November at-a-glance…environment

NAFEM provides comments to Massachusetts

With no national standard, states continue to propose HFC reductions

On behalf of members, NAFEM submitted comments to proposed regulations by the Massachusetts Department of Environmental Protection (MassDEP) that would prohibit the use of certain hydrofluorocarbons (HFCs) in refrigeration equipment, air conditioning chillers, aerosol propellants and foams manufactured or used in the state. Prohibitions would be phased in Jan. 1, 2021 to Jan. 1, 2024.

In its comments, NAFEM recommended MassDEP align its definitions with those used by the U.S. Environmental Protection Agency (EPA) and clarify language around excluded uses. To help manufacturers manage state-by-state product labeling requirements, NAFEM further recommended that, “’Written disclosure can be provided through disclosure via on-unit labeling or symbols, the owner’s manual, or via an online portal available to consumers.” Additionally, because many manufacturers have had their product design and manufacturing processes disrupted by the COVID-19 pandemic, NAFEM requested that, “MassDEP engage in further discussions with manufacturers and end-users to determine if the effective dates in the proposed regulation are realistic compliance deadlines.”

Calif. considers prohibition of certain HFCs

Stakeholders request delay from 2023 to 2025

The California Air Resources Board (CARB) plans a Dec. 10 public hearing to consider approval of amendments to prohibit the use of certain hydrofluorocarbons (HFCs). The proposed rules include a global warming potential (GWP) limit of 150 on new stationary refrigeration systems containing more than 50 pounds of refrigerant in new facilities starting Jan. 1, 2022; company-wide emissions reduction targets for retail food companies by 2030; a GWP limit of 750 for new stationary air conditioning systems starting Jan. 1, 2023, and inclusion of a variance process. Stakeholders have requested CARB delay the effective date for the 750 GWP limit for new stationary air conditioning equipment from Jan. 1, 2023, to Jan. 1, 2025, and have submitted alternative proposals for achieving emissions reductions. CARB is accepting written comments through Dec. 7. Comments also can be presented in person when the topic is discussed during CARB’s two-day meeting Dec. 10 – 11. Details and public comments received are available on CARB’s website.

Rhode Island to review draft HFC reduction regulation

Rhode Island’s Department of Environmental Management is holding a virtual stakeholder workshop Dec. 11 at 10 a.m. Eastern to discuss the state’s proposed regulations to reduce the use of certain hydrofluorocarbons (HFCs) in air conditioning and refrigeration equipment, aerosol propellants and foam end uses beginning Jan. 2021. Members wishing to attend the workshop must preregister. Those interested also can email Allison Archambault with specific questions or topics they’d like addressed at the workshop. Written comments can be submitted to Archambault until Dec. 22.

EU SCIP database live

Manufacturers required to declare substances of very high concern

To further the European Union’s (EU) circular economy, the European Chemicals Agency (ECHA) launched the new Substances of Concern in Articles in Products (SCIP) database in October, with company compliance required by January 2021. Despite efforts to delay the launch due to COVID-19, ECHA mandates that manufacturers declare any final products and components that contain more than 0.1 percent (by weight) of any of more than 200 substances of very high concern (SVHC).

The National Association of Manufacturers (NAM) is seeking input from companies using/testing the database to understand whether they are encountering logistical or other issues. Companies with concerns should contact NAM’s Ryan Ong.