEM can pull together the right people – with the right interests, backgrounds and expertise – to be able to address challenging industry issues that involve interactions with EPA and other governmental organizations.”

Significant New Alternatives Policy (SNAP)

SNAP was established under Section 612 of the Clean Air Act to identify and evaluate substitutes for ozone-depleting substances such as hydrofluorocarbons (HFCS) contained in R-134a. 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.

EPA's evaluation of each substitute in an end use is based on the following types of information and analyses:

  • Atmospheric effects
  • Exposure assessments
  • Releases in the workplace and in homes
  • Releases to ambient air and surface water
  • Releases from the management of solid wastes
  • Toxicity data
  • Flammability
  • Other environmental impacts

AEM’s SNAP Application Development Team

AEM’s SNAP Application Development team was formed in the summer of 2018, and the group engaged EPA on the critical items that need to be included in the risk assessment reports AEM would submit in support of HFO-1234-yf as a viable alternative to R-134a.

Throughout the multi-year process, the association has gained members due to its efforts on behalf of the equipment manufacturing industry to propose the use of an alternative refrigerant in off-road mobile machinery. AEM also attracted support from a wide spectrum of organizations including The Mobil Air Climate Systems Association (MACS),  the  National Council of State Legislatures bipartisan resolution unanimously calling on EPA to approve the SNAP request, and  the Institute for Governance & Sustainable Development (IGSD),   which works to promote just and sustainable societies and to protect the environment by advancing the understanding, development and implementation of effective, and accountable systems of governance for sustainable development.

“AEM deserves praise and recognition for the hard work they put into this. IGSD is delighted that EPA has finally listed R-1234yf as acceptable in off-road machinery, so that off-road equipment manufacturers can join auto manufacturers in using next-generation refrigerants that are better for the climate,” said Kristen N. Taddonio, senior climate and energy advisor at IGSD.

“Ultimately, open and honest communication between key stakeholders, collaboration between members about systems and how they work, as well as a willingness to share sensitive information on sales figures and warranty that AEM was able to organize, consolidate and present, was the only way this effort could be conducted as efficiently and effectively as it was,” said Wagner. “And now, thanks to this newly signed rule, HFO-1234yf is now officially identified as an approved alternative refrigerant for five categories of off-road machines.”

For more information about AEM’s SNAP Application Development Team and its efforts related to HFO-1234-yf, contact AEM’s John Wagner at jwagner@aem.org.

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