In order to achieve better consistency with the Clean Air Act, the U.S. EPA has modified its position regarding the phase-out of HCFC 225 (hydrochlorofluorocarbon 225, AK 225). Manufacturers can purchase and use HCFC 225 until the end of 2014, however, starting Jan. 1, 2015, they 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. 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. 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.
(From BFK Solutions’ September Clean Source newsletter)