A2L refrigerants are the latest refrigerants recognized by the U.S. Environmental Protection Agency and Significant New Alternatives Policy (SNAP) as substitutes in residential and light commercial air conditioning and heat pump systems.
These next-generation refrigerants have lower toxicity and flammability than other classifications of flammable refrigerants, making A2Ls the second-safest category for all refrigerants. Keeping up with code changes is integral to ensuring safe and efficient practices for industry professionals. Given the ongoing EPA-mandated phasedown of HFC refrigerants, there is an increasing demand to switch to A2L refrigerants, and it is becoming more important for industry professionals to anticipate upcoming code changes and understand the rationale behind them.
As we enter a new era of A2L refrigerant implementation, there is a need across the industry for codes and standards to be updated to meet the most current industry requirements. Many codes currently in place are not consistent with the most recent editions of The American Society of Heating, Refrigerating, and Air Conditioning Engineers Standard 15-2022, ASHRAE Standard 34 and UL 60335-2-40, which have all been updated to include A2L refrigerants. To ensure the codes are compatible and cohesive with these standards, changes have been made to the 2024 International Building Code, International Fire Code and International Mechanical Code that permit the usage of A2L refrigerants consistent with ASHRAE Standard 15-2022 and UL 60335-2-40.
Codes currently implemented across many municipalities do not permit the use of A2Ls for comfort cooling applications. Therefore, if local codes are not updated as we progress further through the various stages of the EPA phasedown, there will be significant increases in costs associated with comfort cooling system installation. There is an opportunity for jurisdictions to amend their existing codes with A2L-specific language pulled from the updated 2024 codes to support industry professionals and the market in making the transition earlier and avoiding the rising costs as the HFC phasedown proceeds.
The following points are important to consider with regard to upcoming changes to A2Ls, including the benefits of amending codes early as well as the implications of these changes on industry professionals.
The importance of amending codes early
The EPA mandated a 10% reduction in the production and use of HFC refrigerants from 2021 baseline levels on Jan. 1, 2022. From a more long-term perspective, The American Innovation and Manufacturing Act of 2020 mandates an 85% phasedown of HFC refrigerants over the next 15 years. The application-specific program requires allowances for the production and consumption of HFCs, which will further accelerate the transition from HFCs to A2L refrigerants. It is important for industry professionals to understand that as the phasedown of HFCs proceeds, there are benefits to amending code language preemptively. A mandatory 40% phasedown of HFCs by the EPA will go into effect in January 2024, and it is imperative that businesses prepare for the shift that will follow. For example, the phasedown will cause an extreme shortage of HFCs in the marketplace, resulting in higher costs to the consumer.
These changes will also impact storage practices for A2L refrigerants due to their different flammability characteristics in comparison to other refrigerants. Machinery rooms for Group A2L and B2L refrigerants must comply with elevated temperatures, refrigerant detectors and mechanical ventilation requirements consistent with ASHRAE 15. This means that A2L refrigerants, as well as B2, A2, or B3, cannot be used in areas with open flames, or that have surfaces with temperatures over 800° F (427° C).
These changes also impact storage rooms for manufacturers by requiring that all industry professionals charged with storing A2L refrigerants accommodate these changes with appropriate equipment and storage measures. Allowing for adequate storage space is an area of particular concern for industry professionals as flammability poses a fire risk and therefore a serious safety concern.
Additionally, it is important to differentiate lower-flammability refrigerants from other higher-flammability gases in storage by using the classifications and labeling provisions of the 7th edition of the Globally Harmonized System of Classification and Labelling of Chemicals. IMC refrigerant Table 1103.1 was recently updated with the new refrigerants that have been added to the ASHRAE Standard 34, Designation and Safety Classification of Refrigerants. This table reflects the space needed to accommodate these new standards and comply with safety measures. Overall, current and future storage practices will be impacted, affecting multiple groups of industry professionals, and ultimately resulting in significant cost implications for those that choose to wait to adapt to new code language.
It is important for industry professionals to understand that as the phasedown of HFCs proceeds, there are benefits to amending code language preemptively. A mandatory 40% phasedown of HFCs by the EPA will go into effect in January 2024, and it is imperative that businesses prepare for the shift that will follow. For example, the phasedown will cause an extreme shortage of HFCs in the marketplace, resulting in higher costs to the consumer.
Specific impacts of code changes on industry professionals
Changes around A2Ls will alter the landscape of the industry and require strategic considerations for industry professionals who manufacture, distribute, install and service HVAC systems, such as contractors and service technicians. Some of these changes include standards surrounding refrigerant pipes. For example, the new ASTM A333-18 Standard, Standard Specification for Seamless and Welded Steel Pipe for Low-Temperature Service and other Applications with required Notch Toughness, has been added to Table 1107.4. This table is now consistent with ASHRAE 15 and indicates that certain refrigerants must be used with pipes of a particular material depending on their classification. With these new changes, high probability direct systems for human comfort must use either Group A1 or A2L refrigerants. This may require that technicians change pipes if their current pipes do not comply with these requirements.
These changes specifically impact contractors as they are responsible for installing the equipment that is designed for these refrigerants. According to new I-codes, high probability equipment using Group A2L, A2, A3 or B1 refrigerant shall comply with UL 484, UL/CSA 60335-2-40, or UL/CSA 60335-2-89. By adding this requirement, the code clarifies which safety standards should be used for equipment utilizing these refrigerants. This is consistent with the ASHRAE 15 Standard, Safety Standard for Refrigeration Systems. Contractors should be aware of this new installation process and the accompanying requirements because they may need to update equipment accordingly and amend their current practices.
Upcoming mandates around A2Ls require planning to ensure a safe and efficient transition. Industry professionals should consider adapting to the new code language early and should plan to accommodate measures such as safety, training and building code updates. Those who make appropriate accommodations now will reap the rewards of preparedness later, and will ultimately save on cost, enhance safety, and prevent complications in the future.
For those interested in preparing for these upcoming changes with safety training, amending code language and more, here are two additional resources: Code changes on A2L refrigerants - ICC (iccsafe.org) and www.iccsafe.org/products-and-services/i-codes/a2l-refrigerants-transition.