ATS Submits Comments to EPA on HFC Phase Down Rule
This week, the ATS submitted comments on EPA’s proposed rule to phase down the use of hydrofluorocarbons (HFCs and HFAs) from the U.S. market.  HFCs/HFAs are power greenhouse gases with global warming potential that is hundreds to thousands of times more powerful than CO2.  When fully implemented in 2036, the rule is expected to reduce the U.S. production and importation of HFC/HFA use by 85 percent from current levels.

In addition to its industrial use, HFAs are commonly used propellants for respiratory medications, including metered dose inhalers.

EPA’s action was required by the bipartisan American Innovation and Manufacturing Act of 2020 which directed the agency to issue a proposed rule on HFC/HFA reduction in May of 2021 with a final rule issued by September of 2021.  The underlying legislation explicitly created a protected carve-out for MDI use of HFCs/HFAs, effectively preserving the use of these propellants for MDIs for the foreseeable future. 

The ATS comments supported the EPA’s proposal to phase down emissions of HFCs/HFAs, noted the essential role that MDIs play in the treatment of a wide range of respiratory conditions, supported the carve-out for MDI propellants, urged EPA to consider policy that would encourage switching to MDI propellants with lower global warming impact, and commented on various implementation steps proposed by the EPA.