All year I have received dozens of phone calls and e-mails from friends and colleagues in the automotive industry regarding this new refrigerant for A/C units inside 2016 model vehicles. Over the next couple of months, I will be posting a series of articles about this new refrigerant and the impact it is having on the automotive industry. This first article is to clearly establish this material is a CATEGORY 1 FLAMMABLE GAS and any facility that has over 10,000 pounds in their “process” has a PSM Covered Process (HFO is NOT a listed RMP EHS). There has been much confusion over this new refrigerant and its classification. The makers of this refrigerant have been marketing their product as “mildly flammable” and this has caught a lot of safety departments off guard when the material actually arrives on site. But here are the facts…
Using the Safety Data Sheet from one of the primary manufacturers of this refrigerant we see the following: (CLICK HERE for the SDS)
- SDS states this material is EXTREMELY FLAMMABLE (an SDS defined term) and even classifies this refrigerant as a “Category 1 Flammable Gas” (page 1 of 15)
- SDS states the Lower Explosive Limit (LEL) of this material is 6.2% (page 7 of 15)
- SDS states the Boiling Point of the material is -20.9ºF (page 7 of 15)
So what do these three (3) facts mean?
OSHA defines a “Flammable Gas” in this manner: (Source: 1910.1200 App B – Physical Criteria (Mandatory)
B.2 FLAMMABLE GASES
B.2.1 Definition
Flammable gas means a gas having a flammable range with air at 20°C (68°F) and a standard pressure of 101.3 kPa (14.7 psi).
B.2.2 Classification criteria
A flammable gas shall be classified in one of the two categories for this class in accordance with Table B.2.1:
| Category | Criteria |
| 1 | Gases, which at 20°C (68°F) and a standard pressure of 101.3 kPa (14.7 psi): (a) are ignitable when in a mixture of 13% or less by volume of air; or (b) have a flammable range with air of at least 12 percentage points regardless of the lower flammable limit. |
| 2 | Gases, other than those of Category 1, which, at 20°C (68°F) and a standard pressure of 101.3 kPa (14.7 psi), have a flammable range while mixed in air. |
So as we can see, based on the SDS from the manufacturer (and supplier as well) and OSHA’s Hazardous Communications Std with App B this refrigerant is a Category 1 Flammable Gas.
We now look to 29 CFR 1910.119 for the applicability of the PSM standard to this refrigerant.
1910.119(a) Application.
1910.119(a)(1) This section applies to the following:
1910.119(a)(1)(i) A process which involves a chemical at or above the specified threshold quantities listed in Appendix A to this section;
1910.119(a)(1)(ii) A process which involves a Category 1 flammable gas (as defined in 1910.1200(c)) or a flammable liquid with a flashpoint below 100°F (37.8 °C) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more except for:
1910.119(a)(1)(ii)(A) Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard;
1910.119(a)(1)(ii)(B) Flammable liquids with a flashpoint below 100°F (37.8 °C) stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.
So as safety professionals we need to stick to the facts and NOT some “marketing literature” that has found its way into some risk assessments and uses terms like “mildly flammable”. We have to see through the political hype around the refrigerant and use the SDS data as our source and not a glossy marketing pamphlet regarding this material. Global warming be damned… our vehicles will have around 1 pound of this refrigerant so the risk is NOTHING compared to having tens of thousands of pounds of this material on site! It is deserving of being a PSM Highly Hazardous Chemical.