AEM member group achieves major milestone in EPA Snap approval process

An AEM taskforce comprised of member companies recently received letters of completion for four of the five risk analysis reports submitted to the U.S. EPA related to the proposed use of R-1234yf refrigerant in off-road mobile machinery.

The reports – completed in accordance with EPA specifications under its Significant New Alternatives Policy (SNAP) – propose the use of R-1234yf as a substitute for R-134a in the following five machine categories:

• Self-propelled agricultural machinery –combine, sprayer, forage harvester, windrower, floater
• Compact equipment – tractors under 40 HP and utility vehicles, compact construction equipment
• Construction, forestry, and mining equipment – excavators, dozers, wheel loaders, loader backhoes, feller benchers, log skidders and road graders, articulated trucks, excavators, loaders, sub-surface machines
• Agricultural Tractors 40 HP and above – Two Wheel Drive, MFD, Four-wheel Drive and Track Tractors
• Utility Vehicles – Commercial Use Utility Vehicles

With the letters of completeness, AEM member company equipment with R-1234yf can be placed on the market in North America for all of the applications listed above in late September.

AEM Director of Materials Management John Wagner, said:

“The work done by AEM and its members have provided the industry with an alternative that has a significant and positive impact on the environment. The process by which we conducted our efforts may also serve as a guide for how AEM can pull together the right people – with the right interests, backgrounds, and expertise – to be able to address challenging industry issues that involve interactions with EPA and other governmental organizations.”

AEM’s SNAP Application Development team was formed in the summer of 2018, and the group met with EPA in mid-2019 to learn the critical items that need to be included in the risk assessment reports AEM would eventually go on to submit.

Throughout the multi-year-long process, the association has gained new members, Chemours, Bergstrom Engineering, and Honeywell, due to its work on behalf of the equipment manufacturing industry to propose the use of R-1234yf refrigerant in off-road mobile machinery. Other member company participants included: CNH Industrial, AGCO, Caterpillar, Doosan Bobcat, Red Dot, Claas, John Deere, Wacker Neuson, JLG,  Yanmar, JCB, MacDon, Volvo Construction Equipment, and Kubota.

“Also, every participating company trusted AEM with confidential business information which the association consolidated to define our industry risk for our risk analyses. We met about every other week for two-and-a-half years, talking about the risk and examining every possibility to come to the best possible risk analysis.”

said Wagner.

EPA’s snap program

SNAP 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 to other substitutes available for particular end-use.

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 to other substitutes available for 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

Recognition

In addition, AEM has been recognized for its efforts to propose the use of R-1234yf refrigerant in off-road mobile machinery. The association was nominated by the Institute for Governance & Sustainable Development (IGSD) for a SAE E2T Award for Sustainable AC in Off-Road Equipment. IGSD works to promote just and sustainable societies and to protect the environment by advancing the understanding, development, and implementation of effective, and accountable systems of governance for sustainable development. The Mobile Air Conditioning Society (MACS) also sent a letter of support to AEM in recognition of the association’s work on R-1234yf.

Source: AEM