Environmental Permitting

EPA’s SNAP Program – How It Works

Finding alternatives to harmful chemicals and processes is key to protecting our atmosphere and the safety of workers and the public, but getting it done takes a concerted effort on the part of government and the regulated community. One program that is proving successful is the EPA’s SNAP Program required under 612 of the CAA as a clearinghouse for alternatives to ODS.  Under SNAP, the EPA assesses whether an ODS substitute is acceptable or unacceptable based on risks to human health and the environment. Alternatives deemed acceptable are then listed and published.

A proposed ODS alternative substitute does not have to be found totally risk free to be deemed acceptable, rather it must reduce risk when compared to Class I or Class II substances or other substitutes. The EPA uses this comparative-risk framework to assess a broad range of factors including ozone depletion potential and contributions to global warming, flammability, toxicity, and worker health and safety. Also considered in the equation are risks associated with quality of information, uncertainty of data, and economic factors such as feasibility and availability.

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Using these risk parameters, the EPA evaluates each alternative substitute by use, as required in Section 612. Recognizing that health and environmental impacts can vary considerably by application, the EPA characterizes risk of an alternative based on potential diverse end uses. In addition, when an alternative substitute is covered under other environmental regulations, these regulations are also considered in the decision making. Overall, the EPA restricts only those substitutes that are significantly worse, and does not intend to restrict a substitute that has “only marginally greater risk than another substitute.”

Here is how the EPA classifies ODS alternative substitutes:

Acceptable – alternative reduces overall risk to human health and the environment and may be used without restrictions in end uses.
Acceptable subject to use conditions – alternative may only be used in a certain way, such as with unique equipment fittings.
Acceptable subject to narrowed use limits – alternative may be used only within certain specialized applications within a sector end-use, and may not be used for other applications within an end use or sector.
Unacceptable – alternative is prohibited because it was found to pose significantly higher risk to human health or the environment compared to the use of Class I or Class II substitutes or other available substitutes.
Pending – alternative for which EPA has extended the review period to 90 days.

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When a proposed ODS alternative is found to be unacceptable or acceptable subject to restrictions, the EPA goes through a comment period and then ultimately publishes them in the Federal Register. For example, on June 26, 2014, the EPA published the “Proposed Rule – Protection of Stratospheric Ozone: Listing of Substitutes for Refrigeration and Air Conditioning and Revision of the Venting Prohibition for Certain Refrigerant Substitutes” containing several new substitutes as “acceptable, subject to use conditions, in new equipment in six end-uses.” Those ODS substitutes classified as acceptable or pending are published in a Notice of Acceptability.

Under CAA Section 612(e), producers of ODS alternatives must notify the EPA at least 90 days in advance of selling the product (except companies manufacturing outside the United States and for use outside the United States). Those seeking consideration of a substitute by the EPA may petition the Agency. In both cases, the forms and instructions are available online at http://www.epa.gov/ozone/snap/submit/index.html.