Audit, Compliance and Risk Blog

Motor Vehicle Air Conditioner (MVAC) Refrigerants Have Environmental Impacts

Posted by STP Editorial Team on Wed, Feb 05, 2014

http://www.stpub.com/vehicle-maintenance-facilities-a-california-compliance-guide-onlineEPA has a new fact sheet, “Section 609 Regulatory Requirements: Motor Vehicle Air Conditioning” that outlines the requirements to be followed to prevent the release of refrigerants during the servicing of MVACs and MVAC-like appliances. This fact sheet discusses the regulatory requirements for technician training and certification, sales restrictions, safe disposal, recordkeeping, equipment certification, and approved equipment. It also addresses the importance of protecting our ozone layer and explains the serious impact MVACs can have on the climate:

“For example, the global warming potential (GWP) of CFC-12 is approximately 10,000 times greater than that of carbon dioxide (CO2), a greenhouse gas that contributes to climate change. Currently, most MVACs use HFC-134a (also known as R-134a), a refrigerant that does not deplete the ozone layer, but has a GWP that is approximately 1,400 times greater than CO2. Alternative refrigerants such as CO2 and hydrofluoroolefin (HFO)-1234yf do not deplete the ozone layer and have much lower GWPs than CFC-12 or HFC-134a. CO2 has a GWP of 1 and HFO-1234yf has a GWP of 4. MVACs alone represent about 15% of the global use of HFCs.”

Globally Harmonized System Update to Hazard Communication

California Occupational Safety and Health Administration (Cal/OSHA) is readopting amendments to 29 sections of Title 8 of the California Code of Regulations, and is also amending the appendixes to many of these sections, that were approved and filed on May 6, 2013. The purpose of the amendments was to conform them to recent amendments in federal standards that address updates to the Hazard Communication Standard (HCS) and related sections and ensure that state requirements for hazard communication are at least as effective as the federal standards for HCS programs, which include warning labels, signs, and safety data sheets, and employee training to inform workers and other downstream users of manufactured and imported chemical products. This action revises the existing language for hazard determination to include new wording from the federal standard that requires manufacturers, importers, and employers classifying chemicals to consider the full range of available scientific literature and other evidence. It also includes new federal wording requiring those classifying chemicals to use the criteria in Appendix A for health hazards and in Appendix B for physical hazards. The effect of this change is to require that chemicals be classified as required by the federal regulations, and to also require chemical classifiers to disclose the identity and hazard associated with chemicals that the classifier has determined do not meet the criteria for a specific classification. This retains the existing requirements to disclose the identity of all chemicals for which there is scientifically valid evidence of a hazardous effect, and does not conflict with the federal requirements for classification. These changes took effect November 6, 2013 (California Notice Register 2013 No. 46-Z, page 1787).

STP has recently published an update to its publication Vehicle Maintenance Facilities in California: A Federal and State Compliance Guide and also publishes the following related guides:

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photo credit: Toyota Motor Europe via photopin cc

Tags: Employer Best Practices, Health & Safety, California Legislation, Environmental, Transportation