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Complying with new refrigerant management requirements

Section 608 of the Clean Air Act was enacted to enforce the proper handling and management of refrigerant during maintenance, service, repair or disposal of air conditioning and refrigerant equipment. Last fall, the U.S. Environmental Protection Agency released a Final Rule that updated the agency’s Refrigeration Management Program. The updates took effect on January 1st, 2017. Learn what you need to do to ensure your company complies with the new regulations.

Rules extend to substitute refrigerants

The Final Rule expands the requirements of the Clean Air Act Section 608 to non-ozone depleting substitutes that are not exempt to the venting prohibition such as hydrofluorocarbons (HFCs). The EPA states HFCs are potent greenhouse gases that can have high global warming potential. The new rule outlines that recovered ozone-depleting substances (ODS) and substitute refrigerants can not be resold unless they have been reclaimed by a certified reclaimer or are charged into equipment belonging to the same owner. The sale of ODS and substitute refrigerant will be restricted to certified technicians starting January 1, 2018.

New technicians need new certifications

Starting January 1, 2018, new technicians must pass a certification exam to maintain, service, repair or dispose of appliances containing ODS or refrigerant substitutes. After passing the exam, they must keep a copy of the certificate at their place of business while actively practicing maintenance and for three years after no longer working as a technician. All current certified technicians will not need to recertify; they are exempt.

How to comply during maintenance and repairs

Starting January 1, 2018, technicians must evacuate ODS or substitute refrigerants before opening or disposing of appliances. As part of the new regulation, technicians who dispose of appliances containing 5 to 50 pounds of refrigerant must keep records of the following:

  • Location, date of recovery and type of refrigerant recovered
  • Quantity of refrigerant (by type) recovered from disposed appliances for each month
  • Quantity and type of refrigerant transferred for reclamation or destruction, the person to whom it was transferred and the dates of any transfers

Starting January 1, 2019, leak inspections will be required for all appliances that have exceeded their leak rate. Verification tests are required before and after repairs of appliances that exceed their applicable leak rate. Comfort cooling equipment that has 50 pounds or more of refrigerant must have a leak inspection once per year until the owner can demonstrate that the leak rate hasn’t exceeded 10 percent for one year. For commercial refrigeration and industrial process refrigeration (IPR) equipment containing 50 to 500 pounds of refrigeration, leak inspections must be conducted once per calendar year until the leak rate hasn’t exceeded 20 percent for commercial refrigeration or 30 percent for IPR for one year. Leak inspections must be conducted once every three months for commercial refrigeration and IPR equipment containing 500 or more pounds of refrigeration until the leak rate hasn’t exceeded 20 percent for commercial refrigeration or 30 percent for IPR for four quarters straight. The initial verification test must be performed before any additional refrigerant is added, and the follow-up test must be performed after the appliance has returned to normal operation. Technicians will be required to provide service invoices and records of the leak inspection results to the owner or operator of the equipment as verification.

The EPA estimates that the new regulations will prevent ozone damage by reducing emissions of ozone-depleting refrigerants by approximately 114 metric tons per year. See the full update here.

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