Part 2: Impact on Processes
An evolving regulatory landscape, coupled with new standards from the U.S. Department of Energy (DOE) and Environmental Protection Agency (EPA) are transforming the way commercial refrigeration manufacturers develop and market products. These regulatory changes bring a greater emphasis to energy efficiency and environmentally-friendly refrigerant alternatives in commercial refrigeration products.
The DOE standards will bring significant changes to commercial refrigeration equipment, and the EPA's Significant New Alternatives Policy (SNAP) will establish a list of acceptable substitutes for ozone depleting substances. To prepare for these changes, manufacturers should educate themselves on the new requirements and how they apply to their products, processes and installed product maintenance considerations.
In Part 1 of our blog series we covered key questions for manufacturers regarding the impact of these new regulations on products. Topics include what type of products are impacted, whether or not product redesign is necessary and the criteria for measurement including traditional performance testing and the Alternative Energy Determination Method (AEDM).
The largest procedural changes and potential for redesigned processes come as a result of the EPA's SNAP program. In an effort to reduce the environmental impact and ozone depleting potential of commercial refrigeration products, SNAP will establish a list of acceptable alternatives to the refrigerants traditionally used in commercial refrigeration.
Considerations to be made in terms of alternative refrigerants are two-fold; the first being that existing components in refrigeration products may not be compatible with some alternative refrigerants; the second is that certain acceptable alternatives, such as isobutene or propane, are flammable.
If a manufacturer were to decide to employ a flammable refrigerant into their processes as a result of the SNAP program, their facility and its processes would then need to undergo a hazardous locations evaluation.
A hazardous location evaluation includes a review of a host of conditions such as operational procedures, electrical power, emergency stops, upper and lower explosive limits, area and exit lighting, personal protective equipment (PPE) and hazardous materials certification, among others. This is something for manufacturers to bear in mind when considering incorporating flammable refrigerants into their products and processes.
The use of alternative refrigerants may also require manufacturers to work with suppliers to source new materials and components. This could involve evaluating the properties of new materials, pursuing new safety certifications, re-evaluating pressure limits, and conducting an overall assessment of the supplier's manufacturing process to ensure they have the capability to produce to the new standards by the compliance dates.
In our next article we will discuss how changes to refrigerants can impact the maintenance of your installed products.
With those compliance dates established for these standards, manufacturers should begin planning now for their products to be designed, manufactured, tested, compliant and still competitive under these new regulations. Processes should also be evaluated to ensure a consistent level of quality and safety.
Contact Intertek for an initial consultation to address any questions about the recent and upcoming standards; we can put you on the right track for robust product development and global compliance.
For further information on these new standards and Intertek's services, visit our Commercial Refrigeration web page, download the white paper Commercial Refrigeration: Manufacturer's Guide to the Changing U.S. Regulatory Landscape, and stay tuned for more about how Intertek can help you comply with regulatory changes.
Mark Keller is the Global Business Line lead for Appliances & Electronics at Intertek. He is responsible for coordinating global business development activities for his team of 11 professionals spread across three regions. He is based in the Cortland, New York facility.