As a private citizen, I want to take the time to applaud the EPA’s efforts to protect the environment with this proposal and to show my support. Not only will it remedy the problem we have of using hydrofluorocarbons (HFC) that are 14,000 times more damaging to the Earth than the prevalent Carbon Dioxide gas, but it will also help to prevent increased HFC use in developing countries. The EPA’s own analysis showing that the proposal will give a benefit equal to removing greenhouse gas emissions from 420 million cars each year through 2050 is an incredible statistic that cannot be ignored. Replacing the CFC-12 and HCFC-22 with isobutane, propane, HCR-188C, and HCR-188C1, hydrocarbon refrigerants that have no ozone depleting potential and/or little global warming potential, is a fantastic idea with few drawbacks. Safety, of course, is a chief concern. However, use of these hydrocarbon coolants is nothing new for countries like Germany, the United Kingdom, Australia, and Japan who’ve been using them for over 10 years. Precautions set forth in the proposal such as its use in only new equipment, labeling, special fittings/connections, and appropriate safety standards will mitigate flammability and explosive concerns. Even toxicity is of no real concern – long time exposure levels don’t come close to OSHA or NIOSH permitted/recommended exposure levels. So long as safety remains a vital part of the proposal, the changed from HFC to Hydrocarbon Refrigerants seems to be a positive one.
Anonymous public comment
This is comment on Proposed Rule
Protection of Stratospheric Ozone: Listing of Substitutes for Ozone-Depleting Substances - Hydrocarbon Refrigerants
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