As we enter the busy winter season and begin to shift focus to the flurry of activity around customers’ heating systems, we must not lose sight of the HVAC refrigerant regulations going into effect this year. As we conclude Phase I of the Environmental Protection Agency’s (EPA’s) mandated phasedown of HFC refrigerants, during which we experienced a 10% reduction in their production and usage over the past two years, we must now prepare for Phase II, which began on January 1, 2024, and brought an additional reduction of 30%. If you’re doing the math, yes, that will take us to a 60% production and use level based on the EPA’s historic baseline for HFC use.

Now, if you have been around a few years like I have, you may be thinking back to the days of the phaseout of CFC and HCFC refrigerants, which drove the cost of those refrigerants sky-high, as the industry gradually transitioned to new equipment that utilized the HFC refrigerants. We are seeing some similarities to the earlier phaseout of CFC/HCFC refrigerants, but there are also some significant differences with this phasedown of HFC refrigerants. The biggest difference is that CFC and HCFC refrigerants were replaced by HFC refrigerants, all of which are in the same class of A1 refrigerants and are all nonflammable. In the present case, the replacements for the HFC refrigerants fall into a different class of refrigerants, primarily A2L refrigerants, which are mildly flammable.

Need to Know

A2L refrigerants are the latest refrigerants recognized by the EPA’s Significant New Alternatives Policy (SNAP) as substitutes for the high-GWP HFC refrigerants currently used in residential and light commercial air conditioning and heat pump systems. In 2024, these widely available and more environmentally friendly refrigerants will soon become more commonly used in the HVAC industry. So, what does this all mean for HVAC contractors? What do contractors need to know?

The transition to refrigerants that fall into the A2L class impacts several aspects of the HVAC contractor’s business. These include, but are not limited to, areas such as:

• Design and permitting for HVAC systems;
• Installation of HVAC equipment and piping;
• Storage and handling of new refrigerants; and
• Servicing of HVAC equipment utilizing A2Ls.

With regards to HVAC design and permitting, an important consideration is that the 2021 and earlier versions of the International Code Council’s International Codes (I-Codes) — including the International Building Code, International Mechanical Code, and International Fire Code — do not allow the use of A2L refrigerants for residential and light commercial comfort conditioning purposes. A2Ls are permitted for this purpose in the latest 2024 edition of the I-Codes, but these codes have yet to be adopted across the country. Efforts have been ongoing for jurisdictions across the U.S. to adopt or amend local codes to include 2024 I-Code language covering A2Ls. Cities and states are each handling this issue in different ways, so it is important that HVAC contractors reach out to local building officials in the areas where they do business, to understand the local code requirements that will be enforced related to systems that use A2L refrigerants.

The A2L-related code requirements will impact the installation of these systems and their piping systems. Additional installation steps included in the code provisions include:

• Addition of a risk of fire warning labels for A2L piping due to its flammability;
• Additional requirements for building shafts containing A2L piping, including a continuous ventilation requirement and a requirement for leak detection within the shaft;
• Requirements for refrigerant detectors that signal an alarm and activate the room’s ventilation system in machinery rooms containing A2L refrigerants, complying with ASHRAE 15; and
• Limits to the amount of A2L refrigerant that can be used for air conditioning systems used for human comfort.

In addition to impacting the installation of HVAC systems, the new code provisions regulate the storage and handling of the A2L refrigerants. Due to their flammability, A2Ls come with significant storage implications, which were not a consideration for previous refrigerants. Contractors should be prepared for changes to storage practices, including requirements for appropriate space and labeling measures, especially in spaces where these refrigerants are being stored in large quantities. This includes guidelines for storage rooms that may house equipment with high surface and/or operating temperatures.

Lastly, contractors who install and/or service HVAC systems using A2L refrigerants will need to verify that the tools and equipment they use are compatible with A2L refrigerants. This does not impact the standard hand tools and wrenches used, but contractors will need to verify that their vacuum pumps, leak detectors, and refrigerant recovery equipment are compatible with A2L refrigerants. They will also need to review and understand any new requirements and procedures related to the handling and use of A2Ls.

As you can see, the transition from HFC to A2L refrigerants will have a huge impact on a contractor’s business. There are several additional installation steps contractors will need to address, but none of them are overly complicated or impossible to overcome. The key to a smooth transition is preparation and communication. Most importantly, this includes reaching out to your local building officials to understand any new code requirements they will be enforcing related to A2Ls. The winter months are a great time to reach out and rekindle, or establish, your relationships with local officials.

For more information on A2L refrigerants, please check out the International Code Council’s “Preparing for A2L Refrigerants” page at www.iccsafe.org/products-and-services/i-codes/a2l-refrigerants-transition.