Among the requirements of the American Innovation and Manufacturing (AIM) Act of 2020 is a ban on disposable, single-use cylinder tanks used to transport refrigerants through the supply chain to an HVAC installer.
A final rule posted by the Environmental Protection Agency (EPA) on October 5, 2021, will prohibit the use of disposable cylinders in the next several years.
HVAC installers use the disposable cylinders every day to transport hydrofluorocarbon (HFC) refrigerants including R32 and R410A.
Refrigerants transported in refillable cylinders
Instead, under the ban, refrigerants must be transported in refillable cylinders, which are heavier and difficult to handle in cramped spaces or on ladders. Handling the heavier refillable cylinders will contribute to injuries and long-term strain on technicians.
Imports and placement of HFCs into new disposable cylinders must end by January 1, 2025, and an outright ban on the sale of disposable cylinders will happen on January 1, 2027, according to rules passed by the EPA.
A proposed tracking system will use QR codes on each refillable cylinder, tied to a central database that will identify the producer or importer and track the “chain of custody” of the cylinder.
eliminating the use of disposable cylinders
The small amount of refrigerant will find its way into the atmosphere, either by leaking out or when the cylinder is crushed
There are two stated reasons the EPA is eliminating the use of disposable cylinders. One is environmental concerns about the small amount of refrigerant left in a disposable cylinder after it is used.
This small amount of refrigerant (the “heel”) will eventually find its way into the atmosphere, either by leaking out or when the cylinder is crushed for recycling.
The other stated reason is to curb illegal HFC trafficking and imports because smugglers use the inexpensive and untraceable disposable tanks.
bipartisan legislation passed by Congress
The AIM Act was bipartisan legislation passed by Congress and signed into law in late 2020; it gives the EPA authority to phase down HFCs to 15% of their baseline levels by 2036.
Industry opponents contend the ban on disposable cylinders exceeds the authority granted to the EPA by the AIM Act. Opponents also contend that banning non-refillable cylinders is an unnecessary restriction that does almost nothing to protect the environment.
Hassles for the HVAC industry
The ban would also impose financial and logistical difficulties on contractors and the broader industry
The HVAC industry also sees the tracking database as onerous. For example, distributors would need to track individual cylinders with their EPA identifier number and report which cylinders are sold to which customers.
The measure would also impose financial and logistical difficulties on contractors and the broader industry. One estimate of the cost to U.S. companies of setting up a fleet of refillable cylinders is $2 billion.
There is also concern about how returned cylinders containing A2L refrigerants can be handled to meet fire code requirements for storage of flammable gases. Implementing the new requirements could also further constrain the cooling supply chain, which is already stressed.
Worthington Industries petitioned the EPA to rescind
Worthington Industries, the only U.S. manufacturer of disposable cylinders, has petitioned the EPA to rescind the ban and proposes an alternative approach – a lightweight, fully recyclable cylinder – that addresses concerns about smuggling and heel emissions.
HARDI, the U.S. association of HVAC wholesalers, has filed a lawsuit against the EPA in an effort to overturn the ban. They are joined in the petition by Air Conditioning Contractors of America (ACCA), and the Plumbing-Heating-Cooling Contractors – National Association (PHCC).
Non-refillable, disposable cylinders have already been banned in several countries, including the European Union (EU), Canada and Australia. In these locations, smugglers have adapted to other types of containers.
