Re: Enviro-Safe
LarryK 87 said:
1. Per EPA SNAP rules no approval is required. So approved / disapproved does not apply
Where did you see this? The EPA site does state that the EPA does not test the refergrents, it reviews material from the company and independent labs. They do say that "does not approve or endorse any one refrigerant that is acceptable subject to use conditions over others also in that category." but that just means that the EPA does not approve/endorse one refrigerant over another.
6. If dis-approved then it would NOT be on the market
There are lots of refergrents on the market that are not approved for use in motor vehicles. These refergrents are used in applications such as cooling meat lockers, railroad cars. They "can" be installed in cars but they are not approved for cars.
Also found this on the EPA site:
The Clean Air Act only granted EPA the authority to regulate the use of alternative refrigerants, not the sale of them. Even if EPA determines that an alternative is unacceptable, it is still legal to sell it. It goes on to say that if a technician puts it into a customers car, that would be considered "use" and the tech would then be subject to fines and/or jail time. (
http://www.epa.gov/spdpublc/snap/refrigerants/buying.html#q9 )
My concern was the Envrio-safe site did appear to skirt the issue of EPA approved. But then we all know how easy the EPA is to deal with. My only concern with that was, is it legal...
If Enviro-safe is HC12a as referenced above, it is
not legal for use in motor vehicles. The EPA uses four leves or status for replacement refergrents. They are:
"acceptable subject to use conditions: May be used in any car or truck air conditioning system, provided the technician meets the conditions described above. Note that EPA cannot guarantee that any refrigerant will work in a specific system.
unacceptable: Illegal to use as a substitute for CFC-12 in motor vehicle air conditioners.
proposed acceptable subject to use conditions: May be used legally. EPA will accept public comment on these refrigerants and then make a final ruling. There is no formal EPA position until then, and it is inappropriate for advertising to imply that EPA has found the product acceptable.
not submitted: Illegal to use or sell as a substitute for CFC-12 in motor vehicle air conditioning systems. "
Per the EPA chart at
http://www.epa.gov/spdpublc/snap/refrigerants/macssubs.html HC-12a is in the unacceptable status.
But if Enviro-Safe is not HC-12a, then all bets are off. Enviro-safe refers to it as ES-12. There is no listing for ES-12. Assume that ES stands for
Enviro
Safe. Appears to be their logo for the product.
Again, I am not trying to be ornery, I too would like to find a good replacement for R12, but I want one that is in the EPA
acceptable grouping.
If anyone knows for sure Enviro-Safe's product ES-12 is not HC-12a, could you please post its correct designation.
I have e-mailed the EPA for additional info on the product. Will post response when received.
tom...