A scientific review of the research on the safety aspects of the use of refrigerant R1234yf in Mobile Air Conditioning (MAC) systems, published on 7 March by the European Commission, concluded that there is no evidence of a serious risk under normal and foreseeable conditions of use, as outlined by existing legal framework on the general safety of products . The review reinforces the conclusions by the German market surveillance authorities the KBA (Kraftfahrt Bundesamt), which stated that there is no sufficient supporting evidence of a serious risk that would entail the intervention of the authorities.
The review of the 2013 KBA testing procedures was conducted as a confidence-building measure that the Commission had proposed to the Member-States. The JRC reviewed the testing procedures in an open and transparent way, involving all stakeholders. The testing procedure entails Level 1 and 2 (crash test and refrigerant release tests), as well as Level 3 (release of refrigerant under more extreme conditions.
Following this consultation process, the JRC completed its final report with the following conclusions:
- Regarding the general approach to the testing by KBA, the report acknowledges that there is no "Standard" or "Regulatory" testing procedure available for the purpose. Therefore the KBA has legitimately used the experts' judgments and engineering judgments for selecting the test conditions.
- Regarding the pre-tests that the KBA carried out to determine the desired test temperature for the refrigerant release tests, the testing of the vehicles followed the objective to reach the highest possible temperatures. The derived scenarios were extreme, but justifiable and reasonable ones, covering urban, extra-urban and highway driving conditions, and fully justified within the scope of the vehicle testing for the purpose of product safety investigations.
- Regarding the crash tests, the JRC considered that the approach taken by the KBA was justified.
- Regarding the Level 1 and Level 2 tests, the KBA concluded that "results do not provide sufficient supporting evidence of a serious risk within the meaning of the Product Safety Act (ProdSG) with the vehicle types tested hereto warrant the taking of any immediate measures by the KBA pursuant to that Act". The JRC underlined that these tests showed no ignition of refrigerants and very low hydrogen fluoride (HF) release despite the very high temperatures in the engine compartment. Consequently the results as such with the vehicles tested under the conditions as described provided no evidence of a serious risk. The JRC hence supports the evaluation of the KBA that there were no grounds for the authorities to take measures under the European general product safety legislation. Therefore, according to this legislation, the products tested have to be considered safe products.
- Finally, regarding the refrigerant release tests under Level 3, these were not taken into account by KBA as relevant input "for the assessment of a possible risk within the scope of the statutory tasks as product safety authority". This approach is supported by the JRC. One driving force behind the tests carried out under Level 3 is exploring what could happen under assumed extreme conditions not yet covered in Level 1 and Level 2 testing. The research character is also confirmed by going beyond the boundaries and limitations set for Level 1 and Level 2 tests, to verify if the worst case was chosen in the test setup, and considering in Level 3 also the "development of engines which can be expected for the future". Whilst Level 1 and Level 2 tests were realistic and were considered by KBA for their conclusions on risks with respect to the product safety regulations, the Level 3 tests could not be associated with the necessary concrete probability of occurrence, but serve as a general appraisal of the risk. Compared to the scenarios for the realistic Level 1 and Level 2 testing, the probability of Level 3 scenarios must be assumed to be far lower, and not reflecting "normal or reasonably foreseeable conditions of use" under which the General Product Safety Directive 2001/95/EC applies.
- Although not being part of the working group's mandate, during the meetings some measures to further improve MAC safety were presented. Examples such as release valves in MAC circuits, fire extinguisher, reduction of hot surfaces (thermal insulation) and additional ventilation were discussed in different occasions during the working group meetings.
This assessment reaffirms the position of the Commission that the automotive manufacturers have the means to mitigate the inherent risks of the use of the refrigerant, which are known and have been studied. The refrigerant is not the only fluid used in vehicles that is flammable or that may cause formation of dangerous emissions when burning. To provide for safe products, the automotive manufacturers have found ways to mitigate these risks in a way consistent with a high level of protection for the safety and health of persons.
The process involved the analysis by the JRC of the report by KBA but also of other tests and analysis related to the use of the refrigerant. Three meetings were held, open to all interested stakeholders. All documents presented and debated in these meeting are available in the Commission's dedicated webpage .