Most Equipment with A2L Refrigerants can be Transported with Current Methods

Last week the Department of Transportation sent a letter of interpretation to the industry confirming manufacturers, distributors, and contractors can transport AC and refrigeration equipment over ground containing up to 25 pounds or 12 kg or A2L and A3 refrigerants without the need for HAZMAT protocols. This confirmation means most equipment using A2L refrigerants sold by distributors can be transported in the same manner as current equipment using A1 refrigerants. A2L refrigerants have a lower flammability rating and are non-toxic, A3 refrigerants have a higher flammability rating and include refrigerants such as propane.

The Code of Federal Regulations offers exemptions to the Hazardous Materials Regulations for the transport of “refrigerating machines” which includes air-conditioners, refrigeration equipment, and component parts. Under this exemption any piece of equipment can be transported (except by air) with up to 12kg or 25 pounds of flammable, non-toxic gas. Additionally, the regulations do not limit the number of units with A2L refrigerant that can be shipped together.

HARDI and the rest of the HVACR industry continue to work through the Safe Refrigerant Transition Task Force to ensure a smooth changeover to the use of A2L refrigerants in the coming years. For a timeline of changes to new refrigerants including A2L refrigerants, see the recent blog post on petitions submitted to the Environmental Protection Agency.

See the letter from DOT here.

If you have any questions please reach out to Alex Ayers (aayers@hardinet.org). HARDI will continue to monitor these programs as regulations are released and will update you on relevant information.