Despite the hazardous nature of propane (R-290), a recent EPA notice of proposed rulemaking seeks to expand its uses in refrigeration and air conditioning systems while also exempting these systems from Clean Air Act venting restrictions. If finalized, this rule would allow for propane venting during system installation, maintenance, repair, and disposal, which raises significant concerns about the lack of consideration for propane’s environmental impact and dangers. The industry position is clear: EPA should not finalize the exemption in the proposed rule and, instead, prohibit the venting of propane in the final rule.
The disparity in the proposed treatment of propane compared to other refrigerant products underscores a pivotal issue: the misguided belief that so-called “natural” refrigerants, including propane, are inherently more environmentally and operationally preferable to other options.
There are numerous misconceptions about the applications and limitations of “natural” refrigerants. The reality is that CO2 and ammonia are synthetically produced, energy-intensive, and costly. In the case of propane, butane, isobutane and the other hydrocarbons, these are as natural as an oil and gas wellhead and are shipped in giant oil tankers.
In practical terms, EPA’s proposal for Significant New Alternatives Policy (SNAP) Rule 26 favors propane releases, failing to consider its classification as a very volatile organic compound (VVOC). VVOCs are substances that rapidly evaporate, damaging air quality. They contribute to ground-level ozone and smog, both of which harm the environment. Permitting the venting of propane is unreasonable and out of alignment with EPA’s broader environmental and safety objectives
A balanced, risk-based regulatory approach would account for the fact that propane venting poses not only an air quality concern, but also an immediate safety hazard. Propane is classified as an A3 refrigerant and demands extra precautions due to its high flammability. In contrast, refrigerants such as HFOs and HFCs are neither volatile organic compounds nor highly flammable, but they are subject to “no venting” regulations.
Another observation is the regulatory differentiation between the use of propane in consumer products and its application within HVACR systems. Propane is rightly subjected to regulations as a volatile organic compound in consumer products, which include established limits and prohibitions on its usage. However, it appears that the regulations governing its use in HVACR applications, including SNAP rules, may not take into account the same potential impacts. This divergence in the treatment of propane across different contexts raises questions about how regulators are evaluating risk.
In the complex and evolving refrigerant landscape, achieving balanced regulations is possible, but requires that policymakers utilize comprehensive, credible information when regulating the products they oversee. Only then can we balance our environmental goals with the practical needs of individuals, communities, and businesses. We encourage EPA to consider the comments submitted by industry and prohibit the venting of propane.
