Fishermen's News - The Advocate for the Commercial Fisherman

By Paul Ivy 

New Refrigerant Regulations and the Phase-Out of R22


Plate freezers can be retro-fit to use ammonia economically, because all the coils and freezer components are typically aluminum. Photo courtesy of Teknotherm.

Between worldwide environmental concern and the potential for punishing fines, it is essential that fishermen and shore plant operators be aware of the ever-increasing restrictions on many popular refrigerants. Many people are faced with the prospect of converting an older system to use an approved refrigerant, or replacing the system entirely. We will look at the origin of these regulations and help you figure out what your best option is.

Current and Upcoming Regulations

First a little background. In 1987 an international environmental agreement called the Montreal Protocol, signed by all UN and EU member nations and few others, required beginning the worldwide phase-out of ozone-depleting CFCs (chlorofluorocarbons). In 1992 it was amended to also phase-out HCFCs (hydrochlorofluorocarbons). HCFCs contain ozone-destroying chlorine but are less damaging to the ozone layer than CFCs. CFCs such as R12 and R502 have long been banned. It is important to note that this treaty will eventually eliminate not only R22, but all HCFCs. In other words, if you are currently running R406A or R409A you will still have to deal with this issue. As you can see from the list below, HCFCs include many different refrigerants, but the most common one for the fishing industry is R22.

A third category of refrigerant, HFCs (hydroflourocarbons) are not addressed by the Montreal Protocol because they do not deplete the ozone layer. They are however considered "greenhouse gases" that contribute to global warming. The popular refrigerants R410A and R507A are in this category. The Kyoto Protocol, which expired in 2012, called for a phase-out of all HFCs. Later this year the Nations Climate Change Conference will negotiate modifying and expanding a new version of this treaty. Although the United States never signed the Kyoto Protocol and Canada withdrew after signing, it is unknown if either country will sign this new treaty. 193 nations signed the Kyoto Protocol.

In the US, the Environmental Protection Agency has also proposed a ban on HFCs. It is probable they will be added to the Montreal Protocol too. In the long run all HCFCs and HFCs will be banned.

Refrigerant Types

HCFC Pure fluids: R22, R123, R124, R141b, R142b

HCFC Blends with HFCs

Blends: R401A, R401B, R401C, R402A, R402B, R403A, R403B, R408A, R411B

HCFC Blends with no HFCs: R406A, R409A, R409B

HFC Pure fluids: R134a, R32, R125

HFC Blends: R404A, R407C, R410A, R413A, R416A, R417A, R422D, R423A, R507, R508, FX100, RS44, RS45, RS52

Other: ammonia (R717), carbon dioxide (R744), and hydrocarbons (R290)

How the Phase-Out Works

The Montreal Protocol specifically lists the type of equipment that is affected, including "domestic and commercial refrigeration and air conditioning/heat pump equipment such as refrigerators, freezers, dehumidifiers, water coolers, ice machines, air conditioning and heat pump units." All developed countries are subject to caps on their consumption and production of HCFCs. These nations must show a certain percentage of progress towards the total phase-out of production and consumption of HCFCs, by certain dates. Here is the exact phase-out schedule, from the EPA's web site:

• 2010- 75.0% reduction.

In addition to the R141b restrictions already in place, no production and no importing of R142b and R22, except for use in equipment manufactured before 1/1/2010.

• 2015- 90.0% reduction.

In addition to the previous restrictions, no production and no importing of any other HCFCs, except for use as refrigerants in equipment manufactured before 1/1/2020

• 2020- 99.5% reduction.

No production and no importing of R142b and R22

• 2030-100.0%.

No production and no importing of any HCFCs

This is directly from the EPA web site: "The Clean Air Act does not allow any refrigerant to be vented into the atmosphere during installation, service, or retirement of equipment. Therefore, R-22 must be recovered and recycled (for reuse in the same system), reclaimed (reprocessed to the same purity standard as new R-22), or destroyed.

CFCs and HCFCs have been proven to damage the ozone layer, and there are strong sanctions in place that come with severe penalties for releasing these chemicals into the environment. Every vessel and shore plant should have a refrigerant recovery unit to capture refrigerants for later re-use. It is not only mandatory that you recover it, but refrigerant is expensive and it makes no sense to let it escape. If your system needs to undergo work that requires removing the refrigerant, most refrigeration companies will remove and store the full bottles for you until the work is complete.

Amazing Ammonia

The most common approved, environmentally safe refrigerant is ammonia. There are some systems that use CO2 or hydrocarbons, but the majority of systems in the marine industry not using HCFCs or HFCs run on ammonia. Since it is a naturally occurring substance, it does not harm the ozone layer or contribute to global warming if accidentally released. For this reason, the chance of it being banned in the future is virtually zero. If you use an ammonia-based refrigeration system you won't have to go through this again years from now.

Ammonia is an excellent refrigerant. Beyond being in compliance with the law and being environmentally sound, ammonia has several other advantages. It is much less expensive than other refrigerants, and the oil used is also less expensive than for systems using HFCs. All other things being equal, ammonia is more efficient than most other refrigerants. That means it will drop the temperature of your product faster.

Its pungent smell makes it immediately obvious if a leak has occurred. It is lighter than air, easily detected, and easily disbursed with ventilation. Ammonia systems are in use all over the world, and above it too: the International Space Station uses ammonia!

Convert or Replace?

Every installation is unique. Each application has different needs, equipment, and goals to achieve. It is only possible to speak in general terms about what is involved in each scenario. To know exactly what is needed you should consult with a reputable refrigeration company- they will come to your site, speak with you, and do a thorough evaluation. That is the only way to know with certainty what solution is best for you.

Each option has its pluses and minuses. A conversion, if possible, costs less but you still have an older system with limited, if any, warranty or tech support. A new system costs more but it has a longer life than the one you removed, as well as the accompanying technical support and warranty.

"Conversion" can be misleading. You cannot simply recover your R22 and put in an HFC such as R404A. The oil has to be changed, along with valves, fittings, and other components. However, HFCs will be prohibited eventually so you should consider if this is a good long-term solution. Another negative of a conversion is that the cooling capacity and efficiency might be reduced. You also can't do this with all systems, and there may be reliability issues. Ammonia cannot be used in an R22 system at all because ammonia corrodes brass and copper. So many components have to be replaced that it doesn't make economic sense to "convert" an RSW system to ammonia.

However, plate freezers can be retro-fit to use ammonia economically. All the coils and freezer components are typically aluminum. The compressors, chillers, condensers, and some of the pipes would need replacing but the freezers themselves could stay.

Removing the old system entirely and installing a new, ammonia-based unit is the other option. This gives you a new warranty, higher efficiency, and more modern controls. Many factors determine the cost of a system, including tonnage, existing electrical system, type of controls, desired product temperature, water temperature, and so on.

What Do I Do Now?

Locate everything on your boat or shore plant that uses HCFCs, including cold storage, ice makers, air conditioners, etc. Make a list of the important information for each system: age, cooling load, history of maintenance (especially how much refrigerant has been used to top it up, since this indicates how sound it is), along with any records you may have. Is the system efficient? Is it cooling adequately or does it struggle to keep up? All this can help you plan your approach.

If your current system is 15 years old or older, you probably want to replace it. Likewise if it doesn't handle your cooling needs. If you are using an HCFC blend then it was probably converted from a long-banned CFC refrigerant, because these blends were designed specifically for CFC replacement. One conversion is enough. Finally, if you want to avoid HFCs by using ammonia, you must do a partial or full replacement.

If you want to change over to an HFC refrigerant you can use a pure HFC fluid such as R134a or an HFC blend for new systems such as R407C. But your best option is probably a HFC "Service blend" that is designed to be used with an existing R22 system. A significant issue is that most R22 units operate with mineral lubricating oil but many HFC refrigerants require polyol ester oil. Because it is so time-consuming to change the oil in an existing system, using a service blend can help minimize this problem.

What Are My Options?

This issue will not go away. It's the law, and the potential fines could kill your profit or even put you out of business.

R22 is very expensive and getting more so every year. Every dollar you spend on refrigerant or maintaining your R22 system is a dollar that could go to converting it or buying a new one. And, as with everything else, the cost of retrofitting or replacing your system will only go up over time.

While R22 equipment cannot run on ammonia, ammonia-based equipment can run R22, so you can replace your components, like this chiller, one at a time.

One thing worth noting: While R22 equipment cannot run on ammonia, ammonia-based equipment CAN run R22. So you can replace your components one at a time using pieces that will work with your current R22 system, and later switch to the less expensive and regulation-compliant ammonia. For example, first replace the chiller. Then next year swap out the compressor, then later do the condenser. When you're done, swap out the refrigerant and oil. This way you break up the expense over several years, but you end up with a new, ammonia-based system.

Talk to a reputable refrigeration company to get a price for modifying or replacing your existing equipment. Whichever method you choose, you will end up with a refrigeration system that will keep your catch cold and make sure you get the best price for your fish at the market. Isn't that what it's all about?

Paul Ivy is the Sales and Marketing Manager at Teknotherm Refrigeration. He can be reached at

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