Does the venting prohibition apply to HFC substitute refrigerants such as R-410A and R-134a?

Clean Air Act and Montreal Protocol · EPA 608 Core. The correct answer, and the reasoning behind it.

Phaseout dates and the venting prohibitions at servicing, at disposal and for substitutes.

The question

Does the venting prohibition apply to HFC substitute refrigerants such as R-410A and R-134a?

• ANo, it covers only CFCs and HCFCs
• BOnly for equipment built after 2018
• COnly when the system holds more than 50 pounds
• DYes, non-exempt substitutes are covered tooCorrect answer

Why “Yes, non-exempt substitutes are covered too” is correct

The prohibition in 40 CFR 82.154(a) applies to any refrigerant in an appliance, including substitutes. Only the specific substitutes and end-uses listed as exempt, such as carbon dioxide, nitrogen and water, may be released.

Source: 40 CFR 82.154(a)

Why the other answers are wrong

• No, it covers only CFCs and HCFCs — Substitutes such as HFCs are covered unless specifically exempted.
• Only for equipment built after 2018 — The prohibition does not depend on the date the equipment was made.
• Only when the system holds more than 50 pounds — There is no charge-size limit on the venting prohibition.

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