NAFEM provides input to EPA re: listing of refrigerants for medium-temperature use
EPA recently closed the comment period for its NOPR to list refrigerants R-448 and R-449A and B for medium-temperature, stand-along units. On behalf of members, NAFEM submitted comments to the agency stating that the proposed narrow-use limits are too narrow and the record-keeping requirement too ambiguous and burdensome. NAFEM commented that these refrigerants are necessary to “produce refrigeration equipment needed in the marketplace that otherwise may not be possible.” NAFEM also asked for clarity about the documentation and technical investigation of alternatives outlined in the proposed rule. Finally, NAFEM requested that EPA consider its proposed approach to cost-benefit analysis (see article above) when finalizing its rules around these refrigerants.