- HFOs have obvious benefits to climate, and sustainability goals. Use of HFOs and HFO-HFC blends have helped avoid the potential release of hundreds of millions of metric tons of CO2e from the atmosphere since their commercialization in the early 2010’s.
- HFOs and HFCs have been heavily studied and are rigorously regulated, under the U.S. Clean Air Act, other U.S. Environmental Protection Agency (EPA) programs including TSCA and FIFRA, and California CARB.
- To date, more than 75 third party studies, including Good Laboratory Practice-compliant OECD in vitro, acute, and chronic toxicology reports, and environmental properties research that evaluates persistence and global warming potential, have been conducted on HFOs and HFCs to ensure they are non-PBT (non-persistent, non-bioaccumulate, and non-toxic) and safe for human and environmental health.
- These oversight agencies rely upon the best, most accurate testing methods available, and have consistently listed HFOs and HFCs as acceptable and safe alternatives to other less climate-friendly substances. Accordingly, these substances should be fully excluded from the scope of the criteria set out in Section 64 of the Canadian Environmental Protection Act (CEPA).
- HFCs and HFOs ultimately degrade in the atmosphere to basic chemical building blocks, such as carbon dioxide (CO2), fluoride salts. For some HFOs and HFCs, trifluoroacetic acid (TFA) is a degradation product, which the EPA in its National PFAS Testing Strategy concluded is a “well studied non-PFAS”. Furthermore, a recent study concluded that current and projected TFA concentrations “are well below the threshold for concern with respect to human and environmental health.”
- Moreover, Canada has an existing Refrigeration Management Program to mitigate emission of refrigerants to the environment. This program ensures collection of refrigerants from closed systems are re-used or destroyed.
- We recommend exemption of hydrofluoroolefins (HFOs) and HFO – hydrofluorocarbon (HFC) blends which are innovative and energy efficient materials that enable a rapid, cost effective and responsible transition away from, higher GWP HFCs, responsible for significant global warming.