FEATURE ARTICLE - September 2012
Breaking News: More Restrictions on HCFC 225 for Cleaning
Barbara Kanegsberg, BFK Solutions LLC
Think you know all about the HCFC 225 phaseout? Think again. Here’s a heads-up about a distinct change in the EPA position regarding the phaseout of HCFC 225 (hydrochlorofluorocarbon 225, AK 225). This is a biggie: starting January 1, 2015, in a little over two years, virgin HCFC 225 cannot be used in vapor degreasers or similar cleaning operations. All is not lost. If you get your ducks in a row, you can maintain good critical cleaning processes.
Here’s the story
According to reliable sources in the regulatory community, in order to achieve better consistency with the Clean Air Act, the EPA has modified its position regarding HCFC 225. Manufacturers can purchase and use HCFC 225 until the end of 2014. However, starting January 1, 2015, manufacturers are banned from using virgin HCFC 225 in vapor degreasers or in any other application where they would have to transfer the 225 out of the storage container and into another container (like an ultrasonic tank, a dip tank, or a dispenser bottle). The interpretation from EPA had been that manufacturers could use their existing stockpiles of 225 for product cleaning – this is no longer the case.
Does this rule out all continued uses of HCFC 225? No. There are two cases where 225 can be used after the end of 2014. First, you can continue to use HCFC 225 in such items as aerosols or presaturated wipes. The rationale is that the device containing the HCFC 225 is directly providing the use. It’s sort of like being able to continue to use a phased-out refrigerant that is contained in a refrigerator.
Second, HCFC 225 can be used if it is totally consumed (as in a feedstock for synthesizing chemicals), recovered, or recycled. This means you can use recycled HCFC 225 indefinitely. So, you could use recycled 225 in a vapor degreaser. Therefore, if there is a customer or program requirement to use HCFC 225, one short-term solution might be to stockpile recycled chemical. The terms recovered and recycled are used, but there is no elaboration about the definition.
An official notice about this is expected to be published in the Federal Register. However, the publication date has not yet been determined.
The reason for the Federal ban on the importation, production, sale, and use of HCFC 225 is that HCFC 225 depletes the stratospheric ozone layer. The HCFC 225 ban is called out in the Federal Clean Air Act. This all relates to the Montreal Protocol, a global effort to restore the good ozone in the upper atmosphere. Laws and regulations that save the good ozone are different from those regulating VOCs (Volatile Organic Compounds), chemicals that increase the bad ozone, or ozone that is closer to ground-level. As it turns out, cleaning chemistries with even mild solvency tend to be either VOCs or ODS (Ozone Depleting Substances). Therefore, finding effective cleaning and defluxing chemistries is difficult.
How did I find out about the changes?
There had been statements from EPA personnel indicating that parts and components manufacturers could continue to clean with drums of HCFC 225 that they had purchased before the end of 2014– THIS POSITION HAS CHANGED.
How did I find out? Frankly, I stumbled over this change because we question our assumptions. Our colleagues, Tom and Carrie Seratti, asked me to write an article about lead-free solder and the impact of the loss of HCFC 225 for the Stratesys Group Industry Update Newsletter (http://stratesysgroup.com). I figured, sure thing! I thought I understood the situation with HCFC 225, so this would be a pretty easy article to put together. However, as those of you who have worked with “The Cleaning Lady and The Rocket Scientist” know, we’ve made a career out of striving to learn it all and at the same time always questioning what we think we know. Let’s say my “woman’s intuition” kicked in. So I double-checked, and I’m sure glad I did.
Why will we miss HCFC 225?
HCFC 225 fills a niche in critical and precision cleaning. It has proven to be an effective solution in medical, space exploration, aeronautics, military, and electronics application. Since we’re welcoming readers of the Stratesys Group Industry Update Newsletter and since many of them are in electronics assembly and are located in Southern California, we’ll use defluxing as an example and we’ll discuss VOCs. The same principals apply to many critical cleaning applications.
If you use lead-free solder, the higher temperatures may make flux residue harder to remove. If you have complex assemblies, the flux residue may be harder to remove. HCFC 225 became a favorite solvent for defluxing in Southern California, because it is one of the few readily adapted and readily permitted solvent options in SCAQMD (South Coast Air Quality Management District). HCFC 225 is VOC exempt (i.e. it is not a Volatile Organic Compound; it does not make smog) and it is not a HAP (Hazardous Air Pollutant). HCFC 225 has mild to moderate solvency without additives; it is not flammable; and it evaporates rapidly. It does a reasonable job of removing fluxes (it’s a bit like the legendary Freon® 113); and it can be “revved up” with additives to increase the solvency a bit while still keeping within the legal maximum for SCAQMD of 25 g/L VOC. HCFC 225 is also useful for defluxing because it creeps into tight spaces where flux residue might lurk; i.e. it has favorable wetting properties. In comparison, the surface tension of water is high enough that you may need heat, force, additives (some are VOCs), and increased cleaning time (a slow conveyor belt speed).
Life after HCFC 225?
If moving away from HCFC 225 is not an immediate option, be sure you have an adequate supply of recycled material, that it is of the required quality, and that the price will not drive you to distraction. This may mean obtaining certifications of analysis from a reliable supplier. It may mean setting up your own in-house recycling program.
Unless your application requires short-term use of HCFC 225, you would be wise to explore other options. If you assemble medical devices, start looking at other process options; and be sure to look at the impact on the level and nature of leachable residue and on surface quality. There are FDA and liability implications; you may need to revalidate the cleaning method.
If you are an electronics assembler, you can change the defluxing process. It is important to evaluate the cleaning requirements. With no-clean flux, cleaning may have become unnecessary or at most an afterthought. Lead-free fluxes and complex, highly-populated assemblies with close spacing have moved cleaning back to center stage. As industry experts in critical cleaning, we can tell you that effective cleaning and defluxing processes are possible even in SCAQMD. Chemicals are rarely banned by SCAQMD; you just have to control the process to make them street-legal. There are water-based and solvent-based options. They all have regulatory, worker exposure, and performance issues. We can help find the best options for you. We have clients who are using all kinds of cleaning chemicals in a legal and ethical manner. It’s a matter of controlling both the cleaning agent and the cleaning process.
Other cleaning solvents have been determined to be acceptable through the EPA SNAP (Significant New Alternatives Policy) Program. In general, most of them tend to have mild solvency. Some are VOC-exempt. Because they tend to be more expensive than traditional solvents, they should be used in well-contained systems. Others are most suited to aerosol applications. New alternatives have been posted recently. (http://www.gpo.gov/fdsys/pkg/FR-2012-08-10/pdf/2012-19688.pdf)
So, spritzing HCFC 225 out of an aerosol can is ok, but transferring it into a vapor degreaser is not. Hmmm …. The concept of restoring the ozone layer by allowing highly-emissive uses of HCFC 225 seems counterintuitive. As I understand it, the rationale for allowing continued use of aerosols and pre-moistened/prepackaged wipes containing HCFC 225 appears to be based on analogy with continued use of refrigerants that are already “assembled” into air conditioners and chillers. In other words, the refrigerant is sold as part of the refrigerator; and the packaging is part of the function.
However, there are very well-contained solvent cleaning systems where solvent losses are exceedingly low. It is possible to have equipment where the transfer of solvent into and out of the system is also well contained. If aerosols and wipes are allowed, it would seem even more protective of the ozone layer to allow the use of virgin HCFC 225 in well-contained systems.
Think locally and globally
Finally, have a voice in rule development. Regulatory agencies and manufacturers often feel they are working at cross purposes. However, if agencies can understand the technical aspects of manufacturing processes, they can come up with rules that reach environmental objectives without stifling industry. As we recently discussed in Clean Source, SCAQMD is considering opening Rule 1122, the one that currently restricts manufacturers to no more than 25 g/L VOCs in most cleaning processes. Let’s just say that’s a challenging VOC level for cleaning many electronics assemblies. If you are having trouble meeting your customers assembly requirements, if you are turning down electronics assembly processes that would be doable elsewhere in the U.S., it might be in your own best interest to get involved; and we can help you do so.
If you have immediate issues relating the manufacturing, defluxing, critical cleaning, or about coping with regulations designed to either save the good ozone or reduce the the bad ozone, don’t cringe in terror, give us a call or send us an email.
To send questions or comments directly to the EPA
hotline: 1-800-296-1996 (9 to 5 Eastern Time)