New EPA Rules

On September 26, 2016 the EPA issued a new Final Ruling updating the regulations for handling refrigerants. Don’t panic, there is plenty of time to prepare. For technicians, the first important enforcement date is not until January 1, 2018 and some parts do not take effect until January 1, 2019. However, you do need to prepare. There are more changes than I can list in a short blog post, but I will provide an overview and plenty of links to the information.

Mostly about Global Warming
Most of the changes have to do with limiting global warming by reducing the use and release of HFC refrigerants. Some of the more significant changes include requiring certification to purchase and handle HFC refrigerants, reducing the allowable leak rate for ozone depleting and global warming refrigerants, specifying regular leak inspection for equipment which has exceeded the allowable leak rate, and requiring record keeping when disposing of systems with more than 5 pounds of refrigerant.

Technician Certification
Staring January 1, 2018 technicians must be certified to purchase and handle nearly all refrigerants, not just ozone depleting ones. One curious exception is that sales of small cans of refrigerant for use in car air conditioning systems will not require certification. The cans will be required to have a valve, but sales to the general public will still be allowed.

Leak Rates Lowered
Starting January 1, 2019, the leak rates will all be lowered and will apply to HFC and replacement refrigerants as well as ozone depleting refrigerants. A few specific refrigerants are exempted from the venting prohibition and the leak requirements. These exempted refrigerants include carbon dioxide, nitrogen, water, ammonia, chlorine, hydrocarbons, and R441A. The leak trigger rates which require repair are now 30% for industrial process refrigeration, 20% for commercial refrigeration, and 10% for air conditioning and “other” uses. Note that the refrigerant charge level for these trigger rates remains at 50 pounds or more.

Leak Inspection
Beginning January 1, 2019, the new rules require regular leak inspection for systems that have reached the “trigger rate” requiring leak repair. The frequency of the required inspections is determined by the type of system and the size of the system charge. Quarterly inspections are required for commercial refrigeration and industrial process cooling systems which hold 500 pounds or more refrigerant. Commercial refrigeration and industrial process cooling systems holding at least 50 pounds of refrigerant but less than 500 pounds require an annual leak inspection. Air conditioning systems holding at least 50 pounds require annual leak inspections. When leaks are repaired, an initial system tightness verification is required before adding refrigerant. A second system tightness verification is required after the system is up and operating. Records of all of these tests are required.

System Disposal Record Keeping
Starting January 1, 2018 technicians disposing of systems with at least 5 pounds of refrigerant must keep records regarding the equipment and the refrigerant charge. Specifically, you must keep
The location, date of recovery, and type of refrigerant recovered for each disposed appliance
The quantity of refrigerant, by type, recovered from disposed appliances in each calendar month;
The quantity of refrigerant, and type, transferred for reclamation or destruction, the person to whom it
was transferred, and the date of the transfer. Note that you are not required to report the quantity of refrigerant recovered from each individual system, but rather, the cumulative quantity of refrigerant recovered each month.

Links to EPA Documents
This is just an overview. To really understand all the details you should consult the information published by the EPA. Here is a list of links to some of that information.

Advance Copy of Final Rule
https://www.epa.gov/sites/production/files/2016-09/documents/608_final_rule_pre-publication_copy.pdf

Subpart F—Recycling and Emissions Reduction
http://www.ecfr.gov/cgi-bin/text-idx?SID=085a41355598f2919b6655098a466757&mc=true&node=sp40.21.82.f&rgn=div6

Fact Sheet on New Regulations
https://www.epa.gov/sites/production/files/2016-09/documents/608_fact_sheet_technicians_0.pdf

EPA Page on Revised Regulations
https://www.epa.gov/section608/revised-section-608-refrigerant-management-regulations

EPA page on leak requirements
https://www.epa.gov/section608/stationary-refrigeration-leak-repair-requirements