In its submission to the ongoing approval process for HFO-1234yf, the Automotive Recyclers Association has urged the U.S. Environmental Protection Agency to do further in-depth research regarding the recyclability, storage, cost and overall feasibility of HFO. Automotive recyclers are especially worried about the safety for automotive recycling staff and the general public. Meanwhile, the EPA has extended the public comment period for the second time, as new information on the substance has emerged.
The Automotive Recyclers Association (ARA), the international trade association dedicated to the efficient removal and reuse of automotive parts, and the safe disposal of inoperable motor vehicles, has submitted comments to the U.S. Environmental Protection Agency’s (EPA) regarding the proposed rule to approve the use of HFO-1234yf in Motor Vehicle Air Conditioning (MVAC).
In-depth research needed on issues that the proposed rule does not address
Concerned with occupational dangers and potential costs incurred by recycling facilities (ARA represents over 4,500 auto recycling facilities in the US and 14 other countries) and their employees as well as environmental impacts of HFO, the association underlines the following issues of concern that the proposed rule fails to address:
- Storage
- Disposal
- Occupational hazard
- Internal cost associated with specialized equipment
- Impact on air quality
- Storm water run-off requirements
Hence there is a “need for further information and in-depth research for handling this new fluid during the dismantling process of an end-of-life vehicle, to identify any associated occupational dangers or potential costs that could be incurred by automotive recycling facilities and their employees, or any environmental impact it may have to the public regarding air quality or storm water run-off, which are two key issues of concern for the professional automotive recycler.
EPA extends comment period on HFO SNAP as new information emerges
The EPA decided to extend for the second time the comment period regarding the approval of HFO in new MVAC systems under the Significant New Alternatives Policy (SNAP) Program through to 15 February 2010. This will allow stakeholders to consider some new information issued in the meantime by the agency, namely a significant new use rule for HFO1234yf, requiring manufacturers and importers of the substance to notify EPA of any uses that differ from those outlined in premanufacture (PMN) notices already filed with the agency.
Overall, the document finds that there are no risks from the manufacturing, processing, or use of HFO if it handled under the conditions filed with the agency (no significant industrial or commercial worker exposure, no ‘‘do-it-yourself’’ consumer exposures, use of HFO only in new MVACs). However, “based on test data on the PMN substance, EPA identified health concerns for developmental toxicity and lethality to workers and consumers if they were exposed to a significant amount of the PMN substance via inhalation”.
Moreover, the document has recommended additional testing: “EPA has determined that the results of an acute inhalation toxicity study (OPPTS Harmonized Test Guideline 870.1300 or OECD 403 test guideline) with rabbits would help characterize the human health effects of the PMN substance”.
