Skip to content

Archive for

Refrigerant Transition Continues Along State and Federal Lines

Jennifer Butsch | Regulatory Affairs Manager

Emerson’s Commercial & Residential Solutions Business

Emerson recently participated in the Atmosphere America online conference, where commercial refrigeration industry stakeholders discussed the ongoing transition from hydrofluorocarbon (HFC) refrigerants to those with lower global warming potential (GWP). Dr. Rajan Rajendran, Emerson’s vice president of system innovation center and sustainability, and I were speakers at the event; ACHR The News reported on our thoughts on the topic in a recent article.

Recapping recent events that impacted refrigerant rulemaking

To recap the activities regarding U.S. federal refrigerant regulations, I explained how these policies have faced many legal headwinds over the past few years. These began in 2017, when in response to a court challenge, a federal court vacated the Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) Rule 20 on the basis that the EPA didn’t have authority to regulate non-ozone depleting substances. If you remember, SNAP Rules 20 and 21 had been adopted on the basis of reducing global warming by phasing down the use of higher-GWP HFCs in some commercial and air conditioning equipment.

In response to the court’s ruling, the EPA released a guidance document stating that they would no longer be enforcing the delisting of HFCs under SNAP Rules 20 or 21. As a result, the scope of the SNAP program — including its ability to regulate HFCs and implement Rules 20 and 21 — remains to be seen. As of this time, the industry is still waiting for clarification from the EPA on this matter.

Reviewing new regulatory activity

However, as I explained at the conference, the EPA did introduce a SNAP Rule 23 proposal earlier this year, which recommended the use of three additional lower-GWP refrigerant alternatives for commercial refrigeration — R-448A, R-449A and R-449B — subject to narrow use limits. While the industry is currently awaiting the EPA’s final rule on SNAP Rule 23, this new activity demonstrates that the EPA is continuing to evaluate new refrigerants and list additional substitutes — which is a positive step in the right direction for our industry.

But in the absence of federal regulations governing HFCs, many states have taken measures into their own hands. The U.S. Climate Alliance now consists of 25 member states that are taking the lead on climate policy and in general, refrigerant regulations. So far, the majority of those efforts have been through the adoption of SNAP Rules 20 and 21, which California was the first to adopt into state law via its California Air Resources Board (CARB) initiatives. And as we’ve discussed previously in this blog, additional CARB proposals are currently under review and being formulated with guidance and input from industry stakeholders.

Rajan also spoke about a pair of new bipartisan bills that have been introduced in the House and the Senate which would phase down the production and consumption of HFCs over a 15-year period in accordance with guidance from the Kigali Amendment to the Montreal Protocol. The passing of these companion bills — known as the Senate American Innovation and Manufacturing (AIM) Act of 2019 and the House American Innovation and Manufacturing Leadership (AIML) Act of 2020 — would authorize the EPA to regulate HFCs and establish standards for HFC management (service, repair, recovery, recycle, reclaim, etc.).

Both the AIM and AIML Acts would not affect existing equipment but would provide allowances for the aftermarket servicing needs of our industry. Their goals would be to preserve previous technological investments while supporting innovation and potential job creation.

As Rajan stated, by adopting a federal approach proposed by these bills, our industry would benefit greatly from much-needed regulatory consistency and certainty. It’s important to note that Emerson and its industry partners, such as the American Heating and Refrigeration Institute (AHRI), have pledged their support for these new bills. In addition, since these bills do not preclude states’ rights, efforts that have taken place in California and other states are still valid. While these states might be slightly leading in the refrigerant transition, our hope would be that the rest of the country would soon catch up and follow a standardized approach.

Supermarket Food Safety: Emerson Cold Chain Solutions

Katrina Krites | Marketing and Business Development

Manager, Food Retail

Emerson’s Commercial and Residential Solutions Business

Providing consistently safe and high-quality food in supermarkets is important to each stakeholder in the food retail supply chain. From farm to fork, grocers depend on their cold chain suppliers to collect, share and report on the handling and shipping practices that contribute to food safety. In the first blog based on an article in, we examined food retail market trends and risk factors impacting food safety and quality. In this companion blog, we will explore how Emerson is helping food retailers and stakeholders address these challenges at nearly every step of the food supply chain.

Harvest and processing

The potential decay of perishable produce starts the moment it is picked, but this can be stunted by controlling temperatures and the ambient environment via: flash cooling/freezing; temporary staging in storage coolers; and pre-cooling shipping containers. Shipping containers may be modified with ripening agents, and processors often measure the levels of ethylene, a natural gas that can accelerate ripening.

Emerson provides temperature-probing devices that can be used to measure internal “pulp” temperatures prior to and during the staging and loading processes. Our real-time temperature monitoring and tracking devices can be activated inside a shipping container to immediately begin monitoring location, temperatures and other environmental conditions of in-transit perishable shipments.


Food’s journey to supermarket shelves can last anywhere from days to weeks — by truck, sea and/or air — and grocers rely on their shippers to provide an unbroken chain of temperature certainty. Loading best practices promote airflow and shipments to be “load locked” in order to limit excess vibration. Transport containers must be able to maintain temperatures and provide visibility into container conditions. Mixed-load cargos may have different refrigerated temperature zones within the same shipment.

Emerson’s field-tested, proven compression technologies can withstand the rigors of the road while helping operators to ensure that their transport refrigeration systems preserve product at specified temperature ranges. Temperature monitoring, logging and tracking devices — combined with our cloud-based software portal — can provide real-time temperature and location conditions of product in-transit. The software enables live remote monitoring and issues alerts to stakeholders based on user-defined parameters, such as: temperature excursions; changes to shipping atmosphere; vibration; security breaches; and shipping delays.

Cold storage distribution centers

Upon receipt of food at a cold storage facility, handlers must inspect product temperatures and conditions, including pulp temperatures with probing devices, and trip data from logging and tracking devices. Relying on only the ambient air temperature of the shipping container is not an accurate measure, as some carriers may turn off the refrigeration system during shipping to preserve fuel. After inspection, handlers must promptly transfer perishable cargo into a designated cold storage temperature zone. The entire process must adhere to each facility’s established Hazardous Analysis and Critical Control Points (HACCP) and/or Hazard Analysis and Risk-based Preventative Controls (HARPC) plans.

Emerson’s logging and tracking devices give end-users the ability to maintain live, remote visibility for monitoring the temperatures and locations of their in-transit shipping containers. In cold storage facilities, our compression and refrigeration technologies help operators to establish and maintain proper temperatures in various cold storage zones. Robust facility monitoring solutions help operators to remotely oversee conditions, ensure proper temperatures, and automatically record temperatures for use in HACCP reporting.

Grocery stores

From the moments perishable shipments are unloaded in supermarkets, operators take ownership of food quality and safety. This starts with inspection — checking pulp temperatures and trip data logs — and continues with the prompt transfer of perishables into designated cold storage coolers or freezers. Once in cold storage, control platforms help retailers to monitor perishable temperatures and optimize food quality.

Refrigerated storage and staging coolers for click-and-collect fulfillment must have sufficient capacity to handle fluctuations in order volumes and frequent opening/closing of walk-in doors. Order-picking processes and customer pick-ups and deliveries must be optimized to ensure safe handling and proper temperatures. Supermarket food preparation introduces hot-side complexities as consumers look to grocers for home meal replacements. Staff must be trained in safe cooking best practices — such as those provided by the U.S. National Restaurant Association’s (NRA’s) ServSafe® certification course — and cook-and-hold procedures should also follow established HACCP/HARPC plans.

In addition to our proven compression and refrigeration technologies, Emerson solutions address a variety of modern supermarket requirements. These include condensing units with variable-capacity modulation to precisely match refrigeration load requirements and flexible distributed architectures that can augment existing refrigeration systems. We also offer a suite of temperature-probing devices to help grocers automate the recording of prepared food temperatures and assist grocers with food safety and process compliance concerns.

Our powerful facility management, monitoring and control platforms address both existing and emerging food retail complexities. These tools provide near real-time access to critical information to help retailers track, triage and respond to issues pertaining to food quality and safety compliance — in individual stores and across their multi-site networks. In addition, these control platforms utilize alarms, notifications and remote access to provide end-users with continuous building and refrigeration monitoring at any retail location.

Connectivity drives cold chain visibility

Modern food retailers are held to increasingly higher food safety and quality standards. Store operators, consumers and health inspectors all demand greater transparency into the food supply chain and improved visibility of food’s journey from farm to fork. With today’s connected internet of things (IoT) monitoring and tracking infrastructures, operators now have the potential for visibility into each step of food’s journey — and even the possibility for comprehensive cold chain traceability. Emerson provides the refrigeration technologies and IoT-enabled infrastructures to help stakeholders at each point monitor, control and track a variety of conditions necessary for preserving food safety and quality.






Supermarket Food Safety: Trends and Risk Factors

Katrina Krites | Marketing and Business Development

Manager, Food Retail

Emerson’s Commercial and Residential Solutions Business

Ensuring food safety throughout the food retail supply chain has taken on new importance in 2020. As COVID-19 pushed many grocery shoppers online and reshaped consumer buying habits, grocers had to quickly adapt to new demands without compromising food safety and quality. In a recent article in, we explore the impacts of these rapidly changing market dynamics and discuss Emerson’s commitment to helping retailers and supply chain stakeholders preserve food quality and safety. In the first of a two-blog series, we will examine the evolving food retail landscape and explore food safety best practices at various steps along food’s cold chain journey.

With the onset of the global health crisis, retailers were suddenly inundated with click-and-collect orders and home deliveries. This unexpected high order volume not only placed pressures on e-fulfillment infrastructures, but also required renewed adherence to food safety best practices. Grocers not only had to maintain proper temperature ranges during storage, picking, staging and delivery, but also follow proper sanitation and hygiene protocols for in-store customers and employees alike.

At the same time, grocers began playing an even larger foodservice role by providing ready-to-eat, home meal replacements while still supporting deli- and freshly prepared offerings. Combined, these new challenges only highlighted pre-existing supply chain concerns and underscored the importance of maintaining food safety at every point of its journey to consumers. Consider the dynamic mix of food retail market and consumer trends impacting supermarket food safety in 2020:

Understanding food safety risk factors

Food safety is a cumulative process involving multiple stakeholders. From harvest to production, shipping and cold storage, order fulfillment and delivery, food preparation and handling, grocery retailers rely on food safety best practices across a wide range of disciplines.

Food shipments can proceed through up to 30 individual steps and have multiple changes of ownership, custody and control before they reach supermarkets. Once there, this chain of custody now includes the complexities of click-and-collect fulfillment — from picking processes and staging through customer pick-up. Throughout these processes, multiple factors can either decrease perishable food’s shelf life or increase its risk of becoming unsafe and a potential cause of foodborne illness.

An unbroken chain of temperature certainty and safe handling practices is essential for maintaining food safety. Common risk factors include:

  • Safe handling practices must guard against the spread of bacterial pathogens that can cause food poisoning, such as E. coli and listeria. Cross-contamination, poor employee hygiene, and unsafe or unsanitary processing or food preparation methods are key contributors.
  • Produce and perishable commodities must be kept within optimal temperatures to prevent the growth of bacteria, maximize freshness and shelf life, and avoid food waste and shrink. Environmental conditions within shipping containers must be monitored and managed throughout food’s journey to optimize humidity, ripening agents, security and real-time location tracking.
  • Online order fulfillment presents new challenges for maintaining temperature control. Chilled perishables and frozen goods must be kept within optimal temperature ranges, which can impact in-store picking processes and order staging prior to customer pick-up. Fluctuations in demand can also affect walk-in cooler performance due to changes in employee foot traffic and increased unit access.
  • Cook-and-hold procedures must maintain food at optimal holding temperatures. Per the U.S. National Restaurant Association’s (NRA’s) ServSafe® guidelines, this requires frequent checking and documentation of internal food temperatures to ensure food quality and safety.

Part two of this blog series will explore Emerson refrigeration and temperature monitoring solutions for helping ensure food safety throughout the cold chain and in supermarkets.

Online Order Volumes Drive Grocers to Re-Evaluate Refrigeration Strategies

Katrina Krites | Marketing and Business Development

Manager, Food Retail

Emerson’s Commercial and Residential Solutions Business

As I discussed in a previous blog, the coronavirus pandemic forced many food retailers to shore up their click-and-collect fulfillment capabilities to meet consumer demand for an in-store shopping alternative. While many shoppers tried click-and-collect for the first time during the early phases of the pandemic, industry experts expect this change in buying habits to continue well into the future. In a recent ACHR News article, I explored further how grocers are adapting their refrigeration strategies to support an increased volume of click-and-collect orders.

With the onset of the pandemic and the precipitous rise in online fulfillment, many grocers scrambled to add refrigerated areas to stage their customers’ fresh and perishable orders. Months later, the impacts of the lingering pandemic continue to be felt throughout the cold chain — from food retail to distribution and warehousing strategies. For many grocery supply chain stakeholders, this is an opportunity to deploy innovative technologies that they had only thought about implementing previously.

Explore new distribution warehouse strategies

The grocery industry had been experiencing growth in distribution warehouse infrastructures well before the pandemic; with increased e-commerce fulfillment requirements, we expect this trend to accelerate. As part of their efforts to support click-and-collect fulfillment, many retailers are experimenting with various store formats, including dark stores, micro-fulfillment centers (MFCs) and automated warehouses.

In many cases, existing store layouts are not ideally or efficiently designed to handle large amounts of online orders, and having employees on the sales floor picking to fulfill orders can disrupt the in-store shopper experience. To alleviate these emerging pressures, we may see more MFCs and dark stores dedicated exclusively to the fulfillment of online orders.

Implement food safety and environmental controls

As retailers integrate more of these types of fulfillment facilities to improve efficiencies in their picking and order consolidation processes, ensuring food safety will become increasingly important. There’s no question that the pandemic has created renewed focus on grocers’ efforts to protect the health and safety of employees, customers and of course, food. As part of this focus, grocers are evaluating various tools and technologies to help them monitor and control equipment and systems so that their employees can concentrate on providing positive customer experiences.

This will likely translate into a greater demand for critical control systems that help grocers achieve food safety-related objectives, including:

  • Identifying key refrigeration and facility performance issues
  • Implementing periodic air changes (refreshes)
  • Keeping food safe and sanitary

The abilities to perform remote monitoring, troubleshooting and problem resolution — including predictive failure and maintenance analysis — are becoming essential resources for retailers hoping to schedule service intervals and minimize disruption to in-store shoppers. Grocers can also leverage these tools and technologies to implement a variety of other key store activities, such as: enabling connected, hand-washing stations for increased sanitation; installing remote, wireless sensors for food quality monitoring; or providing enhanced HVAC controls to help maintain indoor air quality.

Consider sustainable refrigerant alternatives

As grocers adapt to the consumer preference for click-and-collect fulfillment, many face the prospect of remodeling their stores to supply this additional refrigeration load. This will give them a prime opportunity to transition toward alternative refrigerants with lower global warming potential (GWP).

Many retailers have considered beginning this transition for quite some time but were uncertain about when to start the process. From a timing perspective, it may make sense to start aligning new store design upgrades with their future refrigerant and sustainability objectives. And in certain areas of the country — where grocery demand may be returning to pre-pandemic levels — many retailers will be well-positioned to invest in new refrigeration equipment or store upgrades.

Proposed EPA SNAP Rule 23 Addresses A2L, HFO Refrigerant Use

RajanRajendran2 Rajan Rajendran | V.P., System Innovation Center and Sustainability

Emerson’s Commercial & Residential Solutions Business

In May, the Environmental Protection Agency (EPA) pre-published Rule 23 of its Significant New Alternatives Program (SNAP), which proposed approving (or listing) multiple substitute refrigerants for commercial refrigeration and air conditioning equipment. Overall, the HVACR industry was pleased to see the EPA actively evaluating the use of lower-global warming potential (GWP) refrigerants, although many stakeholders have sought clarifications on several aspects of the proposal. I recently provided Emerson’s perspective on the proposed SNAP Rule 23 for an article that was published in ACHR The NEWS.

Per normal rulemaking protocols, the EPA accepted public comments on the proposed rule to give equipment manufacturers and industry associations opportunities to submit their thoughts and concerns. Like many industry stakeholders, Emerson expressed our appreciation to the EPA for once again approving new low-GWP refrigerants. As I stated in the article, the HVACR industry relies on federal guidance to provide regulatory consistency across the U.S. — rather than allowing states to assume that role — and SNAP Rule 23 is a continuation of the EPA’s efforts to provide that much-needed guidance.

New A2L listings for AC applications

The SNAP Rule 23 proposal lists several mildly flammable (A2L) refrigerants, including R-454B and R-32, as acceptable, subject to use conditions in new residential and light commercial air conditioners and heat pumps. Other A2Ls listed as acceptable in these applications include: R-452B, R-454A, R-454C and R-457A. The rule also lists R-32 as acceptable, subject to use conditions for new self-contained air conditioners that are typically used for comfort-cooling applications (e.g., rooftop units, water-source heat pumps and ground-source heat pumps) and split systems.

For industry stakeholders, this proposal is an indication that the EPA is likely to move towards approving A2L refrigerants in comfort-cooling applications where applicable safety standards — developed by the Underwriters Laboratory (UL) and the American Society of Heating, Refrigeration and Air-Conditioning Engineers (ASHRAE) — are now in place to govern the safe use of A2Ls in these applications. As the development of A2L safety standards for commercial refrigeration is still ongoing, it is important to remember that the SNAP Rule 23 proposal does not yet include recommendations for the use of A2Ls in commercial refrigeration.

With respect to A2Ls, Emerson and other industry stakeholders questioned why the SNAP Rule 23 proposal did not also recommend these newly approved refrigerants for use in positive displacement chillers. From Emerson’s perspective, we welcome new low-GWP options for residential and light commercial air conditioning applications and would like to see substitutes such as A2L refrigerants used to replace R-410A for positive displacement chillers.

Narrowed use of R-448A and R-449A in commercial refrigeration

In terms of Emerson’s other concerns on the SNAP Rule 23 proposal, we are seeking clarification on the narrowed use limits placed on R-448A, R-449A and R-449B in stand-alone, medium-temperature commercial refrigeration units. Today, these hydrofluoroolefin (HFO) refrigerants are used broadly across many applications and provide the flexibility to meet various design requirements. It is our hope that we could potentially remove unnecessary restrictions and/or simplify the guidelines for using these refrigerants within these applications.

Other prominent stakeholders also objected to the EPA’s proposed use limits of these HFO refrigerants, noting that they impose an unnecessary burden on the industry’s transition away from high-GWP refrigerants. R-448A, R449A and R-449B have already been listed as acceptable without these limitations in many types of applications, including: low-temperature, stand-alone equipment; remote condensing units; supermarket systems; and cold storage warehouses.

Overall, Emerson sees the SNAP Rule 23 proposal as a positive step in the right direction for both the EPA and our industry. Considering the global initiative to phase down higher-GWP, hydrofluorocarbon (HFC) refrigerants, the approval of new lower-GWP alternatives will give manufacturers the confidence to move forward with plans to integrate these approved refrigerants into their product development lifecycles.


%d bloggers like this: