Understanding the Danger of PFAS and Why Refrigerants Should be Exempt from Prohibitions

HARDI is monitoring several states working on legislation to add regulations and prohibitions to products containing per- and polyfluoroalkyl substances (PFAS). PFAS are man-made chemicals that have been widely used in products since the 1940s and remain in the environment for a long time. While it is difficult to show that substances directly cause health conditions in humans, scientific studies have shown that exposure to some PFAS in the environment may be linked to harmful health effects in humans and animals. HARDI believes that the HVACR industry is not a danger to human health factors, like other PFAS products, and should be exempt from any PFAS legislation.

According to a systematic review of chemicals by NIH, the three factors that create a danger are "[p]ersistent, bioaccumulative, and toxic substances … that can subsist for decades in human tissues and the environment." [i]

Persistent. Many PFAS are rightly called “forever chemicals” because of their persistence in the environment for “thousands of years.”[ii] Typically, these dangerous PFAS either stay in the soil or become mobile, moving to water where they can enter streams, rivers, aquifers, and lakes. On the other hand, refrigerant HFCs are gases at ambient temperature; because of this, HFCs cannot be absorbed into the soil and are not water-soluble. Additionally, HFCs have a shorter life span than other PFAS, breaking down in the atmosphere after an average of 15 years.[iii] With such a short lifespan in the atmosphere, HFC refrigerants are not considered to be persistent compared to other PFAS.

Bioaccumulative. “Humans, as the final link in numerous food chains, are subjected to PFAS uptake primarily through food and drinking water.”[iv] As mentioned, PFAS often enter streams, rivers, and lakes, where fish and other animals ingest them. Additionally, plants can absorb PFAS from contaminated soil or irrigation water.[v] The ability of dangerous PFAS to be absorbed in human tissue and remain there for the rest of a person’s life is a concern. However, toxicology reviews have found that R-32 and R-125 are not considered bioaccumulative.[vi] R-32 and R-125 are the two components used to create R-410A, the most common refrigerant gas primarily used in air conditioners and heat pumps. In addition, as a gas, the ability of HFC refrigerants to enter the food chain is nearly impossible without first degrading from its original molecule. HARDI has found no safety data sheets showing an HFC refrigerant listed as bioaccumulative.

Toxic Substances. The American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) classifies all refrigerants as “higher toxicity” or “lower toxicity.”[vii] Common HFC refrigerants and blends like R-410A are classified as lower toxicity. Refrigerants are designed to stay in the closed loop of an air conditioner, heat pump, or refrigerating machine; only when leaked out of the machine in an enclosed space, does toxicity become a concern. CO2 creates dangerous conditions at concentrations as low as 5,000 ppm;[viii] R-32, on the other hand, required 350,000 ppm before adverse effects were observed.[ix] In addition, some HFCs used as refrigerants, like R-134a, are also used as propellants in metered-dose inhalers because of their short serum half-life of between 4-11 minutes; this is considered a low human toxicity risk.[x] HFC refrigerants have low human toxicity and have lower toxicity compared to some non-HFC refrigerants.

According to REACH, the European Union regulation for protecting human health, HFC refrigerants do not meet the persistent, bioaccumulative, or toxicity factors necessary to make them dangerous PFAS.[xi]

HARDI understands that no refrigerant is 100 percent safe; however, HFC refrigerants pose a physical and environmental hazard rather than a health hazard. Because of this physical and environmental hazard, HFCs are already highly regulated. The HVACR industry has worked with the international community to move to environmentally safer refrigerants. However, advocates falsely claim health hazards that do not exist to circumvent these industry agreements. HARDI has fully supported the phase-down of HFC refrigerants and is actively working with the EPA to reduce emissions of these refrigerants into the atmosphere.

Thus, states with PFAS legislation, such as Maine, Illinois, Colorado, and others, should exempt the HVACR industry from any additional regulations and prohibitions.

[i] Fernández-Martínez, N. F., Ching-López, A., Olry de Labry Lima, A., Salamanca-Fernández, E., Pérez-Gómez, B., Jiménez-Moleón, J. J., Sánchez, M. J., & Rodríguez-Barranco, M. (2020). Relationship between exposure to mixtures of persistent, bioaccumulative, and toxic chemicals and cancer risk: A systematic review. Environmental research, 188, 109787. https://doi.org/10.1016/j.envres.2020.109787 [ii] Washington Department of Ecology, Per- and polyfluoroalkyl substances (PFAS), https://ecology.wa.gov/waste-toxics/reducing-toxic-chemicals/addressing-priority-toxic-chemicals/pfas [iii] Climate & Clean Air Coalition, Hydrofluorocarbons (HFCs), https://www.ccacoalition.org/short-lived-climate-pollutants/hydrofluorocarbons-hfcs [iv] Brunn, H., Arnold, G., Körner, W. et al. Correction: PFAS: forever chemicals—persistent, bioaccumulative and mobile. Reviewing the status and the need for their phase out and remediation of contaminated sites. Environ Sci Eur 35, 30 (2023). https://doi.org/10.1186/s12302-023-00730-7 [v] Ghisi, R., Vamerali, T., & Manzetti, S. (2019). Accumulation of perfluorinated alkyl substances (PFAS) in agricultural plants: A review. Environmental research, 169, 326–341. https://doi.org/10.1016/j.envres.2018.10.023 [vi] George M. Rusch (2018) The development of environmentally acceptable fluorocarbons, Critical Reviews in Toxicology, 48:8, 615-665, DOI: 10.1080/10408444.2018.1504276 [vii] ASHRAE, Update on New Refrigerants Designations and Safety Classification, https://www.ashrae.org/file%20library/technical%20resources/bookstore/factsheet_ashrae_english_november2022.pdf [viii] Occupational Safety and Health Administration, OSHA Hazard Information BulletinsPotential Carbon Dioxide (CO2) Asphyxiation Hazard When Filling Stationary Low Pressure CO2 Supply Systems, https://www.osha.gov/publications/hib19960605[ix] Safety Data Sheet – R-32, Chemours, https://hdsupplysolutions.com/wcsstore/ExtendedSitesCatalogAssetStore/product/fm/additional/15/150110_MSDS-PDF.pdf [x] Ritchie, G. D., Kimmel, E. C., Bowen, L. E., Reboulet, J. E., & Rossi, J., 3rd (2001). Acute neurobehavioral effects in rats from exposure to HFC 134a or CFC 12. Neurotoxicology, 22(2), 233–248. https://doi.org/10.1016/s0161-813x(01)00011-0 [xi] REACH Online, Annex XIII: Criteria for The Identification of Persistent, Bioaccumulative and Toxic Substances, and Very Persistent and Very Bioaccumulative Substances, https://reachonline.eu/reach/en/annex-xiii.html