Code Road Map: Addressing Federally Mandated A2L Refrigerants for Comfort Air with Older Adopted Codes
by David J. LeBlanc, P.E., FSFPE
New U.S. EPA refrigerant requirements are prompting major changes to the design and code compliance of HVAC systems in new commercial and residential buildings across the U.S. As of January 1, 2025, all newly manufactured HVAC equipment must use lower global warming potential (GWP) refrigerants – most practically, A2L refrigerants. While this shift supports climate goals, it also introduces new hazards (e.g. lower flammable refrigerants vs. previous non-flammable refrigerants), especially in jurisdictions still operating under older International Code Council (ICC) based codes that do not address the increased risks associated with A2L refrigerants.
This white paper explores how an Authority Having Jurisdiction (AHJ), architect, mechanical engineer, fire protection engineer, or code consultant can navigate the conflict between federally mandated refrigerant requirements and older base code adopted versions of the International Building, Mechanical, and Fire Codes (IBC, IMC, and IFC). It outlines a clear path forward using code modifications to address the practical difficulty of complying with outdated codes while meeting federal law and protecting life safety.
After reading this paper, you will:
- Understand the timeline and implications of the A2L refrigerant transition
- Learn why older editions of base codes fall short in addressing A2L hazards for comfort cooling applications
- Explore the increased hazards and risks introduced by A2L refrigerants and how the 2024 ICC codes and 2022 ASHRAE Standard 15 mitigate them
- Discover how to request and justify a code modification to bridge the gap between federal mandates and older base code editions
- Gain access to ICC-provided A2L code updates to support holistic solutions to the A2L issue
Read the white paper here.
David LeBlanc, PE, FSFPE, is a Vice President, Strategic Advisor with over 30 years of fire protection systems, design, and fire and life safety code consulting experience. He has extensive knowledge of building and fire codes and has…