HARDI Urges Washington Leaders to Reject A3 Refrigerant Code Exception

HARDI has joined the Washington Air Conditioning Contractors Association (WA ACCA), Air-Conditioning, Heating, and Refrigeration Institute (AHRI), the Plumbing-Heating-Cooling Contractors - National Association (PHCC), and the Plumbing-Heating-Cooling Contractors Association of Washington (PHCC WA) in calling on Washington state leaders to reject a proposed mechanical code change that could create new safety and compliance uncertainty for HVACR distributors and contractors.

In a letter to Governor Bob Ferguson and the Washington State Legislature, the associations urged state leaders to prevent CR-102 Proposal 24-GP1-113 from taking effect in the 2024 Washington State Mechanical Code. The proposal would create an exception allowing equipment using highly flammable A3 refrigerants in applications not currently supported by the established U.S. safety framework. The Washington State Building Code Council is targeting October 16 for final adoption of the proposed changes.

How Would CR-102 Proposal 24-GP1-113 Impact HVACR Distributors?

The exception proposed in Washington would rely on international standards that do not fully align with the existing U.S. framework.

For distributors, this could create uncertainty about which products can be legally sold and installed, complicate inventory and product selection decisions, and create additional questions from contractor customers about code compliance. Contractors and code officials would face similar challenges when determining which equipment is approved and how installations should be evaluated.

Supporting a Safe and Orderly Refrigerant Transition

HARDI and industry partners assert that new technologies must be supported by appropriate safety standards, product approvals, and installation requirements before being introduced more broadly.

Washington has already established a Refrigerant Transition Task Force to evaluate the opportunities and challenges associated with low- and ultra-low-GWP refrigerants. HARDI and AHRI representatives currently serve as voting members on the task force. Its work includes examining product availability, workforce training, safety considerations, and implementation timelines.

The associations are asking state leaders to allow that process to move forward rather than creating a new exception before the necessary standards and guidance are in place.

Giving Distributors a Voice in State Policy

By working alongside manufacturers and local contractor organizations, HARDI is bringing the concerns of the full HVACR supply chain directly to Washington policymakers.

HARDI will continue monitoring the proposed code changes and advocating for a regulatory framework that supports safety, consistency, and a practical transition to new refrigerant technologies.

Read the full coalition letter to Washington state leaders.

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