Foams
Contractors must minimize the use and emissions of high global warming potential hydrofluorocarbons in foam blowing agents by using feasible alternatives identified through the EPA SNAP program.
Overview
FAR 52.223-21, "Foams," requires contractors to minimize the use, release, and emissions of high global warming potential (GWP) hydrofluorocarbons (HFCs) and HFC-containing refrigerant blends used as foam blowing agents, unless otherwise specified in the contract. Contractors must consider environmental, technical, and economic feasibility when selecting alternatives, referencing the EPA’s Significant New Alternatives Policy (SNAP) program for approved substitutes. The clause defines key terms such as global warming potential, high GWP HFCs, and hydrofluorocarbons, and directs contractors to use alternatives with lower environmental impact when feasible. This regulation supports federal sustainability goals by reducing greenhouse gas emissions associated with foam production and use in government contracts.
Key Rules
- Minimize Use of High GWP HFCs
- Contractors must reduce the use, release, and emissions of high GWP HFCs and related blends in foam blowing agents when feasible.
- Feasibility Considerations
- Contractors must evaluate alternatives based on emission rates, energy efficiency, safety, ability to meet performance requirements, and commercial availability at reasonable cost.
- Reference EPA SNAP Program
- Contractors are required to consult the EPA’s SNAP program to identify acceptable alternatives with lower global warming potential.
Responsibilities
- Contracting Officers: Ensure the clause is included 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 for guidance.
- Agencies: Oversee compliance and support sustainability objectives.
Practical Implications
- This clause exists to reduce the environmental impact of federal procurement by limiting greenhouse gas emissions from foam products.
- Contractors must stay informed about SNAP-approved alternatives and be prepared to justify their selection of foam blowing agents.
- Common pitfalls include failing to consult the SNAP list or neglecting to consider all feasibility factors, which could result in noncompliance.