From: firstname.lastname@example.org (George Goble)
Subject: DIY refrigerants/FAQs for automotive A/C
Date: 6 Jun 1995 13:51:51 GMT
Organization: Purdue University
There has been quite a bit of ruckus in this group in the
last week or so about DIY refrigerants, and DIYers doing
their own A/C service, using any refrigerant, or blend
they please, venting, etc.. (the "for consideration" loophole).
Reportedly, someone called the ozone hotline (1-800-296-1996)
and was told it was "OK" to do all of this. (under section 609
of the clean air act)
Talking to EPA people and reading section 612 of the clean air
act..prohibits most of this.. section 612 makes it unlawful
to use substitutes which are not on the list of "EPA acceptable"
for the use intended.. Certain "exemptions" are allowed, like
if a substance has been filed for EPA SNAP approval, has waited 90
days after filing, it can be sold.. The EPA will then act on it,
either listing it as "acceptable" or "unacceptable". Once listed
unacceptable, the further sale must stop.
A DIYer can get mobile cert (probably from MACS), can only use
SNAP acceptable (or in approval process) (for automotive) refrigerants,
which currently are
MP-52 (R-401c, R124/R152a/R22 blend), Dupont, not marketed in the US.
FRIGC (R124/R134a/butane blend), Intermagnetics General
some hydrocarbon blends (HC-12a?), in "in process" and legal
at the moment, but rumored to be soon to be "unacceptable"
(if I got this list wrong, I am sure Jeff Levy will correct me)
A number of other refrigerants, such as R-406A, FX-56, etc have
been found to be EPA acceptable and approved for sectors other than
automotive (stationary and transport refrigeration). Using these
refrigerants (in a car in the US) is illegal (they may be legal
in some countries outside the US). This can get you a $25,000
fine and an upto $10,000 reward to the guy who turns you in..,
this applies to DIY'ers also! The often posted (and used with
good results by many on the net) of 79% propane and 21% isobutane,
which I posted to the net in 1990 IS NOT LEGAL in the US anymore..
This was one of the refrigerants I made up before inventing R-406A.
----- section 612, clean air act. look at paragraph (c)
SEC. 612. SAFE ALTERNATIVES POLICY.
(a) Policy._To the maximum extent practicable, class I
and class II substances shall be replaced by chemicals, product
substitutes, or alternative manufacturing processes that reduce
overall risks to human health and the environment.
(b) Reviews and Reports._The Administrator shall_
(1) in consultation and coordination with interested
members of the public and the heads of relevant Federal agencies
and departments, recommend Federal research programs and other
activities to assist in identifying alternatives to the use of
class I and class II substances as refrigerants, solvents, fire
retardants, foam blowing agents, and other commercial
applications and in achieving a transition to such alternatives,
and, where appropriate, seek to maximize the use of Federal
research facilities and resources to assist users of class I and
class II substances in identifying and developing alternatives to
the use of such substances as refrigerants, solvents, fire
retardants, foam blowing agents, and other commercial
(2) examine in consultation and coordination with the
Secretary of Defense and the heads of other relevant Federal
agencies and departments, including the General Services
Administration, Federal procurement practices with respect to
class I and class II substances and recommend measures to promote
the transition by the Federal Government, as expeditiously as
possible, to the use of safe substitutes;
(3) specify initiatives, including appropriate
intergovernmental, international, and commercial information and
technology transfers, to promote the development and use of safe
substitutes for class I and class II substances, including
alternative chemicals, product substitutes, and alternative
manufacturing processes; and
(4) maintain a public clearinghouse of alternative
chemicals, product substitutes, and alternative manufacturing
processes that are available for products and manufacturing
processes which use class I and class II substances.
(c) Alternatives for Class I or II Substances._Within 2
years after enactment of the Clean Air Act Amendments of 1990,
the Administrator shall promulgate rules under this section
providing that it shall be unlawful to replace any class I or
class II substance with any substitute substance which the
Administrator determines may present adverse effects to human
health or the environment, where the Administrator has identified
an alternative to such replacement that_
(1) reduces the overall risk to human health and the
(2) is currently or potentially available.
The Administrator shall publish a list of (A) the substitutes
prohibited under this subsection for specific uses and (B) the
safe alternatives identified under this subsection for specific
(d) Right To Petition._Any person may petition the
Administrator to add a substance to the lists under subsection
(c) or to remove a substance from either of such lists. The
Administrator shall grant or deny the petition within 90 days
after receipt of any such petition. If the Administrator denies
the petition, the Administrator shall publish an explanation of
why the petition was denied. If the Administrator grants such
petition the Administrator shall publish such revised list within
6 months thereafter. Any petition under this subsection shall
include a showing by the petitioner that there are data on the
substance adequate to support the petition. If the Administrator
determines that information on the substance is not sufficient to
make a determination under this subsection, the Administrator
shall use any authority available to the Administrator, under any
law administered by the Administrator, to acquire such
(e) Studies and Notification._The Administrator shall
require any person who produces a chemical substitute for a class
I substance to provide the Administrator with such person's
unpublished health and safety studies on such substitute and
require producers to notify the Administrator not less than 90
days before new or existing chemicals are introduced into
interstate commerce for significant new uses as substitutes for a
class I substance. This subsection shall be subject to section
From: email@example.com (George Goble)
Subject: EPA Q & As on DIYers Fixed and Mobile A/C service (venting)
Date: 16 Jul 1995 15:48:34 GMT
Organization: Purdue University
[Email exchange between Geo. Goble and Christine Dibble @ USEPA
regarding questions on DIYers (Do-it-Yourselfers), on venting
and other rules for Clean Air Act (CAA) part 608 (mostly stationary
refrigeration A/C) and part 609 Mobile MVAC A/C (cars, busses, tractors,
etc) EPA's replies are in UPPER CASE.. Also attached is an EPA
supplied Q & A factsheet (not in upper case) on DIYers, venting, etc..
Hopefully this should clear up many misconceptions.. --ghg]
From DIBBLE.CHRISTINE@EPAMAIL.EPA.GOV Sat Jul 15 09:59:30 1995
From: CHRISTINE DIBBLE <DIBBLE.CHRISTINE@EPAMAIL.EPA.GOV>
To: firstname.lastname@example.org, LEVY.JEFFREY@EPAMAIL.EPA.GOV
Subject: CAA section 609 & DIYers.. -Reply
SEE ANSWERS IN ALL CAPS WITHIN THE TEXT. ALSO SEE THE ATTACHMENT, A Q&A
FACTSHEET WHICH I JUST PREPARED FOR FARMERS AND OTHER DIY-ERS. THIS
FACTSHEET WAS SENT FOR DISTRIBUTION AND REPUBLICATION TO AUTO. PARTS
AND ACCESSORIES ASSN. AND TO MANY FARM TRADE ASSNS. SUCH AS NORTH
AMERICAN EQUIPMENT DEALERS AND FARM EQUIPMENT RETAILERS ASSN. ISN'T
THERE A COMEDIAN NAMED GEORGE GOBLE?
>>> George Goble <email@example.com> 07/14/95 10:24am >>>
I get hounded a lot (on the net & email) from DIYers wanting to work on
cars (with R12)...
CAA section 609 "for consideration" which lets DIYers get away with not
having to have certified recovery equipment, etc...and reading recent
FAQs (made by others whom have talked to you
and the ozone hotline)..and my reading of section
609 + Fedr Reg. updates, etc.. It is still not
completely clear on 609 DIYers and the "venting" situation..
Section 608 is very clear on not venting Class I or II and cert
needed to do everything.. (service, repair, disposal, etc)
on 609.. some say DIY venting is OK?? and others say something to
the effect, that no "certified" recovery equipment is needed, but it
is not legal for DIYers to vent classI or II and they must come up
with some means to achieve 4" vac in a system and capture
the charge...(for class I and II)
Wondered if you could clarify this when you have time (no hurry)?
NO VENTING ALLOWED BY
ANYONE AT ANYTIME! DIY-ERS DO NOT NEED TO USE CERTIFIED EQUIPMENT
HOWEVER. DIY-ERS CAN USE ANY PIECE OF HOMEMADE EQUIPMENT, JUST SO LONG
AS THEY DON'T VENT. THE EQUIPMENT DOES NOT HAVE TO ACHIEVE A 4-INCH
VACUUM. WHO HAS TO USE EQUIPMENT THAT ACHIEVES A 4-INCH (102 MM) VACUUM?
1. TECHNICIANS WHO PURCHASED 608 EQUIPMENT PRIOR TO 11/15/93, AND
2. ANYONE WHO RECOVERS REFRIGERANT FROM AN MVAC OR MVAC-LIKE APPLIANCE
(SUCH AS HEAVY CONSTRUCTION EQUIPMENT, FARM EQUIPMENT ETC.) THAT IS
DESTINED FOR DISPOSAL.
Also after Nov 15, 1995 it becomes illegal to vent "substitutes"
for class I & II (mostly HFCs) unless the EPA determines that each
substance poses no threat and can be vented...
So this means R-134a must be recovered at that point. This is clear.
If one runs into system charged with propane (R22 replacement)or
OZ-12, total hydrocarbon refrigerants 0.0 ODP, can these be vented
after Nov 15?
NO, UNDER 609, NO SUBSTITUTES FOR R-12 IN AN MVAC CAN BE VENTED, SO OZ-12
CANNOT BE VENTED. UNDER 608, NO SUBSTITUTES FOR ANY CLASS I OR II
SUBSTANCE CAN BE VENTED.
Have a good day :)
FARMER.FCT file (wordperfect) converted to plain txt
From Christine Dibble @ the USEPA.
United States Office of Air and Radiation July 1995
Environmental Protection Stratospheric Protection Division
Qs & As FOR FARMERS AND DO-IT-YOURSELF-ERS ON MOTOR VEHICLE
AIRCONDITIONING AND THE CFC-12 PRODUCTION BAN
OZONE PROTECTION HOTLINE TOLL-FREE (800) 296-1996
10 A.M.--4 P.M., MON.-FRI. EST
Q:Is it true that I have to become a certified technician and purchase
approved recycling equipment in order to work on my own motor vehicle's air
A: No. Under Section 609 of the Clean Air Act, only people who repair or
service air conditioning systems for consideration -- that is, for payment,
whether it is monetary or some other form -- are required to be properly
certified and to use equipment approved by the Environmental Protection
Agency. That means that a do-it-yourselfer (DIYer) can work on his own car
without being certified or having to buy recovery or recycling equipment.
Like service technicians, DIYers are not permitted to vent freon (R-12
refrigerant) from an a/c system. Beginning on November 15, 1995, it will also
be illegal for anyone to vent R-134a, or any other R-12 substitute.
In addition, only certified technicians may purchase R-12. The EPA has not
yet decided whether sales of R-134a will be restricted to certified
technicians only. This decision should be made by November, 1995.
Q: How do I comply with the law and service a/c systems on a tractor, or a
car that is up on blocks, or any other vehicle that is difficult to move to a
A: Topping Off. A farmer or other DIYer must become a certified technician in
order to purchase freon to "top off" his own tractor, truck or other vehicle.
If he becomes certified, he can purchase any size container of refrigerant and
perform the topping off himself. Of course, farmers and DIYers should take
all reasonable steps to avoid the release of refrigerant when topping off a
system. Intentional venting is illegal, but should not normally occur during
the topping off procedure if it is done properly.
Other Servicing. Should a farmer or other DIYer wish to do more than merely
top off, such as replace leaky or worn out components of an a/c system, then
in order to avoid venting refrigerant when opening up the a/c system, the
farmer or DIYer must make sure that the refrigerant gets recovered first. The
refrigerant does not need to be extracted into EPA-approved recover/ recycling
equipment -- it can be extracted into homemade equipment, for example -- but
it must not be vented! Venting refrigerant can lead to fines of $25,000 per
If the farmer or DIYer does not own recovery equipment, he can
drive the vehicle to a service facility, or hire a certified technician
who has recover/recycle equipment to come to the vehicle and service it.
Q: Apart from R-134a, what are some other refrigerants approved by EPA? Do I
need to be certified to purchase them or install them in my vehicle's a/c
system? Are there refrigerants that EPA considers unacceptable?
A: EPA has approved R-134a and FRIGC*, a blend manufactured by Intermagnetics
General Corporation of Latham, New York. FRIGC's manufacturer has informed
EPA that FRIGC will initially be marketed for use in vehicle fleets only.
Only certified technicians may purchase FRIGC, since it contains a chemical
that depletes the ozone layer (although it does far less damage than R-12).
You can call the Ozone Hotline in order to determine if other substitutes are
approved by EPA in the future.
Two refrigerants, OZ-12 and HC-12a, have been declared unacceptable by EPA,
because of unanswered flammability concerns. It is illegal to use these
refrigerants. They are both manufactured by OZ Technology, Inc. of Post
Falls, Idaho. EPA has also stated that all flammable substitutes are
unacceptable for use in vehicle a/c conversions.
Q: I'm not a certified technician and so I cannot purchase R-12. I've been
thinking about converting my motor vehicle air-conditioning system to use
R-134a, since I can purchase that refrigerant. What facts should I know
before I convert?
A: First, EPA may restrict the sale of R-134a to certified technicians only.
The proposed rule which would contain this provision (should EPA decide to
propose a sales restriction) should be published in August, and, after thirty
days of taking comment from the public, the final rule should be published in
November. Check with the Ozone Hotline after the publication of the proposal
to see if the sales restriction provision is contained in the proposed rule.
If the provision becomes part of the final rule, then sales of R-134a will be
limited to certified technicians shortly after publication of the rule.
EPA recommends that you consult your vehicle manufacturer, an
authorized dealer or a reputable service facility about conversion
procedures. Many manufacturers have made retrofit guidelines available.
To convert to R-134a, you will need at a minimum to change all the lubricant
to a PAG or POE (ester) oil, since R-134a is not compatible with mineral oil,
and you will have to put new fittings and a new label on the system. You may
also need to replace the accumulator or receiver/drier, and other components
of the system.
EPA rules require that any substitute only be used with fittings unique to
that refrigerant; that the person performing the conversion apply a specific
label to the system; and that the substitute not be used to "top-off" a system
that uses another refrigerant, without first extracting the old refrigerant.
Q: I have heard that R-134a does not cool nearly as well as CFC-12. Is this
A: Vehicle manufacturers have designed air-conditioning systems for new
vehicles that use R-134a while maintaining reliability and cooling
performance. Conversion specifications for a/c units using R-134a are also
being designed to maintain performance, but this may vary depending on the
condition of the unit prior to the conversion, and on other factors. Should
you feel that your a/c system does not perform as well after converting to
R-134a, you should contact the vehicle manufacture and/or a reputable service
technician. They may be able to recommend further changes to the system so
that it performs to your satisfaction.
Q: Why can't I use R-22 in my system?
A: There are three good reasons not to use R-22 in your system.
First, R-22 is not compatible with the polymer and rubber products used in
vehicle a/c systems such as O-rings and hoses, and can cause these products to
det- eriorate. In addition, the small size of the molecules in R-22 often
causes the chemical to leak through hoses.
Second, R-22 has significantly higher operating pressures than R-12 -- at
normal atmospheric temper- atures, R-22 pressures can be double those of R-12.
Although R-134a also operates at higher pressures than R-12, the difference
in the pressures is much smaller than the difference between R-22 and R-12
operating pressures. The control circuits, evaporative assemblies, and other
components in a/c systems designed for use with R-12 may not be able to
withstand these higher pressures, and system failure may result.
Third, it's illegal. Any chemical proposed for use as a substitute to R-12
must first be submitted to EPA for review of its health and environmental
effects. If EPA determines that the chemical is safe for use in a particular
application, the chemical may then be used as a substitute for R-12. Until
that happens, it is illegal to use the substitute in that application. To
date, no one has submitted R-22 to EPA for review for automotive use (most
likely because of the other two reasons set forth above).
Q: Why does freon cost so much now? I used to purchase a can of freon for
A: The price of refrigerant has increased over the last few years largely
because of the tax on the production of ozone-depleting chemicals enacted by
Congress as part of the Omnibus Trade and Recon- ciliation Act of 1989. The
tax rates were increased by Congress in the Energy Policy Act of 1992. The
tax rate per pound of freon for 1995 is $5.35. This summer, freon is
retailing at auto parts stores and warehouse stores at about $7.00 per pound
(which includes the tax).
Q: I'm not convinced that R-12 and other chlorofluorocarbons (CFCs) are
responsible for the thinning of the ozone layer. I'm not even sure that the
ozone layer is really thinning. How can I find out more about these issues?
EPA has a great deal of information you can receive on these subjects by
calling the toll-free Ozone Protection Hotline number listed at the top of
this factsheet. This information includes a factsheet entitled "Ozone
Depletion: The Facts Behind the Phaseout" and a brochure entitled "Reports to
the Nation: Our Ozone Shield."