News & Updates

On November 12^th, 2024, the Board of Building Regulations and Standards (“BBRS”) issued an advisory document pertaining to HVAC equipment utilizing A2L refrigerants. The document reiterates that the published version of the 10th edition code did adopt the latest referenced standards pertaining to A2Ls, including ASHRAE 15 and 34 2022, as well as UL/CSA 60335-2-40 2022, but admits that there are still conflicts between these standards and certain provisions of IMC 2021, which BBRS is working through (referring to the remaining DXS code change proposals still making their way through the process).
 
However, BBRS then advises that HVAC installations abiding by these updated standards, including ASHRAE 15 2022, are approvable by inspectors pursuant to 780 CMR 104.11. The document concludes with this statement: “BBRS is of the opinion that equipment utilizing A2L refrigerants when installed in compliance with the updated safety and design standards, is legal and appropriate for installation in Massachusetts based upon the 10th Edition Building Code”.
 
This advisory document is key to the progression of A2L adoption in Massachusetts, allowing designers to use the latest and safest language surrounding A2Ls, which is ASHRAE 15. This solves key conflicts with IMC 2021, such as R-32 and R-454B being classified as A2 refrigerants, the dated language requiring ventilated shafts, the lack of proper formulas for EDVC quantities, and more. This compliance path will eventually be officially written into the 10^th Edition Building Code as an amendment to Chapter 28, but in the meantime, this advisory document allows project teams to begin designing with A2L refrigerants. Note that the 9^th Edition Building Code, based on IMC 2015 and ASHRAE 15 2013, remains an issue for HVAC equipment of all types using A2L refrigerants.

The tenth edition building code was filed with the Secretary of State on Tuesday, September 24, 2024, and became effective on October 11, 2024. Concurrency with the 9^th Edition of the Building Code has been extended until June 30^th, 2025. However, the 9th Edition, being based on IMC 2015 and ASHRAE 15 2013, does not have references or allowances for A2L refrigerants. Projects wishing to use HVAC equipment with A2L refrigerants will need to adhere to the 10^th Edition Building Code or attempt to petition BBRS under a 9^th Edition compliance.

Consistent with our commitment to decarbonize buildings with high-efficiency heat pumps, ventilation, and automation, DXS Service is also committed to supporting the circular economy of refrigerants. Transitioning to lower GWP refrigerants such as R-32 is key for new systems moving forward, however, there are millions of pounds of R-410A refrigerant currently sitting in HVAC equipment on existing buildings across North America. One of the most important steps that we can take as an HVAC industry to reduce emissions from refrigerants, is to ensure that as many of those pounds of R-410A get properly removed from the field (at end of life or during repairs) and taken to certified reclaim facilities. Doing so properly prevents that refrigerant from being leaked into our atmosphere, but it also reduces the amount of new virgin refrigerant that must be manufactured, and the energy and emissions required to do so.

On July 9^th 2024, BBRS voted in favor of the remaining 6 of 8 DXS code change proposals submitted in March (see previous news segments below). As a result, BBRS has now voted in favor of all DXS code change proposals, almost in their entirety, with only a few modifications. Below is an overview of the accepted proposals:

On March 27^th 2024, BBRS passed a motion to accept one of the DXS code change proposals to the 10^th edition code, and to adopt the 2022 version of ASHRAE 15. The 10th Edition code will now have an MA Amendment to update the referenced standard of ASHRAE 15 from 2019 to 2022. This is a big step towards the adoption of lower GWP A2L refrigerants in the State of Massachusetts. This does result in conflicts between the adopted ASHRAE 15 standard (2022) and the language in IMC (2021). ASHRAE 15 2022 has the latest and most recent published language surrounding refrigerants, but due to model code cycles, there is often a lag in language adoption. IMC 2024 has updated and resolved some of these conflicts, but conflicts still exist, and more updates are expected to be adopted by IMC 2027.

On March 6^th HTS/DXS submitted a total of eight (8) code change proposals to the 10^th edition code, amending six (6) sections of IMC 2021’s Chapter 11 on refrigeration as well as two (2) referenced standards in Chapter 15. The proposed changes would allow ASHRAE 15 to be followed exclusively in lieu of Chapter 11 of IMC 2021, and with the referenced version of the standard being updated to 2022, this would allow the State of Massachusetts to use the latest published language surrounding A2L refrigerants. Other changes also update different key sections of IMC 2021 Chapter 11, bringing the language up to IMC 2024 or ASHRAE 15 2022. HTS/DXS is looking for letters of support from the industry to BBRS for these code change proposals.

On Wednesday, February 14^th, JS Rancourt (Principal, HTS New England, DXS New England, and DXS Ontario) testified in front of BBRS in preparation for the submission of a long list of code change proposals to the 10^th edition code surrounding the adoption of A2Ls. As the only testimony of the day on the topic of refrigerants, the request for attention to this topic was well received, and BBRS suggested that HTS/DXS take the lead in aligning the industry on the required language updates.