Comment Log Display

To Whom it May Concern
 
This letter is in regards to the proposed rule phasing out R-410A
set for 1/1/23.
 
The California Fire Prevention Officers, North and South Sections
are opposed to the implementation date, and would urge the date be
pushed out two years.
 
As CARB is aware, there are concerns of the fire service regarding
the safety of the replacement agents known as A2L. Testing is
currently scheduled to assess the safety and flammability of the
replacements. The testing is necessary so that fire and building
codes can be adjusted to accommodate the refrigerants which are not
allowed under current regulation. The Fire service generally likes
the idea of the A2L refrigerants as they are generally less
flammable than the other options such as propane, but they are not
without risk. Any use of the new agents needs to be allowed by code
however, and California going their own way would not address the
need for testing that would need to occur anyway.
 
Time is needed to put safety elements into those codes so that the
operation can be done safely without creating undue risk to the
occupants of these structures, or the responders fighting fires in
these structures. There is a possibility that the use of these
refrigerants may cause an increase in fire risk under certain
circumstances. The testing hopes to settle this question.
 
Because of the timeframes involved in the testing, as well as the
time it takes to move through the code consensus process, a 2023
date would be too soon for manufacturers, installers, and code
professionals to be able to comply with the new CARB regulation.
 
 
 
 
 
 
It would be preferable for the International Code Council process
to work through its conclusion before mandating the phase out of
the R410A. Once the International Codes are set, California can
move quickly to adopt the new standards into the  Title 24
regulations, ensuring standardization nationally on the issue. This
would reduce costs for the homeowners and businesses in the state.
Premature enforcement could prove costly in the short term, and
lead to buildings that are significantly less safe.
 
It is for these reasons that the California Fire Prevention
Officers Association opposes the 1/1/23 date, and would prefer the
date be set for 1/1/2025 instead.
 
Thank you for your time.
 
Sincerely,
 
 
 
Jason Nailon, President- Southern California Fire Prevention
Officers Association
Mike Payton, President- North California Fire Prevention Officers
Association
Robert Marshall- Rep. to the A2L Workgroup Northern California Fire
Prevention Officers Association
Randy Metz, Rep. to the A2L Workgroup, Southern California Fire
Prevention Officers Association