HFC and HFO refrigerants – the PFAS issue
Are per-and polyfluoroalkyl substances (PFAS) about to be banned? PFAS are synthetic chemicals that have been in use since the 1950’s. They are highly resistant to heat, water, and oil, making them useful for a variety of applications, including packaging, clothes, cook ware and carpets. PFAS substances are persistent in the environment and do not break down easily and so can remain there for long periods of time. They can also accumulate in the human body over time. In particular, concerns have been raised about the PFAS, trifluoroacetic acid (TFA) which is generated when certain refrigerants, in particular hydrofluoro-olefins (HFOs) are released.
In early February the EU European Chemicals Agency (ECHA) published a proposal from Denmark, Germany, the Netherlands, Norway and Sweden to restrict PFAS chemicals under the EU’s chemicals REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation. This proposes a restriction on the manufacture, use and sale of certain f-gas substances and blends. Refrigerants included are both HFCs and HFOs and include HFC-125, HFC-134a, HFC-143a, HFO-1234yf, HFO-1234ze(E), HFO–1336mzz(Z) and HFO-1336mzz(E). If accepted the proposal would apply 18 months after entry into force (EiF).
Critically the proposal provides a definition of what a PFAS is. The suggested definition is ‘substances that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it)’. This is similar to a definition adopted by the Organisation for Economic Co-operation and Development (OECD) in 2021 and one already proposed in another PFAS restriction intention on firefighting foams. There are exclusions from the scope of these definitions but f-gases and TFA would not fall within the proposed exclusions except in some very specific cases. These include:
- Refrigerants in low-temperature refrigeration below -50°C (-58°F) until 6.5 years after EiF.
- Refrigerants in laboratory test and measurement equipment until 13.5 years after EiF.
- Refrigerants in refrigerated centrifuges until 13.5 years after EiF.
- Refrigerants used in maintenance and refilling of existing HVACR equipment for which no drop-in alternative exist until 13.5 years after EiF.
- Refrigerants in mobile air-conditioning (MAC) systems in combustion engine vehicles with mechanical compressors until 6.5 years after EiF.
- Refrigerants in transport refrigeration other than in marine applications until 6.5 years after EiF.
- Refrigerants in HVACR-equipment in buildings where national safety standards and building codes prohibit the use of alternatives.
Probably the most obvious areas where the new proposal may have most impact is HFC-134a in commercial (non-hermetically sealed) and small industrial refrigeration. In both sectors there are natural refrigerant options already available and much of the market is already transitioning to these refrigerants. If accepted the proposal would accelerate this transition. Other PFAS refrigerants such as HFO-1234yf and HFO-1234ze are often used as components in lower GWP blend refrigerants and HFO-1234yf is used in car air conditioning. Replacing these refrigerants with natural alternatives seems more challenging, particularly for car air conditioning where the majority of the market has already transitioned (from HFC-134a) to HFO-1234yf.
The next step in the proposal is for the ECHA’s scientific committees for Risk Assessment and for Socio-Economic Analysis to check that the proposed restriction meets the REACH legal requirements. This should occur this month. If the proposal passes this test, then a scientific evaluation of the proposal will start by the committees. Consultation will be held over approximately a 12-month period so that the ECHA can consult with industry (the period may be extended in this case due to the complexity of the issues). After that the European Commission and EU Member States will decide on potential restrictions.
Whether the proposal is accepted, or not, the initiative clearly highlights the interest from several countries to accelerate the transition to natural refrigerants. This seems to be a growing trend and will obviously concern any end users installing equipment with PFAs. Obviously more information will become available throughout 2023 which will help in making decisions on which refrigerants to select for longevity and compliance with future regulations.
If you are interested in the above issue and how it impacts refrigeration systems, then please contact Judith Evans (j.a.evans@rdandt.co.uk) at RD&T.