Despite lobbying efforts to force HFO as the solution in MVACs, the industry that will be handling the substance still has many concerns over its safety and environmental impact. In its comments to the US EPA this week, the Automotive Recyclers Association mentioned unsolved questions of storage, disposal, occupational hazard, and higher costs. The deadline for public comment on HFO-1234yf has been extended a second time, while new toxicity tests have been recommended.

With the deadline for submitting comments to the US EPA regarding the approval of using refrigerant HFO-1234yf in Motor Vehicle Air Conditioning (MVACs) under the Significant New Alternatives Policy (SNAP) Program being extended, the Automotive Recyclers Association (ARA) has in its submission highlighted the need for further in-depth research before a potential approval of the fluid.

EPA determines additional testing on HFO needed

Last week the EPA issued a Significant New Use Rule (SNUR) for HFO1234yf, requiring manufacturers and importers of the substance to notify EPA of any uses that differ from those outlined in premanufacture (PMN) notices already filed with the agency. The EPA subsequently decided to extend for the second time the comment period regarding the SNAP approval of HFO in new MVAC systems through to 15 February 2010, in order to allow for some time overlap between the SNUR process on HFO running and the SNAP process on HFO, as they concern the same substance.

The SNUR document on HFO recommends that additional testing on the substance be undertaken: “EPA has determined that the results of an acute inhalation toxicity study (OPPTS Harmonized Test Guideline 870.1300 or OECD 403 test guideline) with rabbits would help characterize the human health effects of the PMN substance”.

ARA urges EPA to assess total lifecycle of HFO

Concerned with occupational dangers and potential costs incurred by recycling facilities (ARA represents over 4,500 auto recycling facilities in the US and 14 other countries) and their employees as well as environmental impacts of HFO, the Automotive Recyclers Association has urged the EPA to look at the total lifecycle of the fluid, and consider all ramifications that may occur from the use, and ultimately, the disposal of the new fluid. In its submission, it underlines the following issues of concern that the proposed rule fails to address:

• Storage
• Disposal
• Occupational hazard
• Internal cost associated with specialized equipment
• Impact on air quality
• Storm water run-off requirements

ARA, hence maintains that there is a need for further information and in-depth research for this new fluid.

About ARA

Since 1943, the Automotive Recyclers Association (ARA) is an international trade association, which has represented an industry dedicated to the efficient removal and reuse of automotive parts, and the safe disposal of inoperable motor vehicles. ARA represents over 4,500 auto recycling facilities in the United States and fourteen other countries around the world.