HCPA Expresses Concerns about the Regulation of HFCs
July 17, 2018
On behalf of the Aerosol Products Division, HCPA’s Senior Vice President of Scientific Affairs, Dr. Steve Bennett, sent the Director of EPA’s Office of Atmospheric Programs (OAP) Stratospheric Protection Division, Cynthia Newberg, a letter expressing HCPA’s concerns with the recent events around the regulations of hydrofluorocarbons (HFCs). Of specific concern was the regulation of 1,1,1,2-Tetrafluoroethane (HFC-134a) by the EPA’s Significant New Alternatives Policy (SNAP) Program and how the lack of regulatory certainty may impact products formulated with HFC-134a.
Because of the SNAP Rules regulating the use of HFC-134a, the U.S. aerosol industry has moved away from its use, except for the critical uses that were exempted from the rules. With the regulatory uncertainty in the current environment, companies are unsure of how to proceed, not wanting to invest the time and resources to switch back; however, there is concern that the market may be undercut by foreign manufacturers who have not yet been required to make the investment to move away from its use. HCPA respectfully urged EPA to quickly resolve the uncertainty and diligently move forward on reinstating the restrictions on the use of HFC-134a in a transparent manner for all stakeholders.
On behalf of the Aerosol Products Division, HCPA’s Senior Vice President of Scientific Affairs, Dr. Steve Bennett, sent the Director of EPA’s Office of Atmospheric Programs (OAP) Stratospheric Protection Division, Cynthia Newberg, a letter expressing HCPA’s concerns with the recent events around the regulations of hydrofluorocarbons (HFCs). Of specific concern was the regulation of 1,1,1,2-Tetrafluoroethane (HFC-134a) by the EPA’s Significant New Alternatives Policy (SNAP) Program and how the lack of regulatory certainty may impact products formulated with HFC-134a.
Because of the SNAP Rules regulating the use of HFC-134a, the U.S. aerosol industry has moved away from its use, except for the critical uses that were exempted from the rules. With the regulatory uncertainty in the current environment, companies are unsure of how to proceed, not wanting to invest the time and resources to switch back; however, there is concern that the market may be undercut by foreign manufacturers who have not yet been required to make the investment to move away from its use. HCPA respectfully urged EPA to quickly resolve the uncertainty and diligently move forward on reinstating the restrictions on the use of HFC-134a in a transparent manner for all stakeholders.