Our Threatened Ozone Layer
The ozone layer acts as a blanket in the stratosphere that protects us from
harmful ultraviolet (UV) radiation.
Scientists worldwide believe that man-made
chemicals such as CFC-12
(also known by the trade name Freon) are rapidly destroying this layer of gas 10
to 30 miles above the earth's surface. Strong ultra-violet radiation breaks the
CFC-12 molecules apart, releasing chlorine. A single chlorine atom can destroy
over one hundred thousand ozone molecules. Ozone loss in the atmosphere is
likely to lead to an increase in cataracts and skin cancer, which is now one of
the fastest growing forms of cancer, and could weaken the human immune system.
In the U.S., one person dies of skin cancer every hour. Agriculture, as well as
plant and animal life, may also be dramatically affected.
Remember that ozone is "good up high, bad nearby": even though it protects us when it is in the stratosphere, ozone at ground level can be harmful to breathe and is a prime ingredient in smog. Many man-made sources such as tailpipe emissions from cars contribute to ground-level ozone.
The United States has joined over 160 countries as
a Party to the international treaty known as the Montreal Protocol. All
developed countries agreed to phase out production of most ozone-depleting
substances, including CFCs, by the end of 1995. The 1990 Clean Air Act
Amendments incorporated this production ban date and directed EPA to develop
regulations to maximize recycling, ban nonessential
uses, develop labeling requirements, and examine safe alternatives for ozone-depleting
Impact of Motor Vehicle Air Conditioners
One of the largest uses of CFC-12 in the U.S. is
as a refrigerant in motor vehicle air conditioners (MVACs). Section 609 of the Clean
Air Act gives EPA the authority to establish requirements to pre-vent the
release of refrigerants during the servicing of MVACs and to require recycling
of refrigerants. Widespread refrigerant recycling reduces the demand for virgin
CFC-12 and thus extends the time that it will be available.
Recycling means the use of a machine to
remove impurities and oil and then recharge the refrigerant into either the same
car or a different car. Recycled refrigerant is not as pure as reclaimed
refrigerant. Recycling occurs in the service shop.
Reclamation means the removal of all oil and impurities beyond that provided
by on-site recycling equipment, and reclaimed refrigerant is essentially
identical to new, unused refrigerant. Reclamation cannot be performed in the
service shop. Rather, the shop generally sends refrigerant either back to the
manufacturer or directly to a reclamation facility.
Handling Requirements for CFC-12
Another section of the Clean Air Act, section 608, prohibits
releasing CFC-12 into the atmosphere. The prohibition
on venting CFC-12 has been in effect since 1992.
The original regulation
under section 609 was published in July 1992. That regulation established
standards for equipment that recovers
CFC-12 refrigerant from motor vehicle air conditioners, rules for
training and testing technicians to handle this equipment, and
record-keeping requirements for service facilities and for refrigerant
retailers. A supplemental final rule published in May 1995 established a
standard for equipment that recovers but does not recycle CFC-12, and training
and testing technicians to handle this equipment.
Technicians repairing or servicing CFC-12 MVACs
must use either recover/recycle
or recover-only equipment approved by EPA. Recover/ recycle equipment cleans the
refrigerant so that oil, air, and moisture contaminants reach acceptably low
Technician Training and Certification
Technicians who repair or service CFC-12 motor
vehicle air conditioners must be trained and certified by an EPA-approved
organization. Training programs must include information on the
proper use of equipment, the regulatory requirements, the importance of
refrigerant recovery, and the effects of ozone depletion. To be certified,
technicians must pass a test demonstrating their knowledge in these areas.
Service shops must certify to EPA that they own approved CFC-12 equipment. If
refrigerant is recovered and sent to a reclamation facility, the name and
address of that facility must be kept on file.
Section 609 has long prohibited the sale of small cans of ozone-depleting refrigerants to anyone other than a certified technician. The sale of any size container of CFC-12 to anyone other than certified technicians was prohibited under section 608 of the Act beginning on November 14, 1994. This provision is intended to discourage "do-it-yourselfers" who recharge their own air conditioners. Such individuals often release refrigerant because they typically do not have access to recovery/recycling equipment. The Agency encourages "do-it- yourselfers" to bring their cars to certified technicians who can properly fix air conditioners using approved equipment. This avoids damage to A/C equipment by improper charging and helps to protect the environment.
Automotive Service Using Non-Ozone Depleting Refrigerants
Under the Clean Air Act, releasing non-ozone depleting refrigerants such as
HFC-134a into the atmosphere has been prohibited since November 15, 1995.
Section 609 of the Act requires EPA to promulgate standards for refrigerant
recycling equipment and for the proper use of that equipment. The standards
became effective January 29, 1998.
Beginning at that time, any equipment used to recover or recycle HFC-134a
from MVACs must meet EPA standards and be tested by an approved testing
laboratory (UL or ETL). In addition, equipment that recovers, but does not
recycle, one single, specific blend refrigerant must meet EPA standards and be
tested by UL or ETL. Also, on the effective date automotive service technicians
must be certified to handle non-ozone-depleting refrigerants.
The EPA’s intention is to grandfather automotive service technicians
currently certified under section 609, so that they will not need to be
re-certified in order to operate recover/recycle and recover-only equipment
designed to service MVAC systems that use refrigerants other than CFC-12. Note
that this regulation does not restrict the sale of HFC-134a or other
non-ozone-depleting refrigerants. At this time, anyone may purchase these
refrigerants, no matter what size container they come in.
Handling Requirements for HFC-134a
Venting HFC-134a Refrigerant
Section 608 of the Clean Air Act prohibits
releasing HFC-134a into the atmosphere. The prohibition on venting HFC-134a
has been in effect since November 1995.
repair or service HFC-134a MVACs must recover the refrigerant and either recycle
it on-site, or send it off-site to a reclamation facility so that it may be
purified according to ARI Standard 700. Technicians must use EPA-approved
equipment to perform the refrigerant recovery and recycling.
Recover/recycle equipment cleans the refrigerant so that oil, air, and moisture
contaminants reach acceptably low levels. Note that certain EPA-approved models
can recycle both CFC-12 and HFC-134a refrigerants.
Converting CFC-12 Equipment for Use with HFC-134a
EPA regulations prohibit technicians from changing fittings on the same unit
back and forth so that the unit is used for CFC-12 in the morning, HFC-134a in
the afternoon, then back to CFC-12 again, etc. EPA regulations specify that when
equipment is converted for use with a new refrigerant, the converted unit must
be able to meet the applicable equipment standard set forth in the regulations.
CFC-12 equipment may be permanently converted for use with HFC-134a under
certain conditions. EPA intends to issue regulations placing certain
restrictions on these retrofits in the future. Those restrictions may require
that the manufacturer's service representative rather than the automotive
service technician perform the retrofit, that a unit may only be retrofitted if
retrofit procedures have been certified by an independent testing laboratory
such as Underwriters Laboratories, and that an appropriate label is affixed to
the unit. In addition, the retrofitted unit must meet the technical
specifications of SAE standard J2210 and must have the capacity to purify used
refrigerant to SAE standard J2099 for safe and direct return to the air
conditioner following repairs.
Currently, however, in the absence of any EPA regulations, a service facility
may perform such a retrofit, or may have the equipment manufacturer's service
representative perform the retrofit, as long as the fittings are changed in
accordance with EPA's Significant New Alternative Policy (SNAP) pro-gram
regulations. The Agency cautions technicians, however, that even though
recovering a given refrigerant using permanently converted equipment is legal,
it may not be technically desirable. The equipment is designed to be compatible
with specific refrigerants, and incompatible materials may cause short
circuits, damage to seals, and compressor failure. Technicians should check
with the recovery equipment manufacturer for recommendations about the recovery
of refrigerants other than the refrigerant the equipment was originally
intend-ed to recover. Conversion of recovery equipment for use with other
refrigerants may also invalidate any warranties offered by the equipment
Technician Training and Certification
Technicians who repair or service HFC-134a MVACs
must be trained and certified by an EPA-approved
organization. If a technician is already trained and certified to
handle CFC-12, he does not need to be re-certified to handle HFC-134a.
Service shops must certify to EPA that they own approved HFC-134a
equipment. Note that this certification is a one-time requirement, so that if a
shop purchased a piece of CFC-12 recycling equipment in the past, and sent the
certification to EPA, the shop does not need to send a second certification to
EPA when it purchases a second piece of equipment, no matter what refrigerant
that equipment is designed to handle. If refrigerant is recovered and sent to
a reclamation facility, the shop must retain the name and address of that
Handling Other Refrigerants That Substitute for CFC-12
Venting Substitute Refrigerants
Other than HFC-134a, all
EPA-accepted refrigerants that substitute for CFC-12 in motor
vehicles, and that are currently on the market are blends that contain
ozone-depleting HCFCs such as R-22, R-142b,
and R-124. Section 608 of the Clean Air Act prohibits venting any of these new
blend substitutes into the atmosphere. The prohibition on venting these
ozone-depleting blends has been in effect since 1992.
Using Older Equipment to Recover Blends
Technicians have a number of choices in recovering blend refrigerants. One
option is that a technician may permanently dedicate an older piece of
equipment he owns to recovering one or more blend refrigerants. The technician
may also use this equipment to recover contaminated CFC-12 and HFC-134a and
other "mystery mixtures." This equipment, however, may no longer be
used to recover uncontaminated CFC-12 or HFC-134a. Refrigerant recovered using
this kind of "junk" tank must then be shipped off-site for reclamation
Using New Equipment to Recover Blends
Another option for recovering a blend refrigerant is to use a new piece of
EPA-approved equipment designed to recover, but not recycle, any single,
specific blend refrigerant. The EPA regulation published in December 1997,
includes an appendix that describes the standards that this new equipment must
As of June 1, 1998, EPA allows recycling of
refrigerant blends used in motor vehicle air conditioning systems (MVACs),
provided that recycling equipment meets a new Underwriters Laboratories (UL)
standard (Standard 2964) and refrigerant
is returned to the vehicle from which it was removed. The only exception is for
fleets of vehicles with a common owner; recycled blend refrigerant may be moved
among vehicles within such a fleet. EPA detailed this policy in a June
1, 1998 open letter to the industry.
Converting CFC-12 or HFC-134a Recover/Recycle Equipment for Use with Blend
EPA currently prohibits the conversion of existing CFC-12 or HFC-134a
recycling equipment for either temporary or permanent use with a blend
refrigerant, unless the equipment is used only to recover, but not to recycle,
the refrigerant. In the future, EPA may issue regulations allowing these
conversions but placing certain restrictions on who performs the conversions,
what models may be converted, etc.
Retrofitting Vehicles to Alternative Refrigerants
Although section 609 of the Act does not govern retrofitting, section 612 of the Act, which describes the Agency's Significant New Alternatives Policy (SNAP) program, does require that when retro-fitting a CFC-12 vehicle for use with another refrigerant, the technician must first extract the CFC-12, must cover the CFC-12 label with a label that indicates the new refrigerant in the system and other information, and must affix new fittings unique to that refrigerant. In addition, if a technician is retrofitting a vehicle to a refrigerant that contains R-22, the technician must ensure that only barrier hoses are used in the A/C system. Finally, if the system includes a pressure relief device, the technician must install a high-pressure compressor shutoff switch to prevent the compressor from increasing pressure until the refrigerant is vented.