Avoiding the Icebergs Ahead

While it appears the industry is getting hit with a one-two punch from the DOE and EPA, that’s not entirely the case.

Ray-SoucieFoodservice operators, dealers, designers, service agents, reps and, yes, manufacturers, hang on to your hats. Changes to foodservice refrigeration regulations that take effect this year could potentially leave you out in the cold.

New regulations from both the Department of Energy (DOE) and the Environmental Protection Agency (EPA) will impact our industry in a big way. In their efforts to combat global warming and comply with the Energy Policy and Conservation Act of 1975 (EPCA) and the Clean Air Act, the DOE and EPA are laying down the law. Fortunately, the foodservice equipment industry has had an opportunity to respond, and there’s no need to shiver when thinking about the future of refrigeration. Compliance dates phase in over time, giving our manufacturing partners just enough time to come up for air.

Of course, when word started to spread about these changes, like many others in the industry, I found myself asking, “What does this mean to me, and why should I care?” That prompted me to confer with a longtime colleague, Rick Jones of Imperial Brown. Over the years, Rick has helped answer many of my refrigeration-related questions and is, in general, a good and objective resource for consultants like me. Knowing how active Rick has been with Air-Conditioning, Heating & Refrigeration Initiative (AHRI) and other industry associations, I knew he would cut to the chase and provide a clear picture of what’s about to happen. And I was right. With his blessing, I will share with you some of what we discussed.

What sparked all of this change? The DOE established minimum efficiency levels for commercial refrigeration equipment, including reach-in coolers and freezers and self-contained refrigeration equipment, in May of 2014. The next month, the DOE established minimum efficiency levels for both walk-ins of certain sizes and the associated refrigeration equipment. Finally, in developing its Significant New Alternatives Policy, commonly referred to as SNAP, the EPA outlined what types of refrigerants and insulation manufacturers can use. SNAP came down in July 2015. (For a more detailed look at the myths and realities about these regulations, check out this month’s Green Tip on page 94).

While it appears the industry is getting hit with a one-two punch from the DOE and the EPA, that’s not entirely the case. For most manufacturers, meeting the DOE’s energy efficiency requirements won’t be as challenging as meeting the EPA’s refrigerant standards. That’s because the latter appears to be a huge undertaking that requires retooling for use of new refrigerants and expensive re-testing to meet UL listings on different refrigeration designs.

SNAP remains an ever-evolving program due to the fact that as new information becomes available regarding human health, environmental risk and available substitutes, requirements may change. The primary driver of the current SNAP evolution is greenhouse gas emissions from refrigerants and foam blowing agents that are used for insulation.

New remote walk-in cooler refrigeration systems will require substitutes beginning January 1, 2018. New stand-alone medium-temperature units under 2,200 BTUh will require substitutes beginning January 1, 2019. Stand-alone units over 2,200 BTUh and all freezer systems must comply by January 1, 2020. The EPA has decided what refrigerants are acceptable. It is up to the industry to figure out how to keep it affordable. There is some concern within the industry about how the SNAP changes will affect the efficiency rules from the DOE.

So what does this mean to the industry? Those specifying refrigeration equipment that will be installed after these dates, please plan accordingly. Manufacturers will adapt to the new refrigerants and will likely settle on one or two options. These options include a blend of refrigerants or R-290 Propane, which is coming on strong, especially since it is a proven commodity in Europe.

Moving forward, customers may see subtle changes in design and more models available with Energy Star ratings. Harmful refrigerants will gradually be replaced with environmentally friendly options. An analogy to the automobile industry is appropriate: we went through growing pains, and yet cars are now more efficient and run cleaner.

At first pass, it becomes easy to think this is little more than a factory issue, but these rulings affect all foodservice professionals. Just as global warming has an impact on our planet, these changes affect our industry.

For example, operators may wish to know what category their walk-in falls under when deciding whether to repair an existing unit or purchase a new one. Further, refrigerant charts may be of little concern to an operator or a distributor, but understanding the cost and design implications, both current and moving forward, will be invaluable.

It’s the belief that complex regulations can bring out the best in our industry. Operators can protect their interests by working with professional foodservice consultants who are up to date on the current regulations. In conjunction with the manufacturer, they will provide written specifications for code-compliant reach-ins and walk-ins. A qualified dealer can then install the unit. Using factory-authorized service agents for installation of the refrigeration systems is always a wise choice, as they are familiar with the various refrigerants and are trained to install or dispose of them safely.

The best way to stay informed is to talk to industry representatives who are active in FCSI, AHRI and/or NAFEM.

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