2 Refrigerants, Ozone, and Environmental Regulations
Understand how refrigerants affect ozone depletion and climate, and how U.S. laws and international agreements regulate refrigerant use, emissions, and substitutes.
Ozone in the atmosphere
Stratospheric ozone forms a protective layer that absorbs much of the Sun’s harmful UV-B radiation. When less stratospheric ozone is present, more UV-B reaches Earth, increasing risks such as skin cancer and cataracts and harming ecosystems.
Ground-level ozone is an air pollutant. Protecting stratospheric ozone does not mean ozone is beneficial everywhere.
Ozone depletion and climate impacts
Certain ozone-depleting substances (ODS), including chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), can remain in the atmosphere long enough to reach the stratosphere. Ultraviolet light breaks them down, releasing chlorine atoms that destroy ozone through catalytic reactions. Bromine-containing ODS can also destroy ozone. Because the process is catalytic, one released atom can participate in many ozone-destroying reactions.
compares a substance’s ability to deplete stratospheric ozone with a reference substance. CFC-11 is the common reference and has an ODP of 1.
compares a substance’s heat-trapping effect with carbon dioxide over a specified time period. A refrigerant can have little or no ODP and still have a high GWP. Many hydrofluorocarbons (HFCs) contain no chlorine and therefore do not significantly deplete ozone, but some are powerful greenhouse gases.
Refrigerant emissions can contribute to climate change directly, while the energy used to operate equipment can contribute indirectly. Preventing leaks and using efficient, appropriate equipment help reduce these impacts.
and refrigerant management
Title VI of the directs federal action to protect the stratospheric ozone layer. Its programs include controlling ODS production and import, reducing refrigerant emissions from stationary equipment, and reviewing substitutes. EPA’s regulations are in 40 CFR Part 82, Subpart F.
Technicians who perform work that could reasonably be expected to release refrigerant must hold the applicable EPA certification. Type I covers small appliances, Type II covers high- and very-high-pressure appliances, Type III covers low-pressure appliances, and Universal covers all types.
Intentionally venting ODS refrigerants or their substitutes during maintenance, service, repair, or disposal is generally prohibited. A limited allowance covers de minimis releases during good-faith recovery efforts, such as when connecting or disconnecting hoses. EPA has also adopted specific, limited exemptions for certain substitutes and uses; these exceptions are not general permission to vent refrigerants.
Refrigerant must be recovered using appropriate practices and equipment. It generally must be reclaimed to required purity before it can be resold as reclaimed refrigerant. Refrigerant sales are generally restricted to appropriately certified technicians, subject to specified exceptions.
Special leak-repair requirements apply to appliances containing 50 pounds or more of ozone-depleting refrigerant when their leak rates exceed applicable thresholds. The thresholds vary by appliance type. Do not assume these leak-repair requirements automatically apply to every appliance charged with an HFC substitute.
For example, a technician servicing stationary equipment must not intentionally release its refrigerant to the atmosphere. The technician should recover it using the required procedures; a small incidental release while making a good-faith attempt to recover refrigerant is treated differently from deliberately venting it.
ODS phaseout
The is the international agreement to phase out ozone-depleting chemicals. In the United States, the implements ODS controls.
U.S. production and import of most Class I ODS, including CFCs, have been phased out, subject to limited exceptions. Most HCFC production and import were phased out in 2020, with limited exceptions and remaining HCFC phaseout steps.
A phaseout of production or import does not necessarily mean existing equipment must immediately be discarded. Recovered or existing supplies may still be relevant to servicing, subject to current rules.
Substitutes and the HFC phasedown
The program, established under Section 612, evaluates substitutes for ODS and HFCs. EPA decisions depend on the substance’s intended use and may list it as acceptable, acceptable subject to use conditions, or unacceptable. A substitute is not automatically approved for every application, so technicians and equipment owners must follow the applicable use conditions.
The , enacted in 2020, directs EPA to phase down HFC production and consumption through an allowance program, reaching of baseline levels by 2036. This climate-focused HFC phasedown is distinct from the ozone-protection phaseout of CFCs and HCFCs: HFCs generally do not deplete ozone, but many have high GWPs.