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The North American Association of
Food Equipment Manufacturers Represents:
550 foodservice equipment & supplies manufacturers
220 members w/annual revenues of $5M or less;
78 members w/annual revenues of $5-10M;
89 members w/annual revenues of $25-10M.
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Blast Chillers
Cabinets,
Refrigerated
Cook-Chill
Systems
Coolers, Bar
Back
Coolers,
Beverage
Coolers,
Display/Floral
Coolers, Milk
Reach-in
Cooler
Walk-In Cooler
Coolers, Wine
Coolers,
Display/Pastry
Deli Cabinets,
Cases
Dispensers, Ice,
Ice & Beverage
Dispensers, Ice
Cream
Dispensers, Ice
Tea
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Freezer Bases,
Undercounter
Freezers, Reach-in,
Roll-in
Refrigerated Passthrough
Freezers, Soft Ice
Cream
Refrigerated
Merchandisers
Refrigerated
Drawers
Gelato Equipment
Ice Crushers
Ice Machines
Ice Storage &
Transport
Remote
Compressors &
Condensers
Refrigeration
Evaporators
Refrigerator Bases
Refrigerators,
Reach-in, Roll-In
Refrigerators, Walkins
Slush Machines
Sno-Cone Machines
Vending Machines
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The Significant New Alternatives Policy (SNAP) Program is authorized by Section 612(c) of the Clean Air Act.
SNAP is designed to protect the stratospheric ozone layer by phasing out ozone-depleting chemicals.
To meet this goal the EPA publishes and updates lists of acceptable and unacceptable substitutes for class I or class
II ozone-depleting substances.
Status of substances is determined by EPA’s determination a less harmful alternative is available.
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Refrigeration & Air
Conditioning
Foam Blowing Agents
Cleaning Solvents
Fire Suppression and
Explosion Protection
Aerosols
Sterilants
Tobacco Expansion
Adhesives, Coatings & Inks
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Equipment Considered Proposed Additions
Retail food refrigeration
(new stand-alone only)
Isobutane (R-600a)
Limit 150 gr (5.29 oz.)
R441A
* doesn’t apply to large CRE systems such as multiplex direct expansion systems, WICF due to charge limits
Very low temperature refrigeration and non-mechanical heat transfer
(new stand-alone only)
Retail food refrigeration
(condensing units and supermarket systems)(new)
(condensing units and supermarket systems)(retrofit)*
Vending machines
(new)
Household refrigerators and freezers
(new only)
Residential and light commercial AC and heat pumps .
(new)
Ethane (R-170)
Limit 150 gr (5.29 oz.) multi systems
No new proposed additions
Isobutane (R-600a), Propane (R-
290)
Limit 150 gr (5.29 oz.)
R441A
Propane (R-290)
Limit 57gr (2.01 oz.)
Propane (R-290)
Difluoromethane (HFC-32, R-32)
R-441
Limits vary-see table 3-6 in NPRM
Previously approved 12/20/11 76
FR 78832
Propane (R-290)
--
--
CO
2
(R-744)
Isobutane (R-600a)
R-441
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Not “Drop-In” Replacements
Flammable
High Pressure
Unavailable in US Market
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What is the EPA is specifically delisting?
– R134A
What alternatives are Available?
– Water based & Cyclopentane
Why the alternatives don’t work?
– Foam Formation/Filling Issues
– Decreased Thermal Resistance Leads to Increased Heat Loss
Why a supplier switch would be necessary?
– Suppliers are choosing one substitute over another
Costly Extension to Time it Takes to Manufacture Each Product & Sales Per Year
May Impact Foodservice Heating Equipment
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DOE & EPA Regulations
EPACT
Enacted
DOE
ECS Ice
Cream
Freezers
NOPR
DOE
NOPR
ECS
Vending
Machines
DOE Final
Rule on
ACIM Test
Procedure
EPA SNAP
Stakeholder
Meetings
DOE ECS
Ice
Cream
Freezers
Final Rule
Ice
Maker
ECS
NOPR
DOE Final
Rule on Ice
Maker ECS
2005
2006 2007 2008 2009 2010
2011
2012 2013 2014
2015
2016
DOE ECS
CRE
WIC/F
Dates
2017-2018
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DOE Final
Rule on ARI &
ASHRAE
Energy Use
Calculation
DOE Ice
Maker
Final Rule
DOE Final
Rule
Vending
Machine
Effective
Date
DOE Test
Procedure
Final Rule
Comm.
Refrig.
DOE Test
Procedure
NOPR Ice
Makers
EPA V 3.0
Energy Star
Compliance
Date
EPA has announced the review of hot food holding cabinet ratings & is exploring blast chill freezers as potential products to add to the program.
Ice Maker
ECS
Effective
Date*est*
DOE’s Automatic Commercial Ice Makers Energy Conservation
Standards Rulemaking, Docket No. EERE-2010-BT-STD-0037
DOE’s Commercial Refrigeration Equipment Energy Conservation
Standards Rulemaking, Docket No. EERE-2010-BT-STD-003
DOE’s Walk-in Coolers and Walk-in Freezers Energy Conservation
Standards Rulemaking, Docket No. EERE-2008-BT-STD-0015
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EPA’s Protection of Stratospheric Ozone: Listing of Substitutes for
Refrigeration and Air Conditioning and Revision of the Venting
Prohibition for Certain Refrigerant Substitutes, Docket No. EPA-HQ-
OAR-2013-0748-0001
Restaurants/Chains
(990,000 in the US)
Corporate Facilities
Correctional Facilities
Health Care
Lodging & Casinos
Schools
Science, Floral, etc.
Supermarkets
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Mass Transportation
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• Marketplace Variety Reduction
• Unknown User & Operator Safety & Health Risks
• Costly Infrastructure Changes to Plants
• Trapped Inventory Through Supply Chain
• Gives Advantage to Foreign Companies Importing Products
• Lab Testing Shortages Causes Noncompliance
• Passes Direct Costs to Customers
• Limits Product Innovation
• Increased Insurance, Placement, & Servicing Costs for
Customers
• Are your costs “as-incurred”?
• Do you have limited or uncertain financing options?
• How much will this raise your insurance premiums?
• What training will be required and how will you pay for it?
• Have your 2015 budgets and capital requests been made?
• Do your local building and fire codes and regulations support flammable refrigerants?
• Can your current facility run concurrent operations while transitioning?
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• Can small companies compete (from a technical resource pool standpoint) with the salary and benefits offered to develop these products?
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Extend the compliance deadline:
– To prevent dramatic and sudden price increases .
– To allow time to ensure product lines are safe .
– To allow time for product testing .
– To allow time for training .
– To allow time for components & refrigerants to become available in the US market .
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Letters Requesting Extension from Hill
Committee Outreach: 2014 Hearings &
Legislation
Develop Coalition Materials
Weekly Meeting/Membership Outreach
Thank you for taking time to learn about SNAP and how it will impact each of your industries.
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NAFEM looks forward to working with you as a voice demanding common sense in the regulatory process.
Contact:
Annie McCarthy
NAFEM Government Relations
202.714.6162
amccarthy@smithbucklin.com