The California Air Resource Board recently published the presentation for the March 5, 2008 Public Workshop on Proposed Amendments to the Consumer Products Regulation and some shocking proposals were made public.
By far, the announcement most significant to our industry is the proposal to impose global warming potential (“GWP”) limits on pressurized duster products. The proposal is to limit the GWP of pressurized dusters to 150 as of Dec 31, 2010, and then to lower it to 10 on Dec 31, 2015.
The GWP of HFC-134a is 1400, and the GWP of HFC-152a is 140. This means that if the proposal goes through, 134a based dusters will be banned in California on Dec 31, 2010, and HFC-152a based dusters will be banned on Dec 31, 2015.
When asked if this proposal is for sure or not, David Mallory of CARB states “I would characterize our proposal as an ‘initial draft proposal.’ We are in the process of working with interested parties to discuss the issues…. It is possible that the proposal would be modified before we present the measure to our Board in June. In addition, the Board could choose to adopt the measure as proposed, approve with changes, or disapprove the measure at the Board Hearing.”
When questioned as to whether or not there will be a three-year sell through period, David states “We did not include sell through language in our initial proposal. With VOC limits we do provide a 3-year sell through, I will have to get back to you on whether we intend to provide the same sell through allowance for the [Green House Gas] limitation. It is a good comment/question.”
These responses make it appear that the ban is likely a done deal, but we may see some modifications and tempering of the proposal before it is made law. If the proposal become law as is, the electronics distribution industry will lose one of its biggest selling products in less then two years.
Initially the bulk of the market will move to HFC-152a dusters. Many customers have already done this for reasons of cost, but others have refused, concerned that HFC-152A is flammable in liquid form. MG Chemicals has been telling customers for years that for protection of the environment, only people who require absolute non-flammability because they work in a dangerous industrial environment should use HFC-134a, and everyone else should be using dusters based on HFC-152a. It looks now like those customers who absolutely require a non-flammable duster will have to switch to CO2.
At present, CO2 dusters (GWP=1) are also the only option for meeting the very strict 2015 limit. CO2 dusters have numerous issues that have prevented their adoption to date. In particular, since CO2 is a gas propellant rather then a liquid, the pressure initially is very strong, and then as the product is used the pressure drops off to nothing. The liquid HFC propellants currently in use provide a constant pressure. As well, the high pressure of a compressed gas means that CO2 dusters cannot be packaged in aerosol cans; they must be packaged in steel cylinders. These are expensive, and of course heavy, so transportation costs can be significant.
CARB points out that the large corporations who produce fluorinated compounds are working hard on a 134a replacement, and they hope these products will be available for use in duster products by the time the strictest limit is imposed.
The large corporations that produce fluorinated propellants are in fact working hard to replace HFC-134a with a non-global warming replacement. They are doing so because Europe has limited the GWP of gasses used in new car air conditioners to 150, effective in 2011, and all car air conditioners effective in 2017. So far the results have not been promising; of the three propellants developed, one has failed because it turned out to be ozone depleting and flammable, the other two failed because of toxicity.
These companies have now developed a new alternative that is awaiting the results of toxicity testing. Hopefully the results are good, but it’s doubtful that a new substance like this would be helpful to the duster market, because duster is price sensitive and new substances are generally very expensive.
Other interesting items from the CARB presentation include a proposed VOC exemption for HFE-7200, new lower VOC limits for glass cleaners (8%), and limits for a variety of new product categories including lubricant and penetrants.
The complete presentation for the March 5, 2008 Public Workshop on Proposed Amendments to the Consumer Products Regulation can be found here.
MG Chemicals Ltd.
March 7, 2008