Building Code Council adopts emergency amendment to 2021 code for A2L refrigerants

The Washington State Building Code Council on Oct. 17 voted to find an emergency basis and adopt an emergency amendment to the 2021 state building code that updates language governing the use of A2L (mildly flammable) refrigerants.

The change, proposed by Eric Vandermey of Delta E Consulting, incorporates clarifications in the ASHRAE 15 consensus standard (including Addendum A issued May 2025) to ease installation requirements for VRF and other heat pump systems that use A2L refrigerants. Council staff and the MVPE committee recommended the emergency finding and the amendment.

Council members and staff said the addenda provide important clarifications on the difference between continuous pipe and piping with fittings, information the council said is needed sooner than the regular code-adoption cycle. "The ASHRAE 15 changes ... have been providing more favorable interpretations and revised addenda on how to enforce the provisions for A2L refrigerants," Vandermey told the council. He and committee members described the clarifications as critical for cost-effective installation of VRF and similar systems.

The council first voted to establish an emergency basis under RCW rulemaking provisions. After a roll-call vote the council recorded that it had established the emergency basis and then moved to adopt the emergency amendment into the 2021 code. The motion to adopt was moved by Scott (recorded as "Scott Fosthuis" in the transcript) and seconded by Tom Handy; the council reported the final adoption vote as 10–0 in favor.

Why it matters: Council members said the ASHRAE addenda are being issued at a faster cadence than the council's code cycles and that Washington jurisdictions and industry are transitioning from A1 refrigerants to A2L refrigerants under EPA and Ecology phase-down requirements. The amendment is intended to reduce project delays and avoid costly installation burdens arising from older, more restrictive text.

What the amendment does: According to the proponent and committee summary, the amendment (a) incorporates ASHRAE 15 clarifications distinguishing continuous refrigerant tubing from piping with valves and components that raise leak probability, and (b) allows certain runs of continuous refrigerant tubing to be installed without the previously required vertical vented shafts when the tubing is continuous and pressure tested. The adopted emergency language targets sections of the 2021 mechanical and refrigerant-related provisions; the council noted the rest of the existing emergency rule remains in force unless changed in future filings.

Next steps: Staff indicated it will file the adopted emergency rule and manage required extensions until the permanent rulemaking pathway is complete. The council also noted that future permanent-rule or code-cycle work will reconcile the 2021 emergency language into later code editions.

Votes and motions recorded: The council first took a roll-call to establish emergency basis (two‑thirds threshold per RCW as interpreted by council counsel). The council then adopted the emergency amendment by recorded motion and roll-call; the transcript records the final adoption vote as 10 yes, 0 no (mover: Scott (recorded in the transcript as "Scott Fosthuis"); seconder: Tom Handy).

Attribution: Quotes are from meeting transcript and from proponents and council members present at the Oct. 17 meeting.