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Refrigerants Regulations Are Creating Confusion
#1
The Vessel Fire That Sparked a Bigger Question
A recent fire aboard a large fish processing vessel near Tacoma, Washington raised eyebrows not just for its scale, but for the reported presence of 19,000 pounds of refrigerant onboard. For many observers, this figure seemed staggering—especially considering how tightly regulated refrigerants like R-22 and R-134a have become in recent years. The incident triggered broader questions about environmental policy, regulatory inconsistencies, and the double standards between industrial and consumer applications.
Why Would a Ship Carry That Much Refrigerant
Large fishing vessels that double as processing platforms require massive refrigeration systems to preserve catch over extended voyages. These systems often span multiple compartments, blast freezers, and chilled storage bays. In such setups, refrigerant volumes can easily exceed 10,000 pounds, especially if the system uses older refrigerants like R-22 or R-12, which require higher charge volumes compared to modern alternatives.
Terminology note:
  • Refrigerant charge: The total amount of refrigerant required to fill a cooling system to operational capacity.
  • R-22 (chlorodifluoromethane): A hydrochlorofluorocarbon phased out in many countries due to ozone depletion potential.
The vessel in question likely had legacy systems installed decades ago. Retrofitting such systems to use newer refrigerants like R-410A or R-32 would require extensive redesign, new compressors, and re-piping—costing millions and risking operational downtime.
Regulatory Disparities Between Sectors
In the U.S., the Environmental Protection Agency (EPA) has restricted the sale and use of ozone-depleting refrigerants under the Clean Air Act. As of 2020, R-22 production and importation were banned, and purchasing it now requires Section 608 certification. Meanwhile, consumer products like refrigerators and cars have shifted to flammable but low-GWP (Global Warming Potential) refrigerants such as isobutane (R-600a) and R-1234yf.
Yet industrial and maritime sectors often operate under different rules. Ships registered in foreign jurisdictions may not be subject to U.S. environmental laws. Even domestically flagged vessels can be grandfathered into older standards if their systems predate regulatory changes.
Terminology note:
  • GWP (Global Warming Potential): A measure of how much heat a greenhouse gas traps in the atmosphere compared to CO₂.
  • Section 608 certification: A U.S. EPA requirement for technicians handling regulated refrigerants.
This regulatory patchwork creates confusion. A homeowner can’t buy a can of R-134a without certification, but a ship can carry thousands of pounds of R-22 across international waters.
The Risk of Flammable Refrigerants in Fires
Modern refrigerants like R-600a (isobutane) and R-290 (propane) are favored for their low environmental impact, but they are highly flammable. In a vessel fire scenario, their presence could dramatically increase explosion risk. Ironically, older refrigerants like R-22 are non-flammable, making them safer in fire-prone environments despite their environmental drawbacks.
One technician recalled working on a converted Navy tugboat that used R-22 in a large commercial system. The copper lines were nearly 2 inches in diameter, and the system required custom welding and rewiring to meet Coast Guard standards. The choice of R-22 was deliberate—it offered stability and performance in a marine setting where flammability was a serious concern.
Ammonia as an Alternative and Its Hazards
Some commercial refrigeration systems use ammonia (R-717), which is efficient and inexpensive but toxic and mildly flammable. Ammonia leaks pose serious health risks, and its use on ships is controversial. While ammonia is being explored as a fuel source for trucks and ships due to its carbon-free combustion, its volatility and corrosiveness make it a difficult candidate for widespread adoption.
Terminology note:
  • R-717 (ammonia): A natural refrigerant with zero ozone depletion and low GWP, but high toxicity.
  • ABYC (American Boat and Yacht Council): A standards organization for marine systems and safety.
In slaughterhouses and ice rinks, ammonia systems are common. But on ships, the risk of leaks in confined spaces makes it a less attractive option.
Environmental Ironies and Public Perception
The conversation around refrigerants often reveals deeper contradictions. While oil spills are treated as catastrophic, natural seepage of oil and tar from the earth is rarely discussed. Similarly, asphalt paving involves massive oil use, yet is considered routine. These inconsistencies fuel skepticism among industry veterans who feel that environmental policy sometimes lacks practical grounding.
One operator noted that while he’s always practiced responsible recycling, he’s frustrated by the demonization of oil and refrigerants without acknowledging their natural origins or industrial necessity.
Recommendations for Policy and Practice
To reduce confusion and improve safety:
  • Harmonize refrigerant regulations across sectors, including maritime and industrial
  • Encourage phased retrofits with financial incentives for legacy systems
  • Promote technician training on flammable refrigerants and emergency response
  • Require labeling and tracking of refrigerant volumes on commercial vessels
  • Develop fire suppression systems tailored to refrigerant hazards
Conclusion
The fire aboard the fishing vessel was more than a maritime incident—it exposed the tangled web of refrigerant regulation, environmental policy, and industrial practice. As technology evolves and climate goals intensify, clarity and consistency in refrigerant management will be essential. Until then, questions like “Why can a ship carry 19,000 pounds of R-22?” will continue to cause headaches—and rightly so.
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