Collaborative efforts between the HVAC industry and the U.S. Department of Transportation (USDOT) have resulted in special permits for shipping HVAC equipment containing A2L refrigerants, exempting them from stringent hazmat regulations.
Background
As of now, the U.S. Department of Transportation (USDOT) has not established specific regulations for transporting HVAC equipment containing A2L refrigerants. However, collaborative efforts between the HVAC industry and USDOT have led to the creation of special permits designed for shipping A2L refrigerants. These permits play a crucial role, exempting A2L refrigerants from more stringent hazardous materials (hazmat) requirements.
Special Permits
There are two distinct permits based on the total refrigerant charge in the unit. Manufacturing plants responsible for shipping units with refrigerants must be listed on the permits. In this context, AAON has six listings across its Tulsa, Longview, and Redmond plants.
Permit Accessibility
Permits can be placed inside the unit, but it is vital that they remain accessible to the driver without unloading the unit from the truck. This becomes particularly important when multiple units are stacked on a truck.
Permit Specifics
1. SP-21287 (Units with less than 44 pounds of refrigerant):- Complete exemption from hazmat regulations.
- Placards on the truck/trailer are not required.
- No air or water transport.
- Incidents with gas release must be reported to USDOT.
- Not a complete exemption from hazmat regulations.
- Placards on the truck/trailer are not required.
- Label must be on at least two sides of the unit.
- One label must be visible without unloading the unit.
- Must be transported on an open flatbed trailer, open flatbed rail car, or a well-ventilated closed transport vehicle.
- No air or water transport.
Industry Advocacy
The HVAC industry is actively urging the Office of the Secretary of Transportation (ODOT) to adopt these rules in the Code of Federal Register, which would potentially render these permits obsolete.
Labeling
The label that must be applied to each unit should be 100mm (3.9”) on each side.
Disclaimer
This communication is provided for informational purposes only and does not constitute legal advice. The content presented herein represents AAON’s best interpretation of the current permit requirements for A2L refrigerants as of December 21, 2023. The information contained in this communication is subject to change, and we recommend consulting with legal professionals or relevant authorities for precise and up-to-date guidance on A2L shipping requirements. AAON assumes no liability for the accuracy or completeness of the information provided in this communication. Users are encouraged to independently verify and seek legal advice for their specific circumstances.
International Shipping
The information pertains specifically to shipments within the United States. Shipping outside of the U.S., including Canada, may be subject to different rules. Developments are monitored, and updates will be provided as more information becomes available.