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Tom73
07-31-02, 10:29 PM
A while back there was discussion about using Envirosafe ES12 as a subistitute for R12. Discussion was fairly heated over if Envirosafe ES12 was an approved refregrent. That thead is here: http://corvetteactioncenter.com/forums/showthread.php?s=&threadid=14042

To get to the facts I sent an e-mail to the EPA asking. Just received the response. Here is what it said:

Under U.S. law, only those substitutes approved by EPA may legally be used to replace ODSs {ozone-depleting
substances} , such as CFC-12 ("freon") in automobiles and other applications that farmers have used ODSs in the past.

Envirosafe ES-12 has never been submitted to the EPA for review, and therefore it is illegal to use this chemical as a substitute for any ODS, such as CFC-12 in automobiles. For a list of those substitutes that have been approved, please refer to http://www.epa.gov/ozone/snap/lists/index.html. Although I do not have specific information on ES-12, others have indicated that it is a mixture of flammable hydrocarbon substances. As you may be aware, the EPA has specifically found all flammable refrigerants unacceptable as substitutes for CFC-12 in automobiles.

Eagle85C4
07-31-02, 11:01 PM
Does ENVIRO-SAFE have EPA approval?

ENVIRO-SAFE is a zero ozone depleting "second generation" replacement for R-134a and all other substitutes for Freon that are non-ozone depleting. Unlike R134a, it is also non-global-warming . EPA's Final Rule, issued April 1, 1994, states:

"In this final rule, the Agency has determined that second generation replacements, if they are non-ozone depleting and are replacing non-ozone depleting first generation alternatives, are exempt from reporting requirements under Section 612"

If an automotive system is "first generation" (has 134a fittings and contains no Freon ) it may accept a "second generation" refrigerant like ENVIRO-SAFE.

Tom73
07-31-02, 11:51 PM
Eagle85C4,
I did some further reading and I must say that what you said above is correct. Here is the link: http://www.epa.gov/Ozone/snap/refrigerants/hc12alng.html#q9

Apparently the EPA only regulates the substitutes for ozone-depleting substances such as R12. So their regulations only apply to refrigerants that are being used in an R-12 Freon type of system. They do not regulate replacements for R134a. So Enviro-Safe apparently can be used as a substitute for R134a. You are right on this point. I am wrong.

But re-read the original thread. It was about using Enviro-Safe in an R-12 system (pre 1994) as a substitute for R-12. That is illegal and against EPA regulations. What about a system that has been converted from R-12 to R134a, can you then convert it to Enviro-Safe? Yes you can as long as the conversion to R134a was not a “sham retro-fit” (as the EPA calls it). A Sham Retro-Fit is taking an R12 system converting it over to R134a and then converting it to something like Enviro-Safe. Intent is the key. The intent was never to use the R134a. But if it was converted to R134a and ran like that for 2-3 months or a season and for some reason you did not like R134a due to its lack of cooling or whatever, then you could legally use Enviro-Safe as that conversion, from R134a to a “second generation” refrigerant, is not EPA regulated. But it is still illegal to go from R12 directly to Enviro-Safe.

tom...

Eagle85C4
07-31-02, 11:59 PM
yawn.........

LarryBible
08-01-02, 06:33 AM
In taking my 609 Certification test I learned that it is illegal to use ANY refrigerant with a flammable gas. There are some who say you are driving a bomb if you use a flammable refrigerant. I don't really buy that, but I don't buy anything but R12 or R134a either.

The illegality is not related to whether or not it is an ozone depleting agent, rather because of the flammability. Additionally, the down side to many of these replacements relates to the fact that they are "blends." With a blend a leak allows the components to leak out at different rates. This means that you have to remove all refrigerant and totally recharge to have the correct refrigerant again.

It appears to me that the EPA is willing to look the other way on these alternates because they are not ozone depleting, but the flammability is rubbing some other law producing agency the wrong way.

If you think there is debate HERE about refrigerants, go read some of the posts at: www.aircondition.com and you'll see it really get crazy.

Have a great day,

LarryK 87
08-01-02, 08:11 AM
nope, dont do it...... oh well here we go ( and at least we can have these discussions with out turning on the ol flame throwers )

i think the last series of posts are really not more than syntax, if you remove ( evacuate ) all R-12 from a system and convert it then you now have an R-134a system, wheather you actually charge it with 134 is moot, certified techs would not ( against the law ) recharge it with R12 ( as it is now an R-134 system ), and this is exactly what the manf. of Envriosafe have stated you must do.
The original thread was to use it (envriosafe) as a total replacement to R-12, not recharge with R-12 still in the system. They simply state there is no need to replace any component(s) of the system ( that is working as designed) prior to re-charging with their product. They mention promintly about EVACUATING THE SYSTEM. This then ceases to make it an R-12 system when re-fitted with the R-134 fittings.

As a side note.... R-134 is also flammable and is acceptable as a direct replacement of CFC-12.

LarryBible
08-01-02, 08:34 AM
I do not remember anything from the 609 Certification that indicated that it is against the law to convert BACK to R12. It is illegal to vent either refrigerant, and definitely not a good thing to mix, but it is not illegal to do a reverse conversion.

If you DO convert back, you will definitely have to do a THOROUGH flush of the system, and replace the filter drier.

Although I use only 12 or 134, I am neutral about the other alternate refrigerants. The way I look at it, it's your car so it's your business.

Have a great day,

Tom73
08-01-02, 08:35 AM
Just a follow up e-mail from EPA about the second generation stuff:

Basically, if you have a car that came with an R-134a air-conditioner, the SNAP regulations do not apply. Using Enviro-Safe would NOT violate EPA's SNAP regulations. Also, there may be State or Local laws that forbid the use of flammable refrigerants, like Enviro-Safe, in cars regardless of whether SNAP applies or not. You should follow-up with your State and Local governments on that matter.

If your car came with a CFC-12 air-conditioner, and it was retrofitted to use HFC-134a, SNAP rules likely still apply and the use of Enviro-Safe would be prohibited.

If you do choose to use Enviro-Safe, please take every precaution possible, including warning anyone who works on your car that the refrigerant is flammable.

LarryK 87
08-01-02, 12:50 PM
I do not remember anything from the 609 Certification that indicated that it is against the law to convert BACK to R12. It is illegal to vent either refrigerant, and definitely not a good thing to mix, but it is not illegal to do a reverse conversion.
l

my error in how i said that, when the system has been retrofitted, and the new 134 style fittings installed ( assuming they do not get removed ) it would be illeagal ( assumption on my part ) to charge the system ( leaving fittings in place ) with R-12.
so if ya cant fill it with R-12 then it must be filled with R-134 or replacement

My error, i really stated that badly.

and no there is nothing that says you cannot retro backwards

The whole point is once the system is retro'd to R-134 weather or not R-134 is actually installed, the envrio-safe is an acceptable replacement to it ( R-134 )

R-12 is heavely ozone depleating, and non-flammable.

R-134 is not as bad,Ozone - wise, but is flammable , and is a known carcenogen(sp)

Enviro-Safe is a 2nd generation a replacement for R-134,is non-ozone depleating, but is flammabe( but to a lesser extent than R-134), and in non-carcenogenic (being an organic)

Vettelt193
08-01-02, 01:49 PM
something tells me if you convert the system to R134a, and go directly to envirosafe, the EPA isn't going to find out about it, and they aren't going to come knock down your door and arrest you... It isn't like the EPA has cameras and wire taps in everyones garages to figure out if they are doing environmentally friendly and EPA law abiding activities or not.