Over the past few months, I have been collaborating with HARDI (Heating, Airconditioning & Refrigeration Distributors International) on a white paper that they are planning on the subject of R-410A and its impact on our industry. In the process, one of the association's members raised the question of whether HFC refrigerant sales should be limited to EPA-certified technicians only. Presently, there are no restrictions on the sales of these products, and it would be a good idea to know just where HVACR supply houses and wholesalers stand on this issue. In fact, I'm sure that the folks at HARDI would like to know.
Obviously, HVACR contractors and their associations would like to see sales of these chemicals limited to just qualified technicians. For example, ACCA (Air Conditioning Contractors Association) has already done much lobbying to bring about such legislation. So, should HVACR wholesalers vigorously support them in this fight? Let's consider the facts.
First, they say that HFCs (Hydro Fluoro Carbons) don't do any damage to the atmosphere - at least that's the current thinking of environmental scientists. However, they believed the same was true of HCFCs and CFCs until just a few years ago. And if we knew then what we know now, we would have started recovering and recycling refrigerants from the beginning. Then we probably would never have had the current extreme phaseout legislation. And if we find that dumping HFCs creates a problem sometime in the future, what will we switch to after that?
My personal opinion is that legislators have allowed HFCs to be sold over the counter to anyone with the ready cash, because of their experience with R-134A. As the replacement for R-12 (a CFC), most of this product is finding use in the automobile air-conditioner market. And for years prior to the phaseout legislation, R-12 was sold over the counter in all auto parts stores. I don't believe that anyone is willing to go up against this huge market and request restrictions to limit sales to just qualified technicians (however, I'm sure the auto mechanics would be all for that).
Be that as it may, it does seem that there should be some sort of restrictions on sales of bulk quantities of R-134A, because the main market for such large quantities of refrigerants is for use in huge commercial screw and centrifugal chillers. Obviously, only qualified technicians should be allowed to do such work. And since asphyxiation becomes possible whenever large quantities of HFCs are released, shouldn't there be some licensing required to buy it in bulk?
The interesting thing is that the EPA passed rulings (thanks to strong lobbying by refrigerant manufacturers) which forbid HVACR contractors to do their own HCFC and CFC recycling for the purpose of reselling it. The reason? They said that they were concerned about the possibility of contamination (however, the inside of A/C and refrigeration systems isn't exactly an EPA concern). But what will happen to all the HFC systems when unqualified and unlicensed people think they are qualified to recharge them with over-the-counter refrigerants?
You know the problem here! With our industry facing the phaseout of R-22 and going to new systems that use R-410A, we are currently in a training crisis. We know that the lubricants that are used with HFCs are very susceptible to moisture and that special training will be required to prevent the new systems from being terminally damaged through poor (standard) service techniques. Also, with blended HFCs, any refrigerant loss requires a complete refrigerant removal and a new charge to be carefully weighed back in, to keep the proper balance of refrigerants and to maintain proper operation.
Not only that, R-410A is the highest-pressure refrigerant that we have encountered in normal air-conditioning service to date. Isn't anyone worried about Joe Blow buying a 25-pound drum of the stuff and harming or killing himself or anyone else? I have my concerns.
If the EPA is really worried about contaminating HVACR systems (and not just serving the special interests of the refrigerant manufacturers), then they should be especially worried about over-the-counter sales of HFC refrigerants to unqualified personnel. And if your company sells HVACR equipment, you should be concerned too - as should all equipment manufacturers. I think that everyone should be up in arms over this problem!
Of course, the EPA card that service technicians must carry was designed as an EPA certification that the bearers know how to protect the environment against the release of ozone-layer-damaging refrigerants, and that is (apparently) no longer a concern with HFCs. However, our industry has no accepted national certification of service-technician qualifications. If no national organization (such as the EPA) is willing to test and certify that people are qualified to use these refrigerants properly before they can be purchased, the net result for our industry will be a disastrous failure of the conversion to HFC refrigerants.
So, that's my viewpoint. What's yours? One way or the other, you should let your industry's national association know what you think. Otherwise, nothing at all may be done, or, something that you don't want to be done may be forced on you. Either way, it's your company's future. <<
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