U.S. EPA’s SIGNIFICANT NEW ALTERNATIVES POLICY (SNAP) PROGRAM

Revision Date: 9/00
Process Code: Navy/Marines: SR-04-02; Air Force: FH03, SV09; Army: N/A
Usage: Navy: Medium; Marines: Medium; Army: Medium; Air Force: Medium
Compliance Impact: Low
Alternative for: Class I and Class II ozone-depleting substances
Applicable EPCRA Targeted Constituents: Class I and Class II Ozone Depleting Substances
Overview: Section 612 of the Clean Air Act stipulates that the EPA create a list of acceptable chemical and process alternatives to Class I and Class II ozone-depleting substances. The list, created in March of 1994, includes substitutes for major industry applications such as aerosols, adhesives, coatings, inks, foam blowing, fire suppression, refrigeration, solvents, sterilants, and tobacco expansion. As a result of the Significant New Alternatives Policy (SNAP) list, the Clean Air Act makes it illegal to replace any Class I or Class II substance with an alternative that has been identified as hazardous to human or environmental health if acceptable alternatives are available. Any person can petition the EPA for inclusion of certain alternatives on future revised lists of approved substitutes and permission will be granted or denied within 90 days. The producer of a substitute for a Class 1 substance must notify the EPA at least 90 days before the new or existing alternatives are introduced. The framework of the SNAP program is included in Subpart G of 40 CFR Part 82. The original SNAP listing separates alternatives by industry application. Revisions from August 1994, September 1994, January 1995, June 1995, July 1995, February 1996, September 1996, October 1996, March 1997, May 1997, June 1997, February 1998, and May 1998 are included as revisions at the end of the original SNAP listings. The latest updated list is available from the Stratospheric Protection Hotline (800) 296-1996 relating generic names to trade names. SNAP Federal Register Notices can be ordered from the Government Printing Office Order Desk at (202) 783-3238. Complete information about the SNAP Program is also available at: www.epa.gov/ozone/title6/snap/.


Compliance Benefit:

The SNAP creates a list of acceptable chemical and process alternatives to Class I and Class II ozone-depleting substances. This helps facilities meet the requirements under 40 CFR 82, Subpart D and Executive Order 12843 requiring federal agencies to maximize the use of safe alternatives to Class I and Class II ozone depleting substances, to the maximum extent practicable.

The compliance benefits listed here are only meant to be used as a general guideline and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g. the amount of workload involved.


Materials Compatibility:

Materials compatibility is based on the alternative procedure or chemical implemented. Considerations include the possibility of corrosion, swelling, deformation, and damage to coatings and adhesives. Testing will reveal particular types of damage to parts: stress, embrittlement, and total immersion corrosion.


Safety and Health:

Consult your local Industrial Health specialist, your local health and safety personnel, and the appropriate MSDSs prior to implementing any of these recovery, recycling, or reclaiming processes.
Benefits:
  • Facilitates compliance with the Clean Air Act.
  • Reduces the amount of ozone-depleting substances and EPCRA-targeted chemicals going into the environment.
  • Reduces worker exposure to constituents that have adverse effects to human health.


Disadvantages:
  • Potential substitutes not listed on the SNAP list may or may not actually be acceptable. Check with the Stratospheric Ozone Protection Hotline for the latest information from the EPA, especially for recent decisions or where a decision about a particular potential substitute is pending.
  • Time is required to identify acceptable substitutes.


    • Economic Analysis: Any SNAP-listed substitute process or chemical needs to be evaluated for a given application in order to determine the economic impact of the specific substitution. Regardless of any substitute’s cost, taxes on CFCs will continue to rise.


    Approving Authority:

    Approval is controlled locally and should be implemented only after engineering approval has been granted. Major claimant approval is not required.

    NSN/MSDS:
    Product NSN Unit Size Cost MSDS*
    R-134a 6830-01-390-9622 30lb CY $104.96 Click me
    R-124 6830-01-391-3107 30lb CY $373.97  
    R-401A 6830-01-391-3101 30lb CY $180.63 Click me
    R-401B 6830-01-391-3109 30lb CY $169.79  
    R-402A 6830-01-391-3105 27lb CY $279.53  
    R-402B 6830-01-391-3103 13lb CY $162.82  
    R-404A 6830-01-392-0960 33lb CY $563.95  
    R-404B 6830-01-391-3104 24lb CY $247.90  
    R-123 6830-01-391-3111 200lb CY $1291.25 Click me

    *There are multiple MSDSs for most NSNs.
    The MSDS (if shown above) is only meant to serve as an example.

     

    Points of Contact:

    Civilian:
    The International Cooperative for Environmental Leadership (ICELP) is a non-profit organization made up of technical associations, corporations, and governmental agencies exchanging information on ozone layer protection, ODSs, and alternative technologies. ICELP has developed seven different guidance manuals on ODS replacement products, each including case studies and extensive vendor lists which can be down loaded from their web-site: http://www.icel.org

    International Cooperative for Environmental Leadership
    11430 Balls Ford Rd
    Suite 102
    Manassas, VA 20109
    Phone: (703) 335-6300
    FAX: (703) 335-2585

    EPA:
    Mr. Jack Johns
    SNAP Document Coordinator
    U.S. Environmental Protection Agency
    Phone: (202) 564-9870

    Stratospheric Ozone Protection Hotline
    U.S. Environmental Protection Agency
    Mail Code 6205J
    401 M St., SW
    Washington, DC 20460
    Phone: (800)-296-1996 or (301)-614-3396

      U.S. Government:
    Government Printing Office Order Desk
    Phone: (202) 783-3238


    Vendors:

    National Concrete Products
    P.O. Box F
    Greenwood,  DE   19950
    Phone: (302) 349-5528 
    FAX: (302) 349-9435
    Contact: Mr. Mac McCombs

    Sources:

    United States Environmental Protection Agency, Office of Air and Radiation Stratospheric Protection Division SNAP program, August,1998
    http://www.epa.gov/ozone/title6/snap
    International Cooperative for Environmental Leadership, August, 1998

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