HCFC 225 - Ban or Phaseout?

You may have heard that HCFC (hydrochlorofluorocarbon) 225, a popular solvent for many industries involved with critical cleaning, is going away in 2015 per the U.S. Clean Air Act. But what does “gone” mean? It is important to explore the details.

 

Successful industrial cleaning requires process flexibility. This is because desirable performance attributes must be balanced with the current and anticipated regulations in environmental protection and worker safety. Cleaning protocols often require a substantial monetary and intellectual investment. With all of the pending regulations and discussions of regulations, it is important to understand exactly how you will be impacted and then make informed, proactive decisions. HCFC 225 is a good example.

 

HCFC 225 has significant use in industrial cleaning because of performance, environmental and worker exposure attributes. On its own, it has low to moderate solvency; it can be blended with other organic solvents, including trans-1,2-dichloroethylene (trans) to increase solvency. While there are many pluses in terms of its environmental attributes (it is VOC exempt) and its worker exposure profile, because HCFC depletes the stratospheric ozone layer, it is scheduled for global phase-out through the Montreal Protocol.

 

In the United States, the Federal Clean Air Act calls for a use, sale and production ban as of Jan. 1, 2015. This might give pause to those using HCFC 225, particularly in the precision cleaning or critical cleaning of high-value product. While users should be proactively looking at alternative processes, the door does not abruptly shut.

 

Take the meaning of “use” by the regulatory community. Margaret Sheppard of the U.S. EPA’s Stratospheric Protection Division explains that the EPA has interpreted the use ban to mean a ban on “use for manufacturing products.”

Sheppard explains that a solvent manufacturer or aerosol packager would no longer be able to use virgin material after Dec. 31, 2014, to produce, for example, cleaning products. For more detailed information about EPA’s interpretation of the regulations regarding HCFCs, peruse the 38-page document (Federal Register Doc. E9–29569, 74 FR 66412, Dec. 15, 2009).

 

The important point for those doing hard-surface cleaning as part of manufacturing or repair is that end users could continue to use existing stocks of HCFC 225 that they have already purchased. Furthermore, use of recycled HCFC 225 material is also allowed, either for end use or for use in manufacturing of cleaning agents. This clarification should allow manufacturers to make informed, reasonable decisions about using HCFC 225 in current and impending projects. It also allows time to plan cleaning process changes. 

 

What is next for AGC Chemicals, the producer of HCFC 225? “We are committed to supporting industry in the United States,” says David Ferguson, business manager at AGC Chemicals Americas, Exton, Penn. “We have developed new HFCs and HFEs that show promise in some applications. We have to wait for answers from the EPA before we can market them in the United States.” In terms of future cleaning chemistries, Ferguson notes that “in Japan, we have a fairly large, active R&D campus—one with foundations in fluorinated chemistry. Even though the solvent market is not as large as it used to be, if we come up with something of value to the manufacturing community, we will explore it.”

 

One might note that HCFC 225 was developed as an interim replacement for ozone-depleting chemicals, and that the “interim” began approximately 20 years ago. Ferguson points out that in evaluating any cleaning solvent “over the last 20 or 30 years, ‘magic fluids’ have been marketed as a total panacea.” One might predict that a panacea is unlikely and that changes impelled by regulations are inevitable.