EPA’s Summary of Meeting of Standard-Setting Groups for SAE
International, Interior Climate Control Committee

New and Revised Standards for HFO-1234yf , HFC-134a, and R-744

Meeting held January 18, 2010 in Las Vegas, NV

Representatives from SAE International, automotive manufacturers
(“original equipment manufacturers” or OEMs), and suppliers
discussed 16 standards under consideration.  EPA staff was also in
attendance (Yaidi Cancel and Margaret Sheppard, Stratospheric Protection
Division and Kristen Taddonio, Climate Protection Partnerships Division)

For abbreviation purposes, HFO-1234yf appears as R-1234yf and HCF-134a
appears as R-134a.

Standards = stds

Agenda: 

9:30am: R-1234yf service fittings and stds

10:00am: Review of topics discussed on the November 20th meeting with
EPA

11:00am: Break out of work teams

2:00pm: Group work team allots resolution for the stds

4:00pm: Future SEA meetings

4:15pm: Lubricant std

The committee is broken up into the following teams: OEMs, Motor A/C
(MAC) suppliers, fluids, and servicing. 

Standards issues discussion

A brief introduction about the proposed standards for HFO-1234yf and the
expected time in the ballot was discussed. At the end of the meeting the
expected publication dates for the standards were changed. These dates
were presented in the CRP1234 meeting of January 20th. For more
information the presentation is available as a pdf document in the
docket. 

SAE J 639 fitting issues (proposed changes/updates for this standard):

SAE J 639 “provides design standards and safety requirements for MAC
systems. Also included are cautionary statements for the mobile air
conditioning service industry to alert service technicians to the
inadvisability and the possible health and safety effects associated
with venting refrigerant during service.”  (Atkinson, 2010)

The stakeholders commented that fitting measurements should be
consistent according to the refrigerant used in the motor vehicle air
conditioning (MVAC) system. Fittings for R-1234yf should be different
from fittings for R-134a. Also, the attention was brought to update the
coupling leading configuration to provide an adequate area to seal, and
therefore, prevent leakages. Focus was brought to revise the cap seal
and a reduction of the diameter of ball lock feature was proposed. 

SAE J 2844 - Refrigerant Purity and Container Requirements for New
HFO-1234yf Refrigerant Used in Mobile Air-Conditioning Systems 

The attendees commented about the cylinder connections for R-1234yf, and
pointed that such connections should be verified by the Compress Gas
Association (CGA) to meet their requirements. There is a requested
proposal to develop a standard including three new cylinder connections
for R-152a, R-1234yf and R-744. However, priorities for this proposal
might be low at the moment due to consistency issues with J 639. 

The attendees mentioned that changes may be done on the check valve
assembly due to the flammability of R-1234yf. 

Also, discussion regarding the label for R-1234yf container was brought.
The label is likely to contain a white background with a red border. 

The OEMs brought to attention an issue regarding most of the listed
SNAP-MVAC alternative refrigerants due to the lack of certified service
equipment that could lead into cross contamination of the MVAC systems. 

CRP 1234 meeting summary (from November 20, 2009)

During this session the presenter showed a summary of the topics
discussed during the OEMs meeting with EPA on November 20, 2009.
(Further details from this meeting can be viewed in the docket).

OEMs discussed the exposure limits of HF (AEGL-2 limit (94ppm, 10 min))
and compared with the actual results of HF production during the risk
assessments. 

Comments from OEMs:

The OEMs commented that there should be a restriction of refrigerant use
for professionals only (therefore no DIY-ers). Also they commented that
the proposed use conditions or proposed mitigations to limit the
concentration such as applying blowers, could create problems with toxic
fumes being brought into the passenger compartment, increasing safety
issues concerns.   

The OEMs mentioned that HF generation is to be a low level of risk and
added that risks with R-1234yf are 20 times lower than R-152a. They
recognized that EPA accepted R-152a to be used as a secondary loop, but
such engineering strategy is not necessary with R-1234yf and will not
work due to efficiency issues. 

The OEMs expressed that MVACs using R-1234yf should be acceptable
without the specific use conditions mentioned in the proposed rule. The
proposed rule should focus on standards such as J639 and risk
assessments and studies made by the industry. “Raise those standards
(referring to SAE stds) in the rulemaking”. 

Attention was brought again to the Ignition/explosion LFL test showing
the ping-pong balls (showed during the November 20, 2009 meeting) as an
approach to show that ignition during normal conditions is almost
impossible with R-1234yf, since the ignition was assisted using a butane
lighter. This showed that a high energy source is needed to ignite the
refrigerant; however the flame propagation is minimal.

OEMs agreed (as discussed on the November 20 meeting) with the following
use conditions from the proposed rule:

Unique fittings, labeling, high pressure compressor cutoff switch, and
failure mode and affect analysis (FMEA) on MVACs as stated in SAE J 1739
standard. 

Attendees Question and Answer session:

Some OEMs asked if the A/C lubricant has an effect on the refrigerant in
the MVAC system.  Others responded that, yes, the lubricant has an
effect on flammability. Tests were conducted with lubricants as well (in
risk analysis).

OEM work group std review teams:

Attendees broke into several groups to discuss topics to be addressed
into the SAE stds and agree for a completion date for each std. 

MAC group review team & stds to review

J2064 – R-134a & R-1234yf refrigerant auto a/c hose and assemblies

J2842 - HFO-1234yf and R744 Design Criteria and Certification for OEM
Mobile Air Conditioning Evaporator and Service Replacements 

J2911 - Certification Requirements For Mobile Air Conditioning System
Components, Service Equipment, and Service Technicians to Meet SAE J
Standards 

Service work group review team

J2843 - HFO-1234yf Recovery/Recycling/Recharging Equipment for Flammable
Refrigerants for Mobile Air-Conditioning Systems 

J2845 - Technician Training for Safe Service and Containment of
Refrigerants Used in Mobile A/C Systems (R-744, and HFO-1234yf) 

J2851 - HFO-1234yf Refrigerant Recovery Equipment for Mobile Automotive
Air-Conditioning Systems 

J2913 - HFO-1234yf Refrigerant Electronic Leak Detectors, Minimum
Performance Criteria 

J2888 - HFO-1234yf Service Hose, Fittings and Couplers for Mobile
Refrigerant Systems Service Equipment 

J2912 - HFO-1234yf Refrigerant Identification Equipment for Use with
Mobile Air Conditioning Systems 

J2927 - HFO-1234yf Refrigerant Identifier Installed In Recovery and
Recycling Equipment For Use With Mobile A/C Systems 

J2911 – Procedure For Certification That Requirements For Mobile Air
Conditioning System Components, Service Equipment and Service
Technicians Meet SAE J Standards

Fluids work review team

J2099 - Standard of Purity for Recycled HFC-134a (R-134a) and HFO-1234yf
(R-1234yf) or Use in Mobile Air-conditioning Systems 

J2670 - Stability and Compatibility Criteria for Additives and Flushing
Materials Intended for Use in R-134a and HFO-1234yf Vehicle
Air-Conditioning System 

J2844 - HFO-1234yf New Refrigerant Purity and Container Requirements
Used in Mobile Air-Conditioning Systems 

OEM 

J2772 - Measurement of Passenger Compartment Refrigerant Concentrations
under system refrigerant leakage conditions 

J2773 - HFO-1234yf and R744 Refrigerant Standard for Safety and Risk
Analysis for use in Mobile Air Conditioning Systems 

J2842 - HFO-1234yf and R744 Design Criteria and Certification for OEM
Mobile Air Conditioning Evaporator and Service Replacements 

Other topics:

HFO-1234yf name discussion:

Attendees agreed that the refrigerant HFO-1234yf could be called for
technical purposes as R-1234yf. 

Fluids group:

Issues: refrigerant purity, relationship to AHRI/ASHRAE standards,
fittings, lubricants, impurity levels after recovery of refrigerant.

Some attendees asked if vehicles using R-134a should be retrofitred to
for R-1234yf.  The group consensus was “no.” 

Refrigerant service group 

Issues:  leak detectors, recovery/recycling/recharging equipment, who
may test to meet SAE standards, fittings, hoses, evaporators, technician
training

Also concerns about dyes, refrigerant purity, aftermarket additives and
flushing agents.

Outstanding issues on the proposed SAE J standards

J2911 - Certification Requirements for Mobile Air Conditioning System
Components, Service Equipment, and Service Technicians to Meet SAE J
Standards 

An issue was brought into discussion addressing the concern of having
equipment being labeled as SAE certified from labs with unknown
credentials. One of the attendees brought into discussion the lack of
enforcement to control testing facilities and find out if such
facilities are following the standard testing procedures. 

The suggested SAE J2911 standard states: “Certification is required
prior production of equipment for market sale, and application of the
label that recognizes SAE as the certifying entity. Additional
certification might be required if within one year after the product
goes to market using a component purchased on the open market” 

J2912 - HFO-1234yf Refrigerant Identification Equipment for Use with
Mobile Air Conditioning Systems 

Concern was brought into discussion regarding cross contamination in the
MVAC system and the service equipment. Attendees commented on the
importance to test the equipment prior having it available in the
market. 

Future SAE congress meetings

ICCC April 13 (9-5 in COBO)

Climate control tech session (April 15)

ISO/CRP/LCCP… TBA

suites) – (focus on system efficiency)

New lubricant std – proposed by VDA

The proposed standard focuses on lubricant oils for refrigerant
compressors, and requirements for its use with R-1234yf. The current oil
alternatives include PAG, POE & PVE. The presenter stated that R-1234yf
lubricants might have a larger demand compared with R134a for
lubricants. 

Several issues were addressed to consider including different compressor
types since all need oil and have to meet industry and std
specifications, differences in viscosity, and stability when mixing with
the refrigerants and metal parts. There were no suggestions to change
the already available oils in the market. However, there may be changes
in compressor design.

VDA said that they considered risks and performed conductivity measures
of the oil. On of the attendees asked to pursue std, test methods used,
and how much lubricant takes the a/c system. VDA said that the details
regarding the oil and the studies and the proposal for were already sent
for a review to the committee members. 

Question & Answer session with EPA:

Question - Does EPA want to consider comments after the close of the
comment period?

Answer: Yes, we can consider comments once the public comment period is
closed.  (After that point, we are not legally obligated to consider).  

Question:  What’s the timing now?  Does the timing on the standards
matter?

Answer:  It will probably take EPA around 6-12 months to prepare a final
rule.  Standards must be final before there is a final rule.  Ideally,
standards would be final now so that we can take comment on the actual
standard.

Question:  Hypothetically—could EPA say that you’ve already taken
comment, many have offered comments in support, so you could finalize?

Answer:  We would need to check with legal counsel on that.  Based on
experience with other rules, ideally, we would like to give public the
chance to actually see a document.

