Managing the Change

By Ward Atkinson, MACS Technical Correspondent. Chairman, SAE interior Climate Commitee
ts been a little over a decade since CFC-12 was replaced and
now the mobile air conditioning industry is facing the
replacement of HFC-134a. This refrigerant replacement challenge is much greater and we need to address the issues that were
experienced during the last refrigerant changeover. During the
change from R-12 to R-134a, global consensus was reached very
quickly and industry focused on implementation.
With the current change, our first problem is that the focus
has been on a replacement refrigerant for Europe only.
Development of six alternative refrigerants has taken place over
the last 10 years and even today there is no consensus on a single refrigerant for global use.
The European F-gas law will soon require motor vehicle
air conditioning systems (MVACs) to use refrigerants with a
global warming potential (GWP) of less than 150, and much
industry effort has been spent to evaluate possible replacement
refrigerants. In the U.S, legislation in California includes provisions for credits for the use of low GWP refrigerants to encourage their use, and other states may adopt similar laws.
Carbon dioxide (R-744) and HFO-1234yf will both meet
the European requirements.The use of R-744 requires an entirely new MVAC system due to higher operating pressures. HFO1234yf, a mildly flammable chemical, also requires system design
considerations but in general can use current HFC-134a system
component technology since it has similar operating pressures.
On February 5, 2009, David D. Doniger, Policy Director of
the Climate Center of the Natural Resources Defense Council
(NRDC), sent a letter to the co-chairs of EPAs Mobile Air
Conditioning Climate Protection Partnership (Dr. Stephen O.
Andersen, Ward J. Atkinson and Elvis Hoffpauir) proposing a
rapid transition to a replacement MVAC refrigerant.

Mr. Doniger said in the letter:

One of the greatest opportunities for rapid progress is in
your area, mobile air conditioning. NRDC wants to see
HFC-134a replaced as quickly as possible with a highefficiency low-GWP alternative, and employed in systems
achieving near-zero emissions. Ideally, this transition
should occur on a global basis at the same time. But, in
any case, the U.S. must lead.
We would like to work cooperatively with industry and
government to achieve agreement on a schedule for a rapid
transition away from HFC-134a in mobile air conditioning. If we work together and reach agreement on a
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pathway forward, we can avoid a prolonged period of regulatory uncertainty at all levels of government, from state
and local to international.
Specifically, NRDC wants to work with the MVAC
community on measures to:
Phase-out HFC-134a in mobile air conditioning on a
specific schedule,
Contain, recycle, and destroy CFC and HFC refrigerants used in existing and future cars,
Bar manufacture and sale of non-returnable cans of
refrigerant,
Restrict the sale of returnable refrigerant containers to
certified technicians working with the latest recovery/recycle equipment.
This industrys leadership in addressing the dangers of climate change can be an inspiration and a model for others. We have worked together before. I look forward to
working with you again to meet this challenge.
Some perspective
The phase-out of CFC-12 was based upon its causing the
depletion of the earths ozone layer. Today, international attitudes
on global warming issues have dramatically changed, and the
European Union has already started the elimination of HFC134a as a refrigerant in mobile air conditioning systems. With
other organizations and regulatory agencies considering continuing this trend, the problems experienced with the CFC-12 to
HFC-134a transition must not be repeated if a true environmental and consumer benefit is to be achieved.
In North America, the replacement of CFC-12 created
major problems. The vehicle manufacturers developed retrofit
procedures, and in some cases provided kits to convert CFC-12
systems to use HFC-134a.
Only substitute refrigerants listed as acceptable by the
U.S.EPA can be legally installed in automotive A/C systems, and
EPA had listed more than ten different refrigerants under the
Significant New Alternatives Policy (SNAP) as replacement
refrigerants for CFC-12 MVAC systems. Many contained
HCFCs.
Further, each substitute refrigerant required unique service fittings, and, since replacement refrigerants cannot be vented to the
atmosphere, also required specific recovery equipment for which
there were no standards or equipment except for HFC-134a. Also,

Managing the Change

the U.S. Clean Air Act mandated recovery
and reuse of CFC-12 and restricted its
purchase to certified technicians. But the
new refrigerant, HFC-134a, could be purchased and used by anyone professionals
or do-it-yourselfers (DIYers).
Non-OEM
sources
promoted
numerous refrigerant replacements,
including blends and flammable alternatives such as propane. The use of these

non-OEM products and service procedures resulted in many industry problems

including cross-contamination of vehicle
systems as well as damage and contamination of CFC-12 and HFC-134a recovery
and recycling service equipment.
These situations resulted in additional cost to the consumer as well as the service industry, and did not benefit the environment. In fact, since EPA allowed mul-

tiple refrigerants for MVAC use (other

than HFC-134a, the industry standard),
the result was many opportunities for
contamination of systems and equipment.
As well, consumers incurred additional
repair bills after having other refrigerants,
such as blends, charged into their CFC-12
systems. Since specialized recovery or
recycling equipment was not available for
refrigerants other than HFC-134a, there
was the added potential of releasing the
refrigerant to the atmosphere from
MVAC systems.
The next changeover
While the impact of replacing HFC134a can be seen through the lens of
replacing CFC-12, the magnitude is much
greater in view of the present world vehicle population and the fact that A/C has
grown to be nearly standard on all vehicles
worldwide.
Present HFC-134a systems are
designed and tested only for use with
HFC-134a, and with a specific lubricant,
polyalkylene glycol, or PAG. (POE lubricant is used for electric compressors in
hybrid vehicles.) There has been no published information of industry-recognized
tests for any of the other EPA-listed
refrigerants to establish a systems cooling
performance, system reliability, material
compatibility or the potential for damage
should a substitute refrigerant be installed
in an HFC-134a system.
Present systems are mature, and in
recent years, the industry has improved
MVAC system design to be more energy
efficient and have less refrigerant loss.
Current MVAC system refrigerant emissions have an average rate of a one-half
ounce (15 grams) per year. The industry
has also reduced the amount of refrigerant
used in a system. In model year 2000, the
average single evaporator system charge
was 26.9 ounces (763 grams); by 2004 it
was 24.3 ounces (689g)and for 2009 models, the average is 22.2 ounces (629g). The
industry is using less refrigerant in every
passenger vehicle and containing it better.
Any replacement refrigerant should
be evaluated on its total environmental
footprint and consider the best scenarios
for replacing HFC-134a including cost for
the consumer, new vehicle production,

Managing the Change

The SAE Interior Climate Control Standards Committee
has addressed the new design criteria, service equipment and
technician certification that a new refrigerant will require
through J-standards that will soon be published. In addition, the
U.S. EPA has worked with the committee to address various state
regulatory statutes to allow the use of these new refrigerants in
new vehicles.

the existing HFC-134a fleet and effects on the service sector.

For many reasons, it is advisable to allow the natural phaseout of the HFC-134a fleet instead of a legislated phase-out.
When our industry replaced CFC-12 in the U.S. fleet, HFC134a was in production before any regulatory deadline. Presently,
that cannot be said of any proposed substitute refrigerant. When
evaluations are completed on replacement refrigerants, they
should be considered for an orderly and reasonable phase-in
without a mandatory deadline.

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Avoiding problems
Todays industry knowledge should guide the choices for the
future. While it is obvious that a present day HFC-134a system
cannot be converted to use high-pressure carbon dioxide, an
existing system might be retrofitted to use HFO-1234yf with
proper safety modifications. However, the chance for conversion
to other refrigerantsincluding hydrocarbonsexists (as it did
during the CFC-12 conversion) and becomes even more likely if
HFO-1234yf is more costly.
It should also be noted that the history of typical consumer
attitude and HFC-134a usage indicates that charging, not repairing, a leaking system is still very common.This has resulted in the
present atmospheric concentration of HFC-134a that has lead
Europe to take action to replace it.
Even professional service facilities have frequent consumer
requests to only add refrigerant and not repair leaking MVAC
systems. In 2003, the MVAC industry consumed 84 million

Managing the Change

pounds of refrigerant. Of that years total use, roughly 26 million pounds of refrigerant was sold in small cans for consumer use, a very inefficient form of service. Between professional and DIYer uses, it is possible that nearly 25 million
pounds of refrigerant could have been directly released to the
atmosphere by leaking MVAC systems and faulty service practices.
The way forward
It is certain that a change of refrigerant is coming, and that
a cost effective and environmentally acceptable process is possible
without mandatory legislation. It will require cooperation and
commitment by every stakeholder from manufacturer to consumer, and a mutually agreed timetable. It will require aggressive
support by government agencies at the national, state and local
levels.
Regardless of the substitute refrigerant(s) chosen, technicians
will need to be aware of workplace procedures for handling and
storing refrigerants including OSHA and DOT requirements.
Additionally, education will be required to reduce charging of
leaking systems (topping off) by either a DIYer or a service facility. Additional training must be provided to technicians working
on hybrid vehicles to prevent introducing electrical hazards and
system failures through the use of incorrect lubricants.
Revisions to existing regulations should be considered to
restrict sale of HFC-134a to reduce emissions, and regulatory
bodies must revise the rules that allow the sale and use of these
refrigerants. Only certified technicians should be allowed to purchase and use refrigerants in both the mobile and commercial
service sectors. These measures may actually provide more environmental benefit than phasing out R-134a and creating new
issues with retrofitted systems.
An industry-led cooperative phase-out of HFC-134a will
also require unified government and legislative support including:
restricting retrofitting of the HFC-134a fleet and
allowing continued use of that refrigerant until the
vehicle is salvaged,
requiring that all new MVAC systems meet industry
and SAE standards for the refrigerant in use.
allowing only the use of new replacement refrigerants
accepted to the EPAs SNAP list and meeting industry
and SAE specifications,
restricting sale of all refrigerants to only qualified and
certified personnel,
requiring certified technicians for servicing of any
MVAC system,
requiring appropriate and approved MVAC service
equipment for both existing and replacement refrigerants.
The EPA SNAP regulation should be revised so that only
industry and SAE recognized refrigerants are available for use
in MVAC systems, with additional requirements for proper
service fittings and service equipment. All other refrigerants on
the SNAP list for MVAC use should be removed. A
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