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Compliance RequirementsHealthcare facilities are required to prevent further damage to the earth’s protective stratospheric ozone layer by preventing releases of ODSs from their HVAC systems. These releases can occur during normal operation if the system is not properly checked and maintained. They can also occur during servicing. Normal operationThe best way to ensure that an HVAC system minimizes its releases of ODSs during normal operation is to use refrigerants that have an inherently low ozone depleting potential. The production of CFCs was phased out by 1996. But CFCs continue to be used in pre-existing systems. Some facilities have replaced the CFCs in their systems with a compromise alternative refrigerant type, called hydrochlorofluorocarbons (HCFCs). They are less stable than CFCs, and are more likely to break down before they reach the stratosphere, and are thus weaker as ODSs than CFCs. But they still damage the ozone layer. The production of HCFCs is being gradually phased out over the next several years. Please note that HCFCs, like all refrigerants, can be toxic if exposure levels exceed recommended practices. For all chemicals, users should follow the precautions set forth in Material Safety Data Sheets provided by the chemical manufacturer, as well as other safety practices and standards such as ASHRAE Standard 15 (this standard is available for purchase from ASHRAE). Alternatives that are both CFC- and HCFC-free are now available. To ensure future compliance, a facility should either verify that all refrigeration and air conditioning equipment already runs on CFC free and HCFC free gas, or should begin the conversion process now. ServicingServicing should be performed by certified technicians only. Facilities may want to verify that HVAC contractors employ technicians certified by NATE (North American Technician Excellence), the leading industry-supported testing and certification program. EPA provides an information page on technical certification programs. The following professional organizations may be able to provide additional information:
Regulations require that HCFCs and CFCs in discarded equipment are properly captured to avoid release into the environment. (This also applies to alternative fluids such as HFCs.) EPA provides an information page listing EPA-certified refrigerant reclaimers. Pollution prevention opportunitiesHVAC units should be converted to use alternative refrigerants that are both CFC- and HCFC-free. HVAC units should be properly sized, and should be selected for high efficiency. More information is available from the Energy Star healthcare index page. Refrigerant Recycling RuleThe purpose of section 608 of the Clean Air Act (CAA) is to minimize the quantity of refrigerants released to the atmosphere, and to maximize the recovery and recycling of refrigerants during the servicing and disposal of stationary air conditioning and refrigeration equipment. Requirements include technician certification, mandatory use of recovery and recycling equipment, and service practices that minimize refrigerant emissions. prohibition of venting, service requirements, equipment certification, leak repair, proper disposal, and recordkeeping. More information can be found at http://www.epa.gov/ozone/title6/608. Cooling towersCooling towers, which can be part of cooling and refrigeration systems, must not use hexavalent chromium water treatment chemicals. The use of hexavalent chromium in comfort cooling towers was banned under a 1990 rule under the Toxic Substances Control Act. More resourcesThe Stratospheric Ozone Information Hotline, at 800-296-1996, or the Ozone Depletion web site (www.epa.gov/ozone), provides general information about regulations promulgated under Title VI of the CAA. The EPA IAQ Building Education and Assessment tool (I-BEAM) contains comprehensive state-of-the-art guidance for managing indoor air quality in commercial buildings. The Energy Star healthcare index page provides links to energy conservation information selected for relevance to the healthcare sector. EPA provides an information page with links for businesses that use ozone depleting substances. |
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