HVACR Synthetic Greenhouse Gas Emissions and WH&S Assessment 151119
There is a good deal that we know about HVACR emissions and WH&S but there is also a good deal that we do not know that is important to HVACR policy development. The two dimensions are central to HVACR technology management because they are interactive. Here are the facts, as we know them, then the unknowns, and the implications for policy development.
- Climate change and ozone depletion are major sources of harm to health and well being of both humanity and ecosystems. This harm is vastly greater than HVACR WH&S harm or risk. There will be a global agreement to eliminate / reduce the use of HCFC/HFC’s and their emissions. All countries will have a fundamental responsibility to deliver this agreement and the industry will deliver the required technology for use worldwide. The required technology developments are well in hand.
- HFCs / HCFCs are a major source of climate change and ozone depletion worldwide causing global agreement to reduce / eliminate the use of ozone depleting / high GWP synthetic refrigerants (28-45% of radiative forcing if CO2 if stabilized at 450 ppm and HFC/ HCFC are not phased out / down).
- Low GWP refrigerants will be used to a far greater extent in future driven by both the need to reduce the direct emissions of HFC and HCFC and reduce the HVACR indirect emissions (energy consumption).
- There is extreme commercial interest in the use of and promotion of competing refrigerants because the global market for refrigerants is worth about $20B pa. The market for equipment using the range of refrigerants is worth about $150B pa wherein a large proportion is designed specifically for a particular refrigerant.
- The synthetic refrigerants industry offers HFOs, which are characterised as having a very low GWP and R32, which is characterised as having a GWP of 675 albeit its 20 yr. GWP is 2330. The natural refrigerants industry offers ammonia, carbon dioxide, hydrocarbons, air and water which all have GWP less than 3.
- Natural refrigerants offer energy efficiency that will make a further important contribution to emissions reduction. A significant proportion of equipment manufactures offer products designed for the use of natural refrigerants and that have been shown to be highly energy efficient.
- A good deal of industry attention has been drawn to the safety characteristics of alternative low GWP refrigerants. The synthetic refrigerants industry has sought to characterize HFOs and R32 as low flammability and nontoxic whilst characterizing ammonia and hydrocarbons as being highly flammable. The natural refrigerants industry considers the flammability of alternative low GWP refrigerants as similar and manageable when handled by competent professionals trained in their use. As a result the policies that address HVACR WH&S are highly contentious.
- It is possible to cause ignition of synthetic refrigerants and ammonia / hydrocarbon refrigerants albeit fire events that can be shown to be caused by refrigerant flammability are very infrequent. To the extent that WH&S authorities do not have data on the frequency of incidents involving refrigerant flammability. The dangerous goods code uses a different measure of flammability than the proposed refrigerants classification system. Why?
- We know that there is a very large number of unitary devices using HC refrigerants with no apparent or no quantified flammability risk. This also applies to MVAC using HCs in Australia
- The products of thermal decomposition of low GWP synthetic refrigerants are highly toxic. The conditions that give rise to this risk are common - e.g. front-end car accidents and refrigerant leakage onto hot surfaces.
- There is a significant number of toxicity and ignition events involving ammonia in other countries. The safe use of ammonia in large charge applications is well understood in Australia albeit local government intervention is highly variable and often counter productive given the safety record of ammonia use. New technology is enabling safe use of ammonia in small charge applications.
- There is a high level of intentional and unintentional emissions of F-Gas refrigerants. It is difficult and expensive to eliminate refrigerant leakage, albeit doing so is commercially warranted via energy efficiency and emissions reduction.
- There is contractor profit in intentional emissions. The HVACR contracting industry is comprised of a large number of organisations. The industry is highly decentralized and challenged to keep pace with technology developments.
- It is possible for a contractor to report the volume of recharging of any individual piece of equipment and this data can be aggregated and reported cost effectively.
- Leak detection technology is commonly available.
- The training available for the use of low GWP refrigerants is optional - not a required element for certification of a tradesman. The degree of training in the use of low GWP refrigerants is as yet very low. Licensing is the key driver to training for certification but is largely not available for low GWP refrigerants.
We do not know:
- The volume of F-Gas refrigerant emissions by sector or by contractor.
- The frequency of HVACR WH&S incidents in total, for any given refrigerant or categorized according to the causes of such incidents.
- The frequency of ignition events for any given refrigerant, their location and their cause.
- The frequency of toxicity events from synthetic refrigerants, their location and their cause.
- The consequences of a high level of ongoing inhalation of synthetic refrigerants. There is preliminary evidence that it is a health risk.
- The extent to which technicians employ safety measures required by refrigerant MSDS
- Environmental impacts of synthetic refrigerants other than causing radiative forcing (indirect emissions associated with manufacture, indirect emissions associated with end of life equipment disposal, long term effects of exposure for HVACR practitioners, the products of thermal combustion, TFA)
- The products of atmospheric decomposition of low GWP refrigerants that contain synthetic refrigerants that have a high GWP.
- The long term environmental and human health effects of accelerated commercialization of so-called 4th generation refrigerants (HFO’s)
Given what we know and don't know the implications are:
- Utmost attention, investment should and will be made to reduce / eliminate the use of HFC / HCFC refrigerants and capitalize on the energy efficiency of low GWP refrigerants particularly natural refrigerants.
- HFC emissions are an externality that should be incorporated into the cost structure of the HVACR industry by requiring the users of F-Gas to pay for the cost of regulating and educating the industry. One might argue that all refrigerants should be subject to this cost given the importance of education in the use of Low GWP refrigerants.
- The OPSGG MA should be enforced and the trade should be made aware of this in order to reduce F-Gas emissions.
- DoE should require the reporting of F-Gas recharge rates for all equipment with the objective of minimizing environmental impacts. This data should be aggregated and analyzed to assess the degree of F-gas emissions by sector, by contractor and by cause and with repeat refrigerant replenishments conditioned by implementation of leakage elimination measures.
- There is a need to develop and implement nationally consistent HVACR WH&S standards and regulations.
- All refrigerants should only be available for use by people trained in their use with due regard for the range of particular refrigerant safety management and emissions reduction characteristics.
- The commercial value of HVACR requires that it be regulated and supervised to ensure the alternative refrigerants are properly represented to tradesmen and end users. There is therefore a need for a commercially independent regulatory authority to oversee the development of HVACR regulation and the enforcement of HVACR regulation and to do so without commercial bias.