Significant New Alternatives Policy Explained

The Significant New Alternatives Policy (also known as Section 612 of the Clean Air Act or SNAP, promulgated at 40 CFR part 82 Subpart G) is a program of the EPA to determine acceptable chemical substitutes, and establish which are prohibited or regulated by the EPA.^[1] It also establishes a program by which new alternatives may be accepted, and promulgates timelines to the industry regarding phase-outs of substitutes.

Scope

Originally, Section 612 was limited by ozone-depleting chemicals. However, after passing regulations to phase-out R134a, an HFC refrigerant with no ozone-depleting potential, this phase-out was defended by a subsidiary of DuPont siding with the EPA as it was challenged by a major manufacturer of R134a, and was struck down in 2017. This decision was upheld in 2018.^{[2] [3]} In 2021, a new law was passed as part of the appropriations bill extending the EPA's scope to substances with high GWP as well.^[4]

The EPA looks at available chemical substitutes in the following industrial sectors:

• Adhesives, Coatings, and Inks
• Aerosols
• Cleaning Solvents
• Fire Suppression and Explosion Protection
• Foam Blowing Agents
• Refrigeration and Air Conditioning
• Sterilants
• Tobacco Expansion

Evaluations are ongoing as technological understanding improves, and can only prohibit substance where the EPA has determined other available substitutes that pose less overall risk to human health and the environment.^[5]

Submittal process

In order to submit new proposed chemicals, along with general contact and marketing information, for a complete submittal, the EPA requires reports on:

• Impurities
• Byproducts
• Degradation Products
• Test Marketing
• Physical Properties including:
  • molecular weight
  • physical state
  • melting point
  • boiling point
  • specific gravity
  • If a blend
    • bubble point
    • dew point
  • If flammable
    • lower flammability limit
    • upper flammability limit
    • flash point
• Ozone Depletion Potential (ODP)
• Global Warming Potential (GWP)
• VOC content
• Proposed cost
• Toxicity Limits
  • Permissible Exposure Limits (PELs)
  • Short-Term Exposure Limits (STELs)
  • Threshold Limit Values (TLVs)
  • Recommended Exposure Limits (RELs)
  • Workplace Environmental Exposure Limits (WEELs)
  • acceptable exposure limits (AELs)
  • Toxicological studies
• SDS
• Environmental/Health and Safety Law Review
• Industry/Application-specific Use Profile

^[6]

Refrigerants

One important, changing aspect of SNAP is its effect on the HVAC industry. Particularly because it decides which refrigerants may be legally used, it coordinates refrigerant phaseouts in the U.S., and which are prohibited against venting in concordance with Section 608. The following is a list of accepted refrigerants, or phase-out periods according to the EPA.

See also

• ASHRAE - Standards 15 and 34 are necessary part of most submittal processes to the program
• Clean Air Act - The act that established section 612
• EPA - The central regulatory agency in charge of operating the SNAP program
• Section 608 - Which helps enforce the chemicals listed as part of the program
• Title 40 of the Code of Federal Regulations

External links

• CFR section promulgating up-to-date provisions for Section 612
• EPA SNAP Website

Notes and References

1. Web site: § 82.170 Purpose and scope.. eCFR.
2. Web site: MEXICHEM FLUOR, INC., PETITIONER v. ENVIRONMENTAL PROTECTION AGENCY.
3. Web site: Mexichem Fluor, Inc. v. EPA.
4. Web site: H. R. 133. 1074.
5. Web site: Overview of SNAP. EPA. 16 June 2015 .
6. Web site: THE SIGNIFICANT NEW ALTERNATIVES POLICY (SNAP) PROGRAM INFORMATION NOTICE INSTRUCTION MANUAL. EPA. July 2020.
7. Web site: Substitutes in MVAC: Passenger Air Conditioning in Light-Duty, Medium-Duty, Heavy-Duty and Off-Road Vehicles. 13 November 2014 .
8. Web site: Substitutes in MVAC: Passenger Air Conditioning in Buses and Trains. 13 November 2014 .
9. Web site: Substitutes in Centrifugal Chillers. 5 November 2014 .
10. Web site: Substitutes in Positive Displacement Chillers. 8 September 2017 .
11. Web site: Substitutes in Industrial Process Refrigeration. 13 November 2014 .
12. Web site: Substitutes in Cold Storage Warehouse. 13 November 2014 .
13. Web site: Substitutes in Commercial Ice Machines. 13 November 2014 .
14. Web site: Substitutes in Household Refrigerators and Freezers. 13 November 2014 .
15. Web site: Substitutes in Ice Skating Rinks. 13 November 2014 .
16. Web site: Substitutes in Industrial Process Air Conditioning. 13 November 2014 .
17. Web site: Substitutes in Residential and Light Commercial Conditioning and Heat Pumps. 13 November 2014 .
18. Web site: Substitutes in Residential Dehumidifiers. 13 November 2014 .
19. Web site: Substitutes in Refrigerated Transport. 13 November 2014 .
20. Web site: Substitutes in Stand Alone Equipment. 13 November 2014 .
21. Web site: Substitutes in Refrigerated Food Processing and Dispensing Equipment. 26 May 2016 .
22. Web site: Substitutes in Remote Condensing Units. 13 November 2014 .
23. Web site: Substitutes in Typical Supermarket Systems . 27 July 2015 .
24. Web site: Substitutes in Vending Machines. 13 November 2014 .
25. Web site: Substitutes in Very Low Temperature Refrigeration. 13 November 2014 .
26. Web site: Substitutes in Water Coolers. 13 November 2014 .