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Barrier Removal Status
• In 2006 EC/USA/Japan announced global cooperation removing barriers to alternative refrigerants – CO2– HFC-152a– new fluorocarbons
Unintentional barriers identified
– Department of Transportation accumulator pressure requirements
• Accumulators must be able to withstand 5 times their pressure when charged (static)
• 49 CFR 173:306(f)(1)
– State bans on toxic auto A/C refrigerants• Vehicle air conditioning systems shall be designed with
regard for safety of the of passengers and shall not contain any refrigerant that is toxic
• No toxicity threshold established by the laws
Health & safety requirements
• Occupational Safety and Health Administration (OSHA) requirements for high-pressure gas:– Training– Personal protective equipment– Safe handling of high-pressure gas– Pressure relief devices– Equipment inspection– Worker exposure limits– Ventilation requirements– Proper refrigerant storage
Removing Barriers Through Unprecedented Global Private/Public Cooperation
Alliance of Automobile Manufacturers
Audi – Germany
Behr Group - Germany
BMW – Germany & North America
Centro Ricierche Fiat - Italy
DENSO - Japan
Environmental Protection Agency – USA
European Commission
Hydro - Norway
Ingersoll-Rand - Czech Republic
MACS Worldwide - USA
Modine - USA
Obrist Engineering - Austria
Parker Hannifin - Germany
Prospective Technology - USA
Barrier Removal Team Chaired by Kristen Taddonio, US EPA
PSA Peugeot Citroën – France
Red Dot - USA
Sanden - Japan
Shecco Technology – Norway
Society of Automotive Engineers International
Texas Instruments - Netherlands
TEXA S.p.A. - Italy
Thomas Magnete - Germany
Toyota – Japan & USA
U.S. Army - USA
Volvo - Sweden
VDA - Germany
VOSS Automotive - Germany
Witzenmann - Germany
Great Progress So Far…
• Department of Transportation accumulator pressure requirements waived
• NHTSA confirms no barriers
• OSHA health & safety requirements will be satisfied with standards in development
• No state barriers so long as safety demonstrated
…total success with safety documentation
U.S. Department of Transportation Waives Pressure Requirement
• “[Air conditioning systems] are an integral component of a motor vehicle and necessary for the operation of the vehicle”… “Based on the information you provided, the air conditioning system…is not subject to the Hazardous Materials Regulation.”
–John A. Gale, Chief of Standards Development
US Department of Transportation (DoT) Pipeline and Hazardous Materials Safety Administration
11 July 2006
NHTSA Confirms No Barriers Exist
• The National Highway Traffic and Safety Administration (NHTSA) confirmed no barriers to alternative refrigerants under existing rules
OSHA, EPA, & SAE Cooperate to Assure New Technology Meets US Health and Safety Requirements
• SAE J-Standards in progress: “Recommended practice for servicing R744 [CO2] & R152a mobile air conditioning systems”
• The SAE Standards will meet Occupational Safety and Health Administration (OSHA) requirements for training, personal protective equipment, safe handling, pressure relief devices, equipment inspection, worker exposure, ventilation, and refrigerant storage
State Barriers Removed
• Barriers existed in over a dozen U.S. states: Arizona, Arkansas, Connecticut, D.C., Florida, Idaho, Indiana, Kansas, Louisiana, Maryland, North Dakota, Oklahoma, Texas, Virginia, Washington, Montana, Arizona, Utah
• Barrier removal team confirmed CO2 can be used in Arizona, Arkansas, Connecticut*, D.C., Florida, Idaho, Indiana*, Kansas*, Louisiana*, North Dakota, Oklahoma*, Texas*, Virginia, Utah, Washington
• In MD, the state Department of Environment has not yet made a decision regarding CO2. However, legislation is currently being proposed to bring MD laws into conformity with Federal laws.
* Usage conditions apply. MAC systems must conform to federal guidelines and SAE recommended practices.
• Safety documentation developed by this meeting must satisfy state authorities that Federal exposure limits will be met and that technicians will be able to use CO2 safely
• Critical Items:– Engineering strategies to ensure compliance with Federal
regulations
– SAE standards completed and under development for CO2 safety
– Service shop safety strategy
– Anticipated parts challenges
– Develop comprehensive appendixes covering CO2 studies to date
• Safety report will be posted on EPA website
Safety Documentation Strategies
Thank You
Kristen Taddonio
Manager, Strategic Climate Projects
US EPA Climate Protection Partnerships Division
+1 202 343 9234