Capitol Insights By Chris Czarnecki


SNAP & Department of Labor Nomination Updates


EPA Updates Refrigerant Policies The EPA’s Significant New Alternatives Policy (SNAP) program is a regulatory pro- gram that evaluates alternatives to ozone- depleting substances (ODSs). As it relates to the phasedown of HFC refrigerants under the AIM Act, the SNAP program has iden- tified a number of alternative refrigerants that have a lower GWP than traditional HFC refrigerants. These alternative refrigerants are being used to replace HFC refrigerants in a variety of applications, including refrig- eration, air conditioning, and heat pumps. EPA recently published a finalized SNAP 25 rule and proposed a new SNAP 26 rule, which are both summarized below. Most of the affected end uses are very


specific in nature, but it’s worth noting that SNAP 25 does allow for the use of R-32 (a mildly flammable A2L refrigerant) for residential and light commercial applica- tions, as well as heat pumps.


Earlier this year, EPA published a final rule for SNAP 25.


For the end use of residential and light commercial air conditioning and heat pumps (self-contained room air condi- tioners only), the rule allows for the use of R-32, a mildly flammable A2L refriger- ant. This is only acceptable for use in new equipment specifically designed for R-32. The refrigerants included as acceptable


(subject to use conditions) for end uses of centrifugal chillers, positive displacement chillers, industrial process air conditioning using a chiller, and residential dehumidifi- ers include the following (all of which are mildly flammable A2L refrigerants): R-32, R-1234yf, R-452B, R-454A, R-454B, R-454C SNAP 25 allows R-1150 (ethylene) for the


end use of very low-temperature refrigera- tion in equipment designed to reach temper- atures lower than -80 degrees C (-122 degrees F). R-1150 is a flammable A3 refrigerant. EPA also recently proposed SNAP 26,


which covers additional end uses and refrigerants, some of which listed below (acceptable subject to use conditions). All refrigerants listed under SNAP 26 are mildly


32 JULY/AUGUST 2023


flammable A2Ls unless stated otherwise. COMMERCIAL


R-457A, R-516A INDUSTRIAL


ICE MACHINES: R-32,


R-1234yf, R-454A, R-454B, R-454C, R-455A, PROCESS


REFRIGERATION:


R-32 (only in chillers), R-1234yf, R-1234ze(E), R-454A (only in chillers, in equipment with a refrigerant charge capacity less than 200 lbs, or in the high-temperature side of a cascade system, for industrial process refrigeration), R-454B (only in chillers),


R-454C, R-455A, R-457A, R-516A RETAIL FOOD REFRIGERATION – REFRIG-


ERATED FOOD PROCESSING AND DISPENSING EQUIPMENT: R-290 (propane, flammable


A3 refrigerant) RETAIL FOOD REFRIGERATION – SUPER-


MARKET SYSTEMS AND REMOTE CONDENS- ING UNITS: R-1234yf, R1234ze(E), R-454A (only in equipment with a refrigerant charge capacity less than 200 lbs, or in the high-temperature side of a cascade system), R-454C, R-455A, R-457A, R-516A SNAP 26 would also allow for the use of


R-290 (propane, flammable A3 refrigerant) in the end use of self-contained commercial ice machine units and stand-alone retail food refrigeration units. R-290/propane would only be acceptable for use in new units spe- cifically designed for R-290 that comply with UL Standard 60445-2-89 2nd Edition Since SNAP 26 has not yet been finalized,


these stipulations are subject to change. As mentioned, these rules allow for the


use of A2L (mildly flammable), as well as A3 (flammable) refrigerants for applica- ble end-use applications. Make sure you take the proper steps


to prepare yourself, your company, and your employees for A2L and A3 refriger- ants: Invest in training, like the course that ACCA offers, that emphasizes igni- tion prevention and safe handling. Use the right equipment. Follow manufacturer guidelines. Exercise your best judgement.


Concerns over Julie Su’s Nomination


In a recent communication to Chairman Bernie Sanders and Ranking Member Bill Cassidy of the Senate Committee on Health,


Education, Labor and Pensions, Barton James, ACCA president & CEO, expressed the association’s opposition to the nomina- tion of Acting Secretary Julie Su as the new head of the Department of Labor. Under Su’s leadership, the Califor-


nia Labor and Workforce Development Agency supported initiatives that posed a threat to the business models that have fostered prosperity for millions of people. Su played a pivotal role in the passage of A.B. 5, legislation that caused uncertainty among many self-employed individuals. This resulted in controversy and chaos, with over 200 industries and occupations seeking exemptions from the law. Another initiative supported by Su


was the Fast-Food Accountability and Standards Recovery Act (FAST Act). This legislation granted unelected individu- als complete autonomy over the fast-food industry, allowing them to determine wages, establish employment conditions, and create new regulations. The opposition from the state’s Department of Finance, which highlighted increased government costs and a potential fragmented regula- tory environment, further underscored the problematic nature of this law. Additionally, Su oversaw the imple-


mentation of California’s emergency COVID-19 workplace safety rule. This rule placed undue liability on employers for circumstances they neither caused nor created. Employers were required to provide weekly testing to all employ- ees and offer unlimited paid leave to any employee who tested positive for the virus, regardless of whether the infection occurred in the workplace or not. ACCA will continue to fight this nomi-


nation on behalf of contractors and small businesses and keep you up-to-date on any changes.


Chris Czarnecki is ACCA’s Director of Government Relations & Advocacy and is responsible for government relations in Washington, D.C. He can be reached at chris.czarnecki@acca.org.


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