EPA Takes Final Action on Ozone Depleting Substances

The EPA has taken final action to determine that HCFC-22 and HCFC-142b are unacceptable for use in the foam sector under the Signification New Alternatives Policy (SNAP) program under Section 612 of the Clean Air Act (CAA). This action thus regulates the use of HCFC-22 and HCFC-142b as foam-blowing agents used in the manufacture of rigid polyurethane/polyisocyanurate and extruded polystyrene foam products.

The SNAP program reviews alternatives to Class I and Class II ozone depleting substances and approves use of alternatives which do not present a substantially greater risk to public health and the environment than the substance they replace or than other available substitutes.

  • EPA is finding HCFC-22 and HCFC-142b unacceptable as substitutes for HCFC-141b in commercial refrigeration, sandwich panels, and slab stock and "other" rigid polyurethane foams, and removing narrowed use limits previously established in those applications.


  • EPA is finding HCFC-22 and HCFC-142b unacceptable as substitutes for CFCs in all foam end-uses.


  • The Agency is establishing a grandfathering period to allow existing users of HCFC-22 and HCFC-142b in pour foam applications, including commercial refrigeration, sandwich panels, and slab stock and "other" rigid polyurethane foams other than foam for marine applications will be allowed to continue use of these blowing agents until September 1, 2009.


  • The Agency is grandfathering existing users of HCFC-22 and HCFC-142b in extruded polystyrene (XPS) foam and in all other foam end uses until January 1, 2010 in order to allow time for those users to complete their transition to alternatives.


Businesses that currently might be using HCFC-22 and HCFC-142b, or might want to use it in the future, include:

  • Businesses that manufacture polyurethane/polyisocyanurate foam systems;

  • Businesses that use polyurethane/polyisocyanurate systems to apply insulation to buildings, roofs, pipes;

  • Businesses that manufacture extruded polystyrene foam insulation for buildings, roofs, pipes (NAICS 326140 and 326150).

A major goal of the SNAP program is to facilitate the transition away for ozone depleting substances (ODS) to alternatives that pose less risk to human health and the environment.

In 1994, EPA listed several HCFCs as acceptable replacements for CFCs* because the Agency believed that HCFCs provided a temporary bridge to alternatives that do not deplete stratospheric ozone. At that time, EPA believed that HCFCs were necessary transitional alternatives to CFC blowing agents in thermal insulating foam.

As a result, HCFC-141b, HCFC-22 and HCFC-142b became common foam blowing agents in place of CFCs. Pursuant to the CAA and the Montreal Protocol on Substances that Deplete the Ozone Layer, HCFC-141b was phased out of production and import in the United States on January 1, 2003, and HCFC-22 and HCFC-142b are scheduled to be phased out of production and import on January 1, 2010**. Since the time EPA initially listed HCFC-22 and HCFC-142b as acceptable in certain foam blowing uses, the Agency has listed several other non-ODS alternative blowing agents, including hydrofluorocarbons (HFCs), hydrocarbons, carbon dioxide, and other compounds, as acceptable substitutes in foam blowing.


HRP Associates, Inc. offers the resources and engineering expertise to help you make the changes to your foam blowing agents. We have extensive experience in permitting cyclopentane and blends in North American facilities. Contact Tad Goetcheus, P.E. at 800-752-3922 or email.




*Historically, CFC-11, CFC-12, CFC-113 and CFC-114 have all been used as blowing agents in the foam industry, with CFC-11 in polyurethane applications and CFC-12 in extruded polystyrene board stock applications being the two most popular CFC blowing agents (March 18, 1994, 59 FR 13082).

**The phase-out schedule was established on December 10, 1993.




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