Communities for Sustainable Heating and Cooling

EPA/MA Regulatory Conflict on Heat Pump Refrigerants

by John Borger

“First do no harm.” This applies not only to medical interventions but to heat pump refrigerants as well, given the occasional leakage of these substances during handling and equipment malfunctions. Accordingly, the EPA evaluates refrigerant gasses on an ongoing basis, seeking the optimal trade-off among criteria like effectiveness, cost, availability and relative contribution to cumulative greenhouse gasses and ozone layer depletion. The EPA is currently phasing out widely used hydrofluorocarbon (HFC) refrigerants like R-410A because they are about 1,000 times more potent than carbon dioxide as a warming agent. As of January 2026, the sale or installation of HVAC equipment using R-410A will be prohibited by the EPA. 

In response, heat pump manufacturers are switching to other refrigerants allowed by the EPA, including those with a safety classification of A2L such as R-32, which have low toxicity, low global warming potential (GWP), and are mildly flammable but safe when handled by qualified professionals. The problem is that these A2L alternatives are not allowed under current Massachusetts building codes because they are flammable, professional handling notwithstanding.

The Massachusetts State Legislature ended its 2023 – 2024 session without passing a climate omnibus bill. This legislation was supposed to include a temporary workaround to permit A2L refrigerants in homes and buildings until building codes could be updated to allow their use.

The HeatSmart Alliance October Update to Installers calls attention to this quandary and urges installers to contact their elected representatives about the effect that failing to pass a workaround to permit A2L will have on their businesses. 

In mid-October, Commonwealth lawmakers announced a “deal on stalled Clean Energy Bill.” According to Senator Michael Barrett of Lexington,  the agreement includes “some very important housekeeping details around heat pumps.” Those “housekeeping details” presumably will include the needed temporary workaround on refrigerants. As of this writing, no further details are available. But watch the news for updates and, if no action is taken, we will note that in a future post. 

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