Garage Door News: Polyurethane Insulation Changes Proposed
Midland, MI: viernes, 15 de mayo de 2015
Issued in The Garage Door News, Volume 24, Issue 5, May 2015
In order to understand the proposed changes to US polyurethane regulations, the Garage Door News recently interviewed Robert York, Strategic Marketing Manager for Energy Efficiency at Michigan based Dow Polyurethanes. The following article highlights recent EPA proposals and their impact on the garage door industry.
In the fall of 2014, the Obama Administration announced new private sector commitments and executive actions to reduce emissions of hydrofluorocarbons (HFCs), powerful greenhouse gases that contribute to climate change.
The over-riding goal was to increase the incorporation of climate friendly technologies into cars, air conditioners, refrigerators, foams and other manufactured products. These proposed changes could have a substantial impact on the garage door industry because the chemical formulations used for polyurethane foamed-in-place sectional doors may need to change.
A September 2014 White House release notes: "This summer, the Environmental Protection Agency proposed two new rules under the Significant New Alternatives Policy program that would smooth transition to climate-friendly alternatives to HFCs, including by expanding the list of acceptable alternatives and limiting use of some of the most harmful HFCs where lower risk alternatives are available... Today's actions will build momentum for an amendment to the Montreal Protocol to phase down the global production and consumption of HFCs."
Among other changes, the Significant New Alternatives Policy (SNAP) changes recommended by the U.S. Environmental Protection Agency (EPA), call for the elimination of the use of specific hydrofluorocarbon (HFC) blowing agents used by many garage door manufacturers to manufacture polyurethane insulated residential and commercial doors.
"The two key changes for the industry are the proposed elimination of the use of HFC 134a and 245fa," notes Robert York, Strategic Marketing Manager for Energy Efficiency markets in North America for Midland, Michigan based Dow Polyurethanes. "Those two chemical formulations are used by many but not all garage door manufacturers in the U.S. and Canada."
York notes that these two formulations have substantially higher potential negative impact rates on release to the atmosphere than Carbon Dioxide (CO2). HFC 245fa has 1,030 times the potential impact of CO2. HFC 134a has 1,430 times the potential impact of CO2. This potential impact is at the point of manufacturing - as the insulation is being blown into the door sections - and not during or post-installation. One of the concerns expressed by industry is the implementation timeline currently proposed by the EPA - January 1, 2017.
Dow's York notes that similar changes in polyurethane formulations that have been required in other industries have taken up to 5 years to move from initial research to final implementation. That is one of the reasons that the EPA proposals for SNAP have received over 7000 industry comments to date. No target date for a final policy has been announced by the EPA, but it is expected that the final policy will be announced near the end of the 3rd Quarter or early 4th Quarter 2015.
IMPLICATIONS FOR MANUFACTURERS
The various garage door manufacturers that use foamed-inplace (FIP) polyurethane in the manufacturing of their residential and commercial door sections face very different obligations under the EPA?s proposed SNAP changes. This is largely due to the fact that manufacturing processes used by the door manufacturers vary greatly.
"The FIP process will vary, for example, between manufacturers who have continuous versus discontinuous manufacturing systems," explains York. Continuous garage door section manufacturing systems use a virtually non-stop flow of material (front and back door faces, insulation, etc.) into long slabs. Discontinuous garage door manufacturing generally assembles the two faces of a door section and then blows in the polyurethane insulation./p>
But York notes that the impact of the proposed EPA changes could also vary based on the current buildings used by manufacturers and the municipal regulations. For example, some garage door manufacturers use FIP chemical formulations that are flammable. This would mean that they have the appropriate physical facilities and building codes to allow that use. Those flammable formulations are not currently impacted by the EPA proposals.
Manufacturers who use HFC 134a or 245fa will face three major issues.
First, they will have to work with their polyurethane supplier to develop a chemical formulation to meet the manufacturer?s insulation density and energy savings goals. This, Dow's York notes, is not simple. "There is not a simple substitution. It requires substantial back and forth between Dow and the manufacturers."
The second issue facing garage door manufacturers is the potential need to alter the physical production line to adjust to the new formulation that is eventually adopted. "Companies may be able to use their current equipment, but it is also possible that some manufacturers will need significant capital expenditures in equipment," explains York.
The third issue, York believes, is potentially the most important. The currently proposed timeline would require full implementation of the changes by January, 2017. Dow research and development experience indicates that more time will be needed.
THE U.S. Environment Canada is currently exploring changes, but has not yet introduced a formal proposal.
"Environment Canada has tossed out some ideas for discussion and comment," notes York. "It appears that they will not announce formal proposals until after the EPA has formalized its policy." He notes that the timeline currently being discussed by the Canadian government is more realistic for industry - January 2022.
While the U.S. and Canadian proposals differ in timing, they could potentially follow a similar structure. As of a specific date, the use of specific polyurethane formulations will be disallowed. This means that there is a discontinuous approach to change.
The current process remains in use until the new system is launched. And then no further changes are required until new EPA or Environment Canada regulations are introduced (typically 5-10 year increments). Environment Canada is also considering other structures, including a phase down approach that would gradually limit the use of HFCs over the course of several years.
In contrast, Europe uses an incremental improvement philosophy. Under F-Gas, European garage door manufacturers are required to phase down their potential negative impact rates on release to the atmosphere. This continuous improvement philosophy, Dow believes, allows manufacturers at all levels to affordably improve their environmental impact.
While the environmental point of concern for polyurethane insulated garage door sections is at the point of manufacturing, manufacturers outside the U.S. may still be impacted by the proposed EPA SNAP policy. The EPA proposal includes a statement that indicates that the agency is trying to impact finished products manufactured in, or imported into, the U.S. "It is indicated in one sentence in an EPA document of over 40 pages," notes York, "but it is in there." He indicates that this would be a change from prior regulations.
Once the chemical formulations have been developed and production started, there should be no noticeable difference in the garage door sections -- for the installers or homeowners. The new blowing agent for the polyurethane insulation may provide some enhanced insulation values, but Dow believes that the change will be small at best.
Implementing the regulations that are eventually announced by the EPA will require substantial partnering between the polyurethane suppliers and garage door manufacturers. The changes will be difficult, time-consuming and potentially costly.
Robert York of Dow Chemical summarizes the situation: "We are a company that focuses on innovation and efficiency, but at this point, we are hoping for a friendlier timeline, but planning for the worst. We are actively working on new chemical formulations for the garage door industry."
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