Negative Impacts
of
EPA’s SNAP
Regulation
Who is NAFEM ?
The North American Association
of
Food Equipment Manufacturers Represents:
 550 foodservice equipment & supplies manufacturers
 220 members w/annual revenues of $5M or less;
 78 members w/annual revenues of $5-10M;
 89 members w/annual revenues of $25-10M.
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NAFEM Members Manufacture:
 Blast Chillers
 Cabinets,
Refrigerated
 Cook-Chill
Systems
 Coolers, Bar
Back
 Coolers,
Beverage
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 Coolers,
Display/Floral
 Coolers, Milk
 Reach-in
Cooler
 Walk-In Cooler
 Coolers, Wine
 Coolers,
Display/Pastry
 Deli Cabinets,
Cases
 Dispensers, Ice,
Ice & Beverage
 Dispensers, Ice
Cream
 Dispensers, Ice
Tea
NAFEM Members Manufacture:
 Freezer Bases,
Undercounter
 Freezers, Reach-in,
Roll-in
 Freezers, Soft Ice
Cream
 Gelato Equipment
 Ice Crushers
 Ice Machines
 Ice Storage &
Transport
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 Refrigerated
Merchandisers
 Refrigerated Passthrough
 Refrigerated
Drawers
 Remote
Compressors &
Condensers
 Refrigeration
Evaporators
 Refrigerator Bases
 Refrigerators,
Reach-in, Roll-In
 Refrigerators, Walkins
 Slush Machines
 Sno-Cone Machines
 Vending Machines
SNAP Basics
5

The Significant New Alternatives Policy (SNAP) Program is
authorized by Section 612(c) of the Clean Air Act.

SNAP is designed to protect the stratospheric ozone layer by
phasing out ozone-depleting chemicals.

To meet this goal the EPA publishes and updates lists of
acceptable and unacceptable substitutes for class I or class
II ozone-depleting substances.

Status of substances is determined by EPA’s determination a less
harmful alternative is available.
Industries Targeted by SNAP
 Refrigeration & Air
Conditioning
 Sterilants
 Foam Blowing Agents
 Tobacco Expansion
 Cleaning Solvents
 Adhesives, Coatings & Inks
 Fire Suppression and
Explosion Protection
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 Aerosols
SNAP Basics:
Proposed Alternative Refrigerants
Equipment Considered
Retail food refrigeration
(new stand-alone only)
Proposed Additions
Previously approved 12/20/11 76
FR 78832
Isobutane (R-600a)
Limit 150 gr (5.29 oz.)
R441A
Propane (R-290)
Very low temperature refrigeration
and non-mechanical heat transfer
(new stand-alone only)
Ethane (R-170)
Limit 150 gr (5.29 oz.) multi
systems
--
Retail food refrigeration
(condensing units and supermarket
systems)(new)
(condensing units and supermarket
systems)(retrofit)*
No new proposed additions
--
Vending machines
(new)
Isobutane (R-600a), Propane (R290)
Limit 150 gr (5.29 oz.)
R441A
CO2 (R-744)
Household refrigerators and freezers
(new only)
Propane (R-290)
Limit 57gr (2.01 oz.)
Isobutane (R-600a)
R-441
Residential and light commercial AC and
heat pumps.
(new)
Propane (R-290)
Difluoromethane (HFC-32, R-32)
R-441
Limits vary-see table 3-6 in NPRM
* doesn’t apply to large CRE systems
such as multiplex direct expansion
systems, WICF due to charge limits
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Issues with Proposed
Alternative Refrigerants
 Not “Drop-In” Replacements
 Flammable
 High Pressure
 Unavailable in US Market
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Refrigerant Evaluation Factors
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SNAP Blowing Agent Issues

What is the EPA is specifically delisting?
–

What alternatives are Available?
–

Water based & Cyclopentane
Why the alternatives don’t work?
–
–

R134A
Foam Formation/Filling Issues
Decreased Thermal Resistance Leads to Increased Heat Loss
Why a supplier switch would be necessary?
–
Suppliers are choosing one substitute over another

Costly Extension to Time it Takes to Manufacture Each Product & Sales Per Year

May Impact Foodservice Heating Equipment
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Executive Branch Over Regulation
DOE & EPA Regulations

EPA SNAP
Stakeholder
Meetings
DOE
ECS Ice
Cream
Freezers
NOPR
DOE
NOPR
ECS
Vending
Machines
2005
2006
DOE Final
Rule on ARI &
ASHRAE
Energy Use
Calculation
2007
2008
2009
DOE ECS
Ice
Cream
Freezers
Final Rule
DOE Final
Rule on
ACIM Test
Procedure
EPACT
Enacted
2010
2011
DOE Ice
Maker DOE Final
Final Rule
Rule
Vending
Machine
Effective
Date
DOE ECS
CRE
WIC/F
Dates
2012
DOE Test
Procedure
Final Rule
Comm.
Refrig.
2013
DOE Test
Procedure
NOPR Ice
Makers
Ice
Maker
ECS
NOPR
DOE Final
Rule on Ice
Maker ECS
2014
2015
2016
EPA V 3.0
Energy Star
Compliance
Date
EPA has announced the review of hot food holding cabinet
ratings & is exploring blast chill freezers as potential products
to add to the program.
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2017-2018
Ice Maker
ECS
Effective
Date*est*
Executive Branch Over Regulation
 DOE’s Automatic Commercial Ice Makers Energy Conservation
Standards Rulemaking, Docket No. EERE-2010-BT-STD-0037
 DOE’s Commercial Refrigeration Equipment Energy Conservation
Standards Rulemaking, Docket No. EERE-2010-BT-STD-003
 DOE’s Walk-in Coolers and Walk-in Freezers Energy Conservation
Standards Rulemaking, Docket No. EERE-2008-BT-STD-0015
 EPA’s Protection of Stratospheric Ozone: Listing of Substitutes for
Refrigeration and Air Conditioning and Revision of the Venting
Prohibition for Certain Refrigerant Substitutes, Docket No. EPA-HQOAR-2013-0748-0001
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Markets SNAP will Impact
 Restaurants/Chains
(990,000 in the US)
 Corporate Facilities
 Correctional Facilities
 Health Care
 Lodging & Casinos
 Schools
 Science, Floral, etc.
 Supermarkets
 Mass Transportation
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SNAP Unintended Consequences
• Marketplace Variety Reduction
• Unknown User & Operator Safety & Health Risks
• Costly Infrastructure Changes to Plants
• Trapped Inventory Through Supply Chain
• Gives Advantage to Foreign Companies Importing Products
• Lab Testing Shortages Causes Noncompliance
• Passes Direct Costs to Customers
• Limits Product Innovation
• Increased Insurance, Placement, & Servicing Costs for
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Customers
Stakeholder Impacts:
Small Business Questions
• Are your costs “as-incurred”?
• Do you have limited or uncertain financing options?
• How much will this raise your insurance premiums?
• What training will be required and how will you pay for it?
• Have your 2015 budgets and capital requests been made?
• Do your local building and fire codes and regulations support
flammable refrigerants?
• Can your current facility run concurrent operations while
transitioning?
• Can small companies compete (from a technical resource pool
standpoint) with the salary and benefits offered to develop these
products?
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Request to EPA
 Extend the compliance deadline:
– To prevent dramatic and sudden price increases.
– To allow time to ensure product lines are safe.
– To allow time for product testing.
– To allow time for training.
– To allow time for components & refrigerants to become
available in the US market.
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Coalition Action: Next Steps
 Letters Requesting Extension from Hill
 Committee Outreach: 2014 Hearings &
Legislation
 Develop Coalition Materials
 Weekly Meeting/Membership Outreach
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SNAP Coalition
Thank you for taking time to learn about SNAP
and how it will impact each of your industries.
NAFEM looks forward to working with you as a
voice demanding common sense in the
regulatory process.
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Contact:
Annie McCarthy
NAFEM Government Relations
202.714.6162
[email protected]