Posted by jdemaris on December 28, 2007 at 08:10:36 from (67.142.130.35):
I've read through several posts on these forums about using newer refrigerants, e.g. 134A on tractors and cars.
I also read several posts claiming it's illegal to buy the stuff unless certified. Last thread is at Tool Talk. Bob Huntress posted there - that it cannot be legally purchased without certification.
I disagree and have read through way too much EPA documents. I going to paste in a few pieces of it here, but I'm curious what some others on this forum think - or know about it.
As I understand it - it goes like this. The EPA has never banned the sale of 134A to anyone. They've considered it, but not acted on it.
They do prohibit the intentional release of it into the atmosphere - but the word "intentional" has been argued.
They do require that a " technician" be certified to install refrigerant. However, the definition of the word "technician" had been argued, and changed several times. Same with the word "refrigerant." It goes on and on.
Any legal document must have specific definitions for words used - otherwise it reverts to common, everyday useage and connotation.
As far as I can tell - a "technician" must meet certain legal requirements, but you don't have to be what the EPA calls a "technician", to work on your own equipment with certain classes of refrigerants.
If it sounds confusing, that's because it is - at least to me.
Anybody can legally buy 134A in most, and perhaps all states. There are some states looking to make their own laws - which I can't say I'm up on. No problem here in New York.
Here's some wording direct from the EPA. The endless paperwork is almost scary - since we're all paying for it.
September 28, 2006 and still current as of Dec, 2007 In the US, the Protocol is implemented by the Clean Air Act, and regulations issued under the Act ended the production of CFC-12 for air conditioning and refrigeration uses on December 31, 1995.
CFC-12 (also known by the trade name Freon) was widely used in air conditioners for automobiles and trucks for over 30 years. While new vehicles no longer use CFC-12, most vehicles built before 1994 still require its use for servicing.
In 1994, EPA established the SNAP Program to review alternatives to ozone-depleting substances like CFC-12. (Significant New Alternatives Policy). Under the SNAP program, the motor vehicle air conditioning (MVAC) end-use includes all forms of air conditioning that provide cooling to the passenger compartments in moving vehicles. All use conditions, unacceptability findings, and other regulatory actions for this end-use apply equally to on-road vehicles, such as automobiles and trucks, and to off-road vehicles, such as tractors, combines, construction, mining equipment, boats, planes, and trains.
BARRIER HOSES: HCFC-22, a component in some blends, can seep out through traditional hoses. Therefore, when using these blends, the technician must ensure that new, less permeable "barrier" hoses are used. These hoses must be installed if the system currently uses old, non-barrier hoses.. The table of refrigerants below notes this additional requirement where appropriate
Technicians who repair or service CFC-12 and HFC-134a motor vehicle air conditioners must be trained and certified by an EPA approved organization. Technicians who repair or service MVACs that use blend refrigerants must be trained and certified by an EPA-approved organization. If a technician is already trained and certified to handle CFC-12 or HFC-134a, he does not need to be recertified to handle a blend refrigerant. Note, that while certification is required in order to service motor vehicle air-conditioners, certification is not required to purchase R-134a. Right now, there is no restriction on the sale of HFC-134a, so anyone may purchase it. This year, EPA will issue a proposed rule under section 608 of the Act that will include a proposal to restrict the sale of HFC-134a so that only technicians certified under sections 608 and 609 may purchase it. After the proposed rule is published, EPA will review comments from the public on the proposal and will then publish a final rule sometime in 1998 or 1999.
EPA is also amending the prohibition against venting substitute refrigerants to reflect the changes in the definitions. These changes are being finalized to make certain that the regulations promulgated on March 12, 2004 cannot be construed as a restriction on the sales of substitutes that do not consist of an ozone-depleting substance (ODS), such as pure hydrofluorocarbon (HFC) and perfluorocarbon (PFC) substitutes. The March 12, 2004 final rule was not intended to either mandate section 608 technician certification for those maintaining, repairing, or servicing appliances using substitutes that do not consist of a class I or class II ODS or to restrict the sale of substitutes that do not contribute to the depletion of the stratospheric ozone layer, such as pure HFC and PFC substitutes
Technician means any person who performs maintenance, service, or repair that could be reasonably expected to release class I or class II refrigerants from appliances, except for MVACs, into the atmosphere. A petition for review challenging the March 12, 2004 final rule stated that the amended definition of technician could be misinterpreted to mean that technicians servicing and maintaining MVACs must also have section 608 technician certification.
EPA inadvertently removed the text except for MVACs from the definition of technician, at Sec. 82.152. Since EPA did not intend for the amended definition of technician to include persons servicing or repairing MVACs, the Agency is reverting to the original definition.
One of EPA's amended definitions of ``technician'' includes any person (including DIYers or process operators) who performs maintenance, service, or repair, that could be reasonably expected to release refrigerants from appliances into the atmosphere. This has been changed, back and forth, many times.
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