Amy Childress | Vice President of Marketing & Planning, Cargo Solutions
Emerson Commercial & Residential Solutions
Maintaining food quality and safety is a primary challenge facing retailers who rely on the global cold chain to fulfill the growing demand for fresh food offerings. New technologies are emerging to provide improved visibility and traceability of perishable items, help stakeholders communicate, and ensure adherence to food safety best practices and/or regulatory requirements. I recently contributed to an article by Progressive Grocer which speaks to the importance of leveraging these technologies to achieve those goals and maintain an unbroken cold chain.
With the Food and Drug Administration’s (FDA) recent announcement of its New Era of Food Safety initiative, the technology that provides traceability and other key services is becoming more important than ever. This rapidly advancing technological toolset includes internet of things (IoT) condition sensors, temperature-sensitive flexible barcodes and blockchain. Combined, these tools are helping growers, shippers and retailers help ensure the freshest and safest possible product for consumers.
As I stated in the article: “This is especially critical with the global demand for year-round access to perishable products. Achieving this feat can require fresh produce to be transported by land, sea and air, encompassing the point of harvest, processing, cold storage and distribution — all before it ever begins the last-mile delivery to a store or restaurant.” In fact, a perishable shipment may be subject to as many as 20 to 30 individual steps and multiple changes of ownership before it reaches its destination.
Gaining visibility with IoT monitoring and tracking infrastructures
To better manage the sheer complexity of this cold chain journey, stakeholders are leveraging connected IoT monitoring technologies and tracking infrastructures. Operators now have better potential visibility into each step of food’s journey — even the possibility for comprehensive cold chain traceability. These tools — such as Emerson’s GO Real-Time Trackers and GO Loggers combined with our cloud-based Oversight online software portal — are giving stakeholders at each point the abilities to monitor and track a variety of conditions necessary for preserving food quality, including: temperature, humidity, CO2 levels, lighting and much more.
As I pointed out in the article, one of the key values of this technology is the ability to receive email or text notifications in real time when an in-transit shipment falls out of the ideal temperature range: “This allows suppliers to correct the issue promptly with the carrier or even reroute the shipment to a nearby location and preserve that perishable cargo.” Retailers and growers can also track these in-transit shipments to monitor delivery timelines and ensure that carriers are following proper shipping routes. Retailers rely on these devices to help them validate produce quality on receipt and monitor all their suppliers to ensure they’re meeting the freshness standards that their customers demand.
With Emerson’s connected monitoring and tracking infrastructure, data from our GO Real-Time Trackers and GO Loggers is pushed to the cloud and presented in Oversight, giving our customers both visibility and analysis of critical cold chain information with which to make better supply chain decisions.
End-to-end cold chain certainty
Of course, Emerson also provides the critical refrigeration components, controls and compressors to help retailers ensure optimal refrigeration temperatures in their refrigerated cases, walk-in coolers and freezers. Our advanced facility and asset monitoring systems provide real-time access to the critical information that retailers need to track, triage and quickly respond to issues that could potentially impact food safety and quality. What’s more, our automated temperature monitoring and recording devices help operators eliminate the need for time-consuming manual documentation — giving them the abilities to access on-demand reporting as needed for food safety compliance purposes and provide historical cold chain data.
Proactive refrigerant management isn’t just good for the environment. It is also sound business practice. I was recently interviewed by ACHR’s The News magazine on the Environmental Protection Agency’s (EPA) partial rollback of Section 608 provisions for appliance leak repair and maintenance. You can read the full article here and more on our perspective below.
In February, the EPA eliminated leak repair and maintenance requirements on appliances containing 50 or more pounds of substitute refrigerants, such as hydrofluorocarbons (HFCs). As a result, equipment owners are no longer required to:
Repair appliances that leak above a certain level
Conduct verification tests on repairs
Periodically inspect for leaks
Report chronically leaking appliances to the EPA
Retrofit or retire appliances that are not repaired
Maintain related records
But just because these leak repair provisions are no longer required doesn’t mean food retailers should ignore these best practices. There is a price to pay for refrigerant leakage that extends far beyond environmental damage. Detecting, repairing and even proactively reducing refrigerant leaks will help operators avoid a variety of associated costs.
The high cost of refrigerant leaks
The rollback of legal penalties for refrigerant leaks does not change the math on the operational costs. An average food retail store leaks an estimated 25 percent of its refrigerant supply each year, which can quickly add up to thousands of dollars in lost refrigerant. In addition, retailers must consider the maintenance and equipment costs. Persistently low levels of refrigerant can cause:
Excess compressor wear and tear
Reduced compressor and system capacities
Premature system failures
Double-digit efficiency losses
Left unchecked, even minor leaks can eventually lead to equipment failure. When this occurs, emergency repair costs are often only the tip of the iceberg. Operators may also be looking at revenue loss from food waste, business disruptions and reputational damage.
Proactive refrigeration management
So what can operators do to prevent leaks, even in the absence of federal requirements?
In the near term, they can — and should — implement rigorous leak detection and repair programs. Refrigerant leaks can occur anywhere in a system. Thus, an effective refrigerant leak detection program will combine monitoring, detection and notification.
Multiple technologies are available to support these efforts, including active and passive devices for monitoring and detection. Internet of things (IoT) capabilities allow for remote monitoring, enabling operators to focus on more pressing tasks. And with the integration of data analytics platforms, operators can uncover trends, identify persistent problem areas, and make informed choices about equipment upgrades and replacement options.
Over the longer term, operators can adopt refrigeration architectures that reduce the potential for refrigerant leakage in the first place. Legacy, centralized direct-expansion rack systems are high leak-rate offenders. That shouldn’t be a surprise; with thousands of feet of pipe, hundreds of joints and large refrigerant charges, there are many opportunities for leaks to occur.
In contrast, distributed micro-booster, indoor distributed and outdoor condensing unit (OCU) architectures experience lower leak rates by design. As an added benefit, they offer more options for lower-GWP alternative refrigerant use. This is a crucial advantage for operators who want to position their business for future regulations.
Sustainable best practices
The EPA’s Section 608 leak repair provisions were good for the environment. They are also part of a larger body of best practices for optimizing HVACR equipment. As states take the lead in adopting standards for leak detection and control, operators may find the rollback of these regulations to be short-lived.
Emerson is proud to take a lead in developing sustainable and cost-effective refrigeration systems and supporting technologies. Operators and original equipment manufacturers count on us to deliver strategies and solutions that anticipate emerging trends and regulations. From pioneering refrigeration architectures to refrigerant leak detection tools, we are committed to providing operators with the capabilities to meet their sustainability and operational goals today and into the future.
Worldwide connectivity helps keep the global food chain intact. According to The Economist, four-fifths of the planet’s 8 billion mouths are fed in part by imports. Fleets in the air, on the sea and on the road connect tens of millions of farms to hundreds of millions of shops and kitchens.
Emerson’s Transportation Solutions business has a proven reputation for tracking this freight, regardless of where it is within its journey. The world’s leading shipping companies, truck lines and refrigerated container manufacturers count on these refrigeration products and monitoring solutions. Building upon the smart communications it provides, Emerson’s Transportation Solutions business now supports Digital Container Shipping Association’s (“DCSA”) new internet of things (“IoT”) connectivity standards for shipping containers. DCSA is a nonprofit group founded by major ocean carriers to digitize and standardize the container shipping industry.
These recommendations focus on ensuring interoperability within the industry on the standardized methods for communications of IoT devices on container to IoT gateways at sea and on land. These universally adaptable standards align internal radio communication protocols for IoT gateways, addressing the network connectivity requirements for reefer containers, dry containers, and the RFID registration of these containers.
With these recommendations in place, carriers and supply chain participants will be one step closer to providing customers with an uninterrupted flow of relevant information regarding the whereabouts of containers and the status of their contents at any point along their journey.
For several years, the regulatory landscape regarding the governance of refrigerants has been constantly shifting. Already in 2020, we’ve seen developments, both on the state and federal levels in the U.S., which will have significant impacts on the commercial refrigeration and air conditioning sectors for years to come. We recently published an E360 article that lays out these regulatory developments in detail; this blog is a condensed summary of its key points.
Global, national and state regulations have targeted the phase-down of hydrofluorocarbon (HFC) refrigerants with high global warming potential (GWP) and replacing them with lower-GWP options. But while emerging refrigerants — such as natural alternatives and new synthetic blends of HFCs and hydrofluoroolefins (HFOs) — offer environmental improvements, they are not without their operational caveats. Making the transition to these new alternatives will impact refrigeration architectures and raise concerns about performance and safety.
This dynamic combination of factors creates a complex regulatory mix that industry stakeholders have been actively working to resolve. To better understand the full context, we’ve summarized the major regulatory developments in the U.S. and abroad.
Update on EPA SNAP Rules 20 and 21
In 2017, the U.S. District Court of Appeals for the D.C. Circuit ruled to vacate the Environmental Protection Agency’s (EPA) Significant New Alternative Policy (SNAP) Rule 20 — ruling that the EPA did not have authority to require those who had already moved out of ozone depleting substances (ODS) to phase down to lower-GWP HFCs under its Clean Air Act (CAA). Subsequently, the EPA published a “Notification of Guidance,” stating that it would not enforce any of the HFC restrictions set forth in SNAP Rules 20 and 21 when drafting future regulations.
The Natural Resources Defense Council (NRDC) filed a lawsuit claiming that the 2018 Guidance was overly broad because it did not distinguish between ODS and HFC replacements, and that the EPA had not followed proper public notice-and-comment procedures to seek stakeholder input.
On April 7, 2020, the Court of Appeals granted the NRDC’s petition, stating that the EPA guidance was procedurally inappropriate. The court agreed that the initial 2017 decision required only a partial vacatur — not entirely eliminating the requirements SNAP Rules 20 and 21.
It’s important to remember that the industry had already made great strides toward meeting the mandates of SNAP Rule 20 after its passing in 2015, but these ongoing legal entanglements have left the U.S. without a clear path forward in terms of a unified refrigerant strategy. While the majority of the industry still supports the move toward a more sustainable and environmentally friendly future, court rulings around SNAP Rules 20 and 21 have created many questions about what the path forward will look like.
HFCs excluded from refrigerant management requirements
In response to the 2017 Court of Appeals ruling, the EPA also has rolled back other HFC-related regulations. Specifically, it excludes HFCs from the leak repair and maintenance requirements for stationary refrigeration equipment, otherwise known as Section 608 of the CAA. Other beneficial provisions of Section 608 — including the certified technician program and the refrigerant recovery and reclamation rules — are still in effect.
California continues to set the pace
The passing of California Senate Bill 1383 (the Super Pollutant Reduction Act) in 2016 called for Californians to reduce F-gas emissions (including HFCs) by 40 percent by 2030. Since then, the California Air Resources Board (CARB) had been using EPA SNAP Rules 20 and 21 as the bases of its HFC phase-down initiatives. The subsequent passing of California Senate Bill 1013 (the California Cooling Act) in 2018 mandated the full adoption of SNAP Rules 20 and 21 as they read on Jan. 3, 2017; the law is currently in effect.
To meet HFC reductions of 40 percent by 2030, CARB continues to hold public workshops and invited industry stakeholders to comment on the details of its second phase of proposed rulemaking, which currently states:
Refrigerants with a GWP greater than or equal to 150 will not be allowed in new stationary refrigeration systems charged with more than 50 pounds, effective Jan. 1, 2022.
Existing food retail facilities with refrigeration systems charged with more than 50 pounds must collectively meet a 1,400 GWP average or 55 percent greenhouse gas emission potential (GHGp) reduction over 2018 levels by 2030.
Refrigerants with a GWP greater than or equal to 750 will not be allowed in new stationary air conditioning equipment, effective Jan. 1, 2023.
Refrigerants with a GWP greater than or equal to 750 will not be allowed in chillers (including process chillers) greater than -15 °F and ice rinks, effective Jan. 1, 2024.
Refrigerants with a GWP greater than or equal to 2,200 will not be allowed in new chillers ranging from
-15 °F through -58 °F, effective Jan. 1, 2024.
CARB is planning to finalize these rulemaking proposals this summer and is still seeking industry input.
More states join U.S. Climate Alliance
In 2017, a coalition of 16 states and Puerto Rico emerged to form the U.S. Climate Alliance, with a shared commitment of reducing short-lived climate pollutants (SLCPs) and HFCs. Since then, the Alliance has grown to 25 members — comprising more than 55 percent of the U.S. population and an $11.7 trillion economy. Several states have announced plans to follow California’s lead on HFC phase-downs.
Refrigerant safety standards and codes under review
Meeting the targeted emissions reductions in California likely will require the use of low-GWP refrigerants. But many of these low-GWP, HFO refrigerants are classified as A2L, or mildly flammable. The natural A3 refrigerant R-290 (propane) also is becoming more widely used in low-charge, self-contained commercial refrigeration applications. Currently, national and global governing agencies are evaluating the standards that establish allowable charge limits and the safe use of these A2L and A3 refrigerants.
Per a 2019 update from the International Electrotechnical Commission (IEC) to IEC60335-2-89, A2L and A3 charge limits have been increased for commercial refrigeration systems:
A2Ls — from 150g to 1.2kg
A3s — 500g for factory-sealed systems, and will remain at 150g for split systems
Similar efforts to raise A2L and A3 charge limits also are taking place in the U.S. The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) and Underwriters Laboratory (UL) are working to establish new charge limits and mitigations for the use of A2L and A3 refrigerants with support from industry and various stakeholders.
Once adopted, these standards will serve as the bases for codes that govern building, fire and other local authorities having jurisdiction (AHJ). It’s important to remember that building codes vary from state to state; thus, the adoption of flammable refrigerants ultimately may take place on local levels and may take years to accomplish.
Kigali Amendment not ratified in U.S.
In 2016, 197 member countries of the Montreal Protocol met in Kigali, Rwanda, and agreed on a global HFC phase-down proposal. The Kigali Amendment required ratification from at least 20 countries to take effect. To date, 92 countries (including many countries in the E.U., but not including the U.S.) have ratified it; it has been in effect for participating countries since Jan. 1, 2019.
According to industry estimates, ratifying the Kigali Amendment could create up to 33,000 jobs in the manufacturing sector by 2027 and have a positive impact on the U.S. economy. For these reasons, industry advocates are in favor of ratification and have demonstrated this through letters of support to both the Senate and the White House.
New HFC bills introduced in the U.S.
The U.S. Senate and the House of Representatives have each penned new bills that would put the EPA in alignment with the Kigali Amendment and restore the EPA’s authority to phase down the production and consumption of HFCs over a 15-year period.
Senate: American Innovation and Manufacturing Act of 2019 (S2754)
House: American Innovation Leadership Act of 2020 (HR5544)
While the future and timing of these new bills are uncertain, they offer the potential to re-establish a federal standard for HFC management, including guidelines for servicing, recovery, recycling and reclamation.
Industry appeals for consistency
Industry advocates, including the Air-conditioning Heating and Refrigeration Institute (AHRI) and the NRDC, have appealed for states to be consistent in their approach to adopting CARB’s rules. Establishing a unified framework for future refrigerant regulations would provide the certainty needed to help the industry and regulatory bodies move forward with a consistent approach. At Emerson, we’re actively involved in helping the HVACR industry evaluate and steer these proposals — in industry committees, stakeholder meetings and public comments.
Commercial & Residential Solutions is a global innovator of energy-efficient heating, air conditioning and refrigeration solutions for residential, industrial and commercial applications. www.climate.emerson.com
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