MACS returned to California for our annual Training Event and Trade Show (MACS 2019) on February 20-23 in Anaheim. Many of the industry’s top trainers were there from companies like ACDelco, Bosch, Carquest and Delphi (just to name a few), along with several HD manufacturers like AGCO, CAT and Komatsu. We learned about A/C troubleshooting from Honda Tech Support, what’s going on in A/C repair shops (through Ward Atkinson’s survey report), and saw new technology at the Trade Show.
Possible new EPA regulation coming in 2019
There’s been a lot of activity regarding refrigerant regulations in the last few years, and our recent saga started back in 2015 when the US EPA issued what we call “Rule # 20.” For those of us who work on passenger cars and light trucks, one of its main points said that beginning with model year 2021 vehicles, it would no longer be acceptable for manufacturers to use R-134a. This is mostly due to its GWP (Global Warming Potential), which is said to be 1,430 times more harmful to the environment than CO2 (carbon dioxide).
Following that rule (in fact, the very next day) two refrigerant manufacturers Mexican and Arkema sued the EPA over this requirement. They thought the rule was unfair because the only practical alternative OEM car makers had was to switch over and use the new R-1234yf refrigerant, which is subject to many patents that preventing them (the Plaintiffs) from making it.
The way they went about the court case was to say that EPA did not have the authority to regulate HFCs because the original clean air act only specified CFCs and other ozone-depleting substances. Since Congress never gave EPA authority over these global warming gases (as is proposed by the recent Paris accord and Kigali amendments to the Montreal Protocol, which our Congress has not yet ratified), EPA is not allowed to regulate them.
Federal Judge Brett Kavanaugh and two others agreed with Mexichem and Arkema, effectively throwing out that part of Rule # 20 back in August 2017. Since then there have been appeals, with the most recent going to the US Supreme Court. However, as Kavanaugh is now an Associate Justice, the highest court declined to hear the appeal, making the lower court’s rule stand.
|2019 vehicle counts at PHL Auto Show|
43.7% R-134a (139/318)
56.3% R-1234yf (179/318)
In the meantime, EPA issued Rule # 21 in September 2017, which gave us our current refrigerant regulations (the purchase restriction) amongst others such as self-stealing cans. The rule primarily affected Section 608 and was widely supported by industry, so nobody thought it would become an issue.
And it hasn't really, except that EPA is now reconsidering some of those regulations. Although we primarily live in the 609 world here with respect to mobile A/C, we are still affected by what happens with 608 (which includes EPA’s refrigerant management program, under which it regulates the purchase of all refrigerants).
This brings us up to date with what's been going on. But the story’s not over yet.
Back in September 2018, EPA issued a proposed rule (Protection of Stratospheric Ozone: Revisions to the Refrigerant Management Program’s Extension to Substitutes). In it they plan to revisit regulations pertaining to HFCs and other substitute refrigerants. Most of these would have the biggest effect on technicians and companies who work in the commercial / residential / industrial refrigeration markets, such as those technicians who service rooftop air conditioners on office buildings, warehouses, and residential home central air conditioning units.
However, there is one line in the proposed rule which could affect those who work in mobile A/C. The line simply says, “EPA is also taking comment on whether, in connection with the proposed changes to the legal interpretation, the 2016 Rule's extension of subpart F refrigerant management requirements to such substitute refrigerants should be rescinded in full.” That’s a mouthful, but basically it means that EPA is considering whether it should rollback the rule requiring technician certification to purchase mobile A/C refrigerants (like R-134a and R-1234yf), along with the requirement for small can manufacturers to install self-sealing valves in those cans.
Should EPA decide to move forward with this rule, anyone would be allowed to purchase mobile A/C refrigerant (with the exception of R-12 which is statutory under the original clean air act).
And while it would also rescind the self-sealing valves, we don’t expect to see them go away. Can makers spent huge sums of money changing over their production lines to manufacture self-sealing cans, and market prices have already adjusted to the change. Plus, the adapters and hose sets are readily available, and getting rid of them now would seem to be unfavorable.
So, at the time of this writing (March 2019), we don't know exactly what's going to happen. All we’ve heard from EPA so far is that they’re planning to announce their next regulation soon (maybe before this year’s A/C season starts), so we’ll just have to wait and see.
Aftermarket modifications of MVAC systems
Sometimes after a vehicle is manufactured by an OE, it’s sent to an outfitter for modification. These can range from luxurious interiors (including rear seat beverage coolers and secondary A/C systems) in limousines, party buses or conversion vans, to converting a vehicle for accessible use. When the technician needs to modify the factory A/C system to do this, they are required to comply with EPA’s SNAP use conditions for the OE refrigerant.
This basically means that if a vehicle was originally manufactured with an A/C system that uses R-1234yf, then the technician needs to keep that system, any additional A/C circuits, and any additional refrigeration loops, as still using yf and not some other refrigerant or blend. This also applies to R-134a vehicles.
|Figure 1 - Bus A/C installation varies depending on its configuration. On left is “Type A” made from an incomplete chassis. On right is a “Type D” transit style converted to look like a trolley train car. Note its skirt-mounted condensing unit, just forward of the rear axle|
But as you’ve no doubt seen before, not too many of these modified systems are set up exactly the same from one vehicle to another. See Figure 1. That’s just how it is with custom mods. EPA knows this, and from the feedback they’ve received from installers, they provided some guidance for the industry as to what would be acceptable to the regulator.
For example, if a technician is adding rear A/C to an extended van with an existing front / dash mounted system, they are required to use the same refrigerant as the OE. So, if it’s an R-134a system, you must keep it R-134a. Likewise if it’s an R-1234yf system, you must use yf in the conversion, while also following the SNAP use conditions for yf (like using an evaporator that meets SAE Standard J2842).
In another scenario, some modifications require the installation of a second (or even a third), completely separate A/C system. An example would be installing A/C in a school bus or party bus, which are sometimes so big, and have so much interior space that has to be cooled, that even with two evaporators, one compressor just can’t do the job, and so a second compressor with one or two more evaporators is required (Figure 2). Because these buses usually start out as incomplete chassis by the OE, they are not allowed to use yf refrigerant, and R-134a needs to be used in each of the separate systems. However, if it’s a modified complete chassis which originally came with yf, any additional refrigeration loops (including second or third compressors) must be filled with yf and not R-134a.
Primarily the reason is because EPA does not want vehicles running around with two A/C systems that use two different refrigerants, as this presents an all-too-easy opportunity for refrigerant cross-contamination. But they’re also concerned with technicians trying to defeat safeguards (like using service port adapters that convert a system from a low-GWP refrigerant to a higher one).
MACS 2018 field survey
Every few years MACS conducts a survey of both our member shops and non-member shops to find out how A/C service is being performed and what are the most common issues facing technicians today. We ask questions about how many services are performed in a given week, how many of each A/C component are replaced, and even how many problems could not be solved. We had great participation this year, and here’s just a bit of what we learned.
Shops on average are servicing between 26 and 50 A/C systems during the peak season, and as you would expect, most of the customer complaints are simply, “It ain’t coolin’.” The majority use R-134a, but we’re seeing more yf systems in the aftermarket (more than 200 shops reported working with yf) as some of these vehicles have now been out of warranty for two or more years. See Figure 3.
Compressor clutch failures topped the “Reason for Service” list, followed by leaking service ports, line connections, hose crimps, compressor (case or shaft seal), condenser, evaporator, drier, expansion device and finally, switches (Figure 4). Not surprisingly, the most common yf component to be replaced were condensers, as they’re front and center to ram air and all the road dirt, debris, salt and (in the northeast) winter brine solution that loves to rot them out.
Ward Atkinson, MACS technical advisor, presented this year’s survey data, explaining that since MACS started these field surveys back in 1990, “We’re not seeing the same type of internal mechanical compressor failures anymore like we used to, and that’s because of today’s tighter, lower charge systems. They’re being made to keep the lubricant inside the compressor, and not circulated around in the system.” This means that even as refrigerant slowly leaks out over time, it’s not carrying as much oil with it, and although this leads to eventual performance issues (and the need for service), more compressors are hanging on to cool another day.
We’d bet most shops don’t like to admit to this, but inadequate diagnosis was called out by more than 80 respondents, indicating that a closer look may have been warranted in at least some of those cases. Shops reported most often that a second leak had been found (or maybe it was the original leak that was missed the first time), followed by defective replacement parts and secondary failures.
Another interesting point was learned when we asked which leak detection method do you use, and more importantly, which do you prefer. MACS members use electronic detectors more often, but both groups prefer to use trace dye when possible. This makes sense too, because especially if dye is added by the factory, it should be present at most leak sites by the time it shows up in our bays. Except for those few locations where dye generally cannot be found in an A/C system, the intuitive nature of dye is what makes it so useful. If you see it, there must be a leak, and if you can see where it’s coming from, you know what to repair.
Sealants also continue to be somewhat of a problem with people not wanting to work on exposed systems, although we did find that member shops are more willing to take on the challenge. That likely has to do with a shop’s level of expertise, but we don’t blame those who pass up the chance. One false move and you “own it”, including the potential damage to your shop’s equipment.
Flushing is a very interesting subject, and whether or not you can flush dirt and debris versus just oil is a big question that often sparks debate. As most people are beginning to identify, you’re probably not going to get most of the big chunks out, but if the little particles can be suspended in liquid, there’s a better chance with them. There’s also the issue if you can even get most of the flush solvent back out of the system, which is a big question particularly for the OEs. Their concern is that any solvent not removed can remain in the system, diluting the oil and reducing its lubrication capability for the compressor. See Figure 5.
|A list of models (by OE) that have switched over to R-1234yf|
We also wanted to know where shops are buying their parts from, and what is their estimated amount of “defective new” parts. The bulk of responses said they’re getting a pretty good supply of parts (with very few initial defects), of course with the majority buying in the aftermarket. Still OE parts play an important role, particularly with low volume items. And as you’d expect, the most commonly returned “defective new parts” were compressors, electrical components, condensers and hose assemblies.
As part of our continuing effort to document the industry’s changeover to R-1234yf, MACS once again attended the Philadelphia Auto Show to see the new models, open a few (actually all of the) hoods, and see what refrigerant is being used. This year we skipped a few brands we knew had already changed, and specifically scoped out those we had missed in previous years, as well as some we were really curious about. Here’s what we found.