In the previous post, we looked at the global path to a safe transition to low-GWP refrigerants, and the impact that actions by states like California are having on creating a patchwork of regulations and move us toward the use of highly flammable refrigerants. Here, I trace how the move impacts standards and codes, as well as what it means for equipment manufacturers and consumers.
As the body governing standards for applications, ASHRAE has developed ASHRAE 34 as the standard that classifies refrigerants based on toxicity and flammability. ASHRAE 15 is the standard governing the installation of systems using these refrigerants. ASHRAE 15 Addendum “d” was approved in October 2018 to regulate the use of A2Ls in “high probability systems,” which include unitary systems, split systems, multi-split systems, rooftop units and other similar equipment. Addendum “d” stipulates, among other things, that for larger charge systems, leak detectors are required, and they must trigger mitigation (e.g., ventilation to dilute the refrigerant) if 25% of the lower flammability limit concentration is detected. ASHRAE Addendum “h” regulates the use of A2Ls in systems located in machine rooms and stipulates that when the charge exceeds the Refrigerant Concentration Limit (RCL) the system must be installed in a machine room with a number of important safeguards including ventilation requirements. Neither Addenda “d,” nor “h,” however, covers refrigeration application. ASHRAE committees are currently working on a separate addendum for these applications.
UL governs standards for equipment. UL 60335-2-40 regulates the use of A2L refrigerants in air conditioning equipment while UL 60335-2-89 does so for refrigeration equipment. These standards are used by manufacturers for building and listing equipment using flammable refrigerants. UL 60335-2-40 was recently finalized to fully allow the use of A2Ls and is available for incorporation into model codes. The process for finalizing UL 60335-2-89 was started in July 2019. Edition 1 of UL 60335-2-89 allowed charges of 150g of any flammable refrigerant, and while Edition 2 will be based on IEC 60335-2-89, which allows 500g of R-290 and 1.2kg of A2Ls, UL 60335-2-89 may deviate from those charge limits.
Once new standards are completed for A2Ls and A3s, they need to be included in the model codes, which are then used to write state and local building and fire codes. The adoption of these standards into the International Commercial Code (ICC) and the Uniform Mechanical Code (UMC), the two main model codes used by state and local jurisdictions, is not certain. The ICC recently voted against a measure to adopt UL 60335-2-40 into the 2021 model code. As the safety standards were only just completed, they were not adopted into the model codes in 2019. If these standards are not adopted into the two main model codes, states seeking to phaseout HFCs will have to orchestrate their adoption into state or local building codes. Leaders of national fire service organizations have expressed concern about exposing firefighters to flammable chemicals during fires.
Code uncertainties put a safe transition at risk
Since the UMC, which California predominately uses, failed to adopt ASHRAE 15 and UL-60335-2-40, the state will need to implement these standards directly into state building codes rather than through the adoption of the model codes. Typically, AC original equipment manufacturers (OEMs) require certainty that the building codes are in their final form at least three years before a regulatory implementation date. They need this time to engineer new equipment, test its efficacy and safety and certify that equipment with third-party testing labs like UL. This is an expensive and time-consuming process that must be completed before equipment can be commercialized. In addition, supply chains must be filled with parts used in equipment and equipment must be stocked in warehouses to be prepared for the transition.
To give the OEMs the time they need, the California building codes needed to be updated by January 1, 2020. Of course, that date has passed and, at this point, direct adoption of the safety standard during the next triennial code cycle would lead to certainty at publication of the building code at the beginning of 2022. CalFIRE, the California Department of Forestry and Fire Protection, will likely need to propose the addition of the ASHRAE and UL standards to California’s building code by June 2021 after going through an extensive stakeholder process, leaving just 18 months before CARB’s enforcement date. And, should CalFIRE require adjustments to ASHRAE 15 and UL-60335-2-40 beyond non-equipment related changes (e.g., labelling requirements), the OEMs and their suppliers would have very little time to respond. Even if all goes according to plan, this process puts the safe transition at risk with excessively tight timing.
Other alternatives include state legislation to require that the standards are adopted into the building codes. Should the codes be effective by January 2021, most, but not all, OEMs believe they could still meet CARB’s proposed January 1, 2023 implementation date. If this legislative option does not materialize, the industry is requesting that CARB postpone its enforcement date to three years plus the following January after the safety standards are adopted into the building codes.
This uncertainty is putting the safe refrigerant transition in serious jeopardy. Equipment using lower and higher flammability refrigerants must be thoroughly tested and all those who handle it must be properly trained. If the building codes are not updated very soon to incorporate ASHRAE 15 and UL-60335-2-40 as they are currently written and CARB enforces a January 1, 2023 implementation date, OEMs and the rest of the supply chain will have difficulty complying. Suppliers may not have sufficient parts available, technicians may not be fully trained — especially if the codes deviate from the standards as written, and the opportunity to further field-test equipment may be lost.
If equipment manufacturers are not able to rush their product to market, they may not have equipment that is legal to sell in California on January 1, 2023.
Consider this scenario: CARB enacts the proposed regulations to take effect on January 1, 2023; CalFIRE submits a code change proposal in June 2021; and the triennial code is published in early 2022. This would leave OEMs with less than eight months to build, test and qualify systems — and that is assuming the code council does not make changes to CalFIRE’s submission.
Under these circumstances, the OEMs and their suppliers cannot meet the schedule, which means that California businesses and residents will be unable to purchase new, legal AC equipment. Thus, consumers’ only option should their AC units break down is to repair it. Should repairs be too expensive or impossible, they simply will not have air conditioning.