Written on: August 1, 2015 by Doug Raymond
Finally, The U.S. Environmental Protection Agency (EPA) has released its final version of the Significant New Alternatives Policy (SNAP) rule dealing with Global Warming Potential (GWP) Compounds. The compound of note for the aerosol industry is HFC-134a, which has a high GWP. Over the years, the aerosol industry has relied on HFC-134a for a variety of essential uses due to the fact that it is a non-volatile organic compound (non-VOC) and is not flammable.
EPA had originally proposed a ban on HFC-134a as a propellant in aerosols as of Jan. 1, 2016. Industry submitted many comments to EPA on why this was not enough time to reformulate all the products using this compound, as well as some essential uses that would still need HFC-134a.
Below is a short summary of the major issues with the final version of the rule:
As you can see, there are numerous essential applications for which EPA has granted the continued use of HFC-134a. Several of these uses were added to the EPA rule due to a lot of hard work by numerous companies to preserve the use of HFC-134a in these important products.
Unfortunately, industry was not successful in preserving the use of HFC-134a in some products, most notably:
Even though several companies made very good arguments to try and preserve the use of HFC-134a in the above products, EPA did not grant a use exemption. Thus, in July or August of 2016, HFC-134a will not be used in those products any more.
However, EPA is allowing all products made before the effective date to have an unlimited sell-through. This is good news and means any product made before the effective date can be sold without having to worry about a sell-through date.
Industry worked cooperatively with each other and the agency on this rule. Everyone tried to develop the best rule we could. While we did not get everything we asked for, EPA did grant some of our requests. Now, we have to ensure that the work the California Air resources Board (CARB) is doing on the Short Lived Climate Pollutants (SLCP) does not interfere with the SNAP rule. The current essential uses need to be maintained.
On July 1, CARB staff conducted a webinar on the 2014 Consumer & Commercial Products Survey. CARB released instructions for using the new Consumer Products Reporting Tool (CPRT). CPRT instructions and webinar slides can be found at http://www.arb.ca.gov/consprod/regact/2014surv/2014main.htm.
The deadline for 2014 data is Nov. 1, 2015 and another webinar is scheduled for Sept. 16, 2015. More to come on this issue!