1. Barrier Removal Status In 2006 EC/USA/Japan announced global cooperation removing barriers to alternative refrigerants –CO2 –HFC-152a –new fluorocarbons

2. Unintentional barriers identified –Department of Transportation accumulator pressure requirements Accumulators must be able to withstand 5 times their pressure when charged (static) 49 CFR 173:306(f)(1) –State bans on toxic auto A/C refrigerants Vehicle air conditioning systems shall be designed with regard for safety of the of passengers and shall not contain any refrigerant that is toxic No toxicity threshold established by the laws

3. Health & safety requirements Occupational Safety and Health Administration (OSHA) requirements for high-pressure gas: –Training –Personal protective equipment –Safe handling of high-pressure gas –Pressure relief devices –Equipment inspection –Worker exposure limits –Ventilation requirements –Proper refrigerant storage

4. Removing Barriers Through Unprecedented Global Private/Public Cooperation Alliance of Automobile Manufacturers Audi – Germany Behr Group - Germany BMW – Germany & North America Centro Ricierche Fiat - Italy DENSO - Japan Environmental Protection Agency – USA European Commission Hydro - Norway Ingersoll-Rand - Czech Republic MACS Worldwide - USA Modine - USA Obrist Engineering - Austria Parker Hannifin - Germany Prospective Technology - USA Barrier Removal Team Chaired by Kristen Taddonio, US EPA PSA Peugeot Citroën – France Red Dot - USA Sanden - Japan Shecco Technology – Norway Society of Automotive Engineers International Texas Instruments - Netherlands TEXA S.p.A. - Italy Thomas Magnete - Germany Toyota – Japan & USA U.S. Army - USA Volvo - Sweden VDA - Germany VOSS Automotive - Germany Witzenmann - Germany

5. Great Progress So Far… Department of Transportation accumulator pressure requirements waived NHTSA confirms no barriers OSHA health & safety requirements will be satisfied with standards in development No state barriers so long as safety demonstrated …total success with safety documentation

6. U.S. Department of Transportation Waives Pressure Requirement “[Air conditioning systems] are an integral component of a motor vehicle and necessary for the operation of the vehicle”… “Based on the information you provided, the air conditioning system…is not subject to the Hazardous Materials Regulation.” –John A. Gale, Chief of Standards Development US Department of Transportation (DoT) Pipeline and Hazardous Materials Safety Administration 11 July 2006

7. NHTSA Confirms No Barriers Exist The National Highway Traffic and Safety Administration (NHTSA) confirmed no barriers to alternative refrigerants under existing rules

8. OSHA, EPA, & SAE Cooperate to Assure New Technology Meets US Health and Safety Requirements SAE J-Standards in progress: “Recommended practice for servicing R744 [CO2] & R152a mobile air conditioning systems” The SAE Standards will meet Occupational Safety and Health Administration (OSHA) requirements for training, personal protective equipment, safe handling, pressure relief devices, equipment inspection, worker exposure, ventilation, and refrigerant storage

9. State Barriers Removed Barriers existed in over a dozen U.S. states: Arizona, Arkansas, Connecticut, D.C., Florida, Idaho, Indiana, Kansas, Louisiana, Maryland, North Dakota, Oklahoma, Texas, Virginia, Washington, Montana, Arizona, Utah Barrier removal team confirmed CO2 can be used in Arizona, Arkansas, Connecticut*, D.C., Florida, Idaho, Indiana*, Kansas*, Louisiana*, North Dakota, Oklahoma*, Texas*, Virginia, Utah, Washington In MD, the state Department of Environment has not yet made a decision regarding CO2. However, legislation is currently being proposed to bring MD laws into conformity with Federal laws. * Usage conditions apply. MAC systems must conform to federal guidelines and SAE recommended practices.

10. Safety documentation developed by this meeting must satisfy state authorities that Federal exposure limits will be met and that technicians will be able to use CO2 safely Critical Items: –Engineering strategies to ensure compliance with Federal regulations –SAE standards completed and under development for CO2 safety –Service shop safety strategy –Anticipated parts challenges –Develop comprehensive appendixes covering CO2 studies to date Safety report will be posted on EPA website Safety Documentation Strategies

11. Thank You Kristen Taddonio Manager, Strategic Climate Projects US EPA Climate Protection Partnerships Division +1 202 343 9234 Taddonio.kristen@epa.gov