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Negative Impacts of

EPA’s SNAP

Regulation

2

Who is NAFEM ?

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.

3

NAFEM Members Manufacture:

 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

4

NAFEM Members Manufacture:

 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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SNAP Basics

 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.

6

Industries Targeted by SNAP

 Refrigeration & Air

Conditioning

 Foam Blowing Agents

 Cleaning Solvents

 Fire Suppression and

Explosion Protection

 Aerosols

 Sterilants

 Tobacco Expansion

 Adhesives, Coatings & Inks

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SNAP Basics:

Proposed Alternative Refrigerants

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

8

Issues with Proposed

Alternative Refrigerants

 Not “Drop-In” Replacements

 Flammable

 High Pressure

 Unavailable in US Market

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Refrigerant Evaluation Factors

SNAP Blowing Agent Issues

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

10

Executive Branch Over Regulation

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*

Executive Branch Over Regulation

 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

Markets SNAP will Impact

 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

SNAP Unintended Consequences

14

• 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

Stakeholder Impacts:

Small Business Questions

• 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?

Request to EPA

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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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Coalition Action: Next Steps

 Letters Requesting Extension from Hill

 Committee Outreach: 2014 Hearings &

Legislation

 Develop Coalition Materials

 Weekly Meeting/Membership Outreach

SNAP Coalition

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

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