Aerosols
Contractors must minimize the use of high global warming potential hydrofluorocarbons in aerosols by using feasible alternatives identified through the EPA's SNAP program.
Overview
FAR 52.223-20, "Aerosols," requires contractors to minimize the use, release, or emissions of high global warming potential (GWP) hydrofluorocarbons (HFCs) in aerosol propellants or solvents when feasible. Contractors must consider environmental, technical, and economic factors when evaluating alternatives to high-GWP HFCs, such as emission rates, energy efficiency, safety, technical performance, and commercial availability. The clause directs contractors to consult the EPA’s Significant New Alternatives Policy (SNAP) program for approved alternatives with lower GWP. This regulation supports federal sustainability goals by reducing greenhouse gas emissions associated with government contracts involving aerosols.
Key Rules
- Minimize High-GWP HFC Use
- Contractors must reduce the use, release, or emissions of high-GWP HFCs in aerosols when feasible.
- Feasibility Assessment
- Contractors must consider environmental, technical, and economic factors when selecting alternatives.
- Reference EPA SNAP Program
- Contractors are required to use the EPA’s SNAP program to identify acceptable alternatives with lower GWP.
Responsibilities
- Contracting Officers: Ensure inclusion of this clause in applicable contracts and verify contractor compliance.
- Contractors: Assess and implement feasible alternatives to high-GWP HFCs, document decision-making, and refer to the SNAP program.
- Agencies: Oversee compliance and support sustainability objectives.
Practical Implications
- This clause aims to reduce the environmental impact of federal procurement by limiting greenhouse gas emissions from aerosols.
- Contractors must stay informed about SNAP-approved alternatives and be prepared to justify their choices based on feasibility.
- Common pitfalls include failing to consult the SNAP list or not adequately considering all feasibility factors.