EPA’s SNAP Program Provides Solvent Substitute Evaluations

The Environmental Protection Agency’s (EPA’s) SNAP program serves several industries by identifying and publishing lists of both acceptable and unacceptable substitutes for the ozone depleting substances listed in the CAA as follows:

Class I substances: one of several groups of chemicals with an ozone depletion potential (ODP)* of 0.2 or higher including clorofluorocarbons (CFCs), hydrobromofluorocarbons (HBFCs), halons, carbon tetrachloride, methyl chloroform, and methyl bromide , and

Class II substances: chemicals with an ODP of less than 0.2 , which includes all hydroclorofluorocarbons (HCFCs).

The SNAP program evaluates proposed new chemical alternatives to make sure they do not do more damage to the environment or human health than the chemicals they are intended to replace or other already identified alternatives. The EPA assesses each new substitute for:

  1. Ozone-depleting potential
  2. Global-warming potential
  3. Toxicity, and
  4. Flammability.

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The results are then used to determine if the substitute should be allowed unrestricted use, if limits should be place on use of the substitute, or if use should be prohibited. The decision making also is done within a framework that considers the particular end use within a larger sector, such as whether a single substitute for a CFC is acceptable for new residential refrigerators. As a result, potential substitutes reviewed by the SNAP program are listed in one of four categories (noting that all SNAP determinations apply to the use of a specific product as a substitute for a specific ozone-depleting substance (ODS) in a specific end use) as follows:

  1. Acceptable – may be used without restriction
  2. Acceptable subject to narrowed use limits – is unacceptable unless use is restricted to specific applications within an end use,
  3. Acceptable subject to use conditions – is unacceptable except for use under certain conditions which must be fully met to be legal, or
  4. Unacceptable – it is illegal to use as a substitute for an ODS in specific end use.

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Because different substitutes may only be appropriate or allowed in specific uses, they are listed by end use within a particular industry sector and may have additional application requirements. Within the Cleaning solvents industry sector, the EPA reviews and identifies substitutes for three cleaning solvent end uses:

Metal Cleaning – defined as removing contaminants such as cutting oils, grease or metal filings from metal parts,

Electronics Cleaning – defined as removing contaminants, primarily solder flux residues, from electronics or circuit boards, and

Precision Cleaning – defined as cleaning to a specific grade of cleanliness meant to enable products to retain their value.

This sector refers to substitutes for non-aerosol solvents used in industrial cleaning in vapor degreasing, cold-batch cleaning or automated cleaning equipment but does not include dry cleaning, manual cleaning with non-aerosol solvents, non-aerosol mold release agents, or component testing agents.

*The ODP is the ratio of the impact on ozone of a chemical compared to the impact of a similar mass of CFC-11. The ODP of CFC-11 is defined as 1.0.