AEM’S SNAP Application Team’s New Proposal

SOURCE: AEM | June 24, 2019

Representatives from AEM’s SNAP Application Development Team met early last month with the U.S. EPA to discuss the use of R-1234yf refrigerant in off-road mobile machinery.

The group informed EPA officials that efforts were under way to submit the first of six planned risk analysis reports, and the parties in attendance also took the opportunity to determine next steps. 

“Overall, the meeting went well,” said AEM Director of Materials Management John Wagner. “We were able to learn the critical items that need to be included in the risk assessment report we will submit, and EPA was pleasantly surprised at our progress in terms of submitting the first risk analysis report.”

SNAP, which stands for Significant New Alternatives Policy, was established under Section 612 of the Clean Air Act to identify and evaluate substitutes for ozone-depleting substances. The program, which is overseen by EPA, looks at overall risks to human health and the environment of existing and new substitutes, publishes lists and promotes the use of acceptable substances, as well as provides the public with key, up-to-date information.

The program also reviews substitutes within a comparative risk framework in a number of industrial sectors. One of those sectors is refrigeration and air conditioning.

EPA’s decision on the acceptability of new substitutes proposed by manufacturers, formulators, or users is based primarily on the potential human health and environmental risks posed by the substitutes as compared other substitutes available for a particular end use. EPA’s evaluation of each substitute in an end use is based on the following types of information and analyses:

  • Atmospheric effects
  • Exposure assessments
  • Releases in the workplace and in homes
  • Releases to ambient air and surface water
  • Releases from the management of solid wastes
  • Toxicity data
  • Flammability
  • Other environmental impacts

Eleven AEM member company representatives were in attendance at last month’s meeting between the SNAP Application Development Team and EPA to discuss R-1234yf. 

Representing EPA were Bella Maranion, branch chief; Margaret Shephard, SNAP team manager; Chenise Farqueson, SNAP coordinator, Dave Godwin, refrigerant; Gerald Wozniak, SNAP case manager; Christine Motilall, SNAP case manager.

AEM’s SNAP Application Development Team received a wealth of valuable feedback and direction related to the risk assessment report it’s tasked with completing. Specifically, per EPA, the report needs to:

  • Include R-134a as baseline
  • State there is no present need for new SAE standards to be developed
  • Note what exact recovery equipment is available and what standards equipment is certified to, even if they are international
  • Note additional risk assessments will cover different machine forms
  • Note that operators must be highly trained personnel to be able to use tractors

The SNAP Application Development Team has a number of next steps it must take as a result of last month’s meeting. Tractors over 40 hp is the first machine form being addressed, with five other reports covering five additional machine forms coming.

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