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Mechanical code edits proposed to align refrigerant rules with ASHRAE 15; council to refine A3 options
Summary
Staff proposed edits to mechanical code refrigerant sections to match ASHRAE 15 (2024) and presented four options for handling A3 (flammable) refrigerant installations, including a research/demo pathway, jurisdictional approval limits, or making language optional via a separate appendix.
Council staff presented proposed mechanical‑code amendments intended to align section 11.04.3.2 with the latest ASHRAE 15 (2024) language and to address public comments on A2/A3 refrigerants.
"Basically, what the proposed change does is, align the language with that, ASHRAE 15 appendix j section," Ben said, describing editorial updates and reorganization of exceptions into allowable compliance pathways. The changes include updated references and a clarification that some exceptions apply to machinery rooms or to equipment installed outdoors.
On the topic of A3 (flammable) refrigerants, Ben presented four response options pulled from public comment: preserve the original proposal with rewritten exceptions; limit certain compliance pathways to research and demonstration use; require jurisdictional approval ("where approved") for exceptions; or place the approach in an optional appendix jurisdictions may adopt. Council members asked for input from fire‑code officials and other experts before deciding which path to take.
Staff noted a process constraint: the code reviser would not permit adding a new appendix within the current CR103 rulemaking package, so an optional appendix might require a different WAC approach. The council tasked staff to refine options, solicit fire‑safety input, and return with recommended language at a future meeting.
