On November 9, 2015, EPA published a proposal to revise its
Clean Air Act refrigerant regulations under the stratospheric ozone
protection program, which cover all appliances containing a
refrigerant, including HVAC systems, commercial food refrigeration
appliances, and industrial cooling processes. The proposal
would significantly increase the regulatory burden associated with
those regulations in two ways.
First, the proposal would expand the definition of refrigerants
to cover not only the ozone-depleting CFCs and HCFCs that the
program was originally designed to cover, but also all
"substitutes" for those refrigerants that, until now,
were not subject to the program. If EPA finalizes this rule
as proposed, the refrigerant regulations would apply to many more
HVAC, refrigerators, and industrial processes than ever before,
requiring the owners of those appliance to comply with a variety of
maintenance, repair, disposal, recordkeeping, and reporting
requirements.
