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EPA Updates to the Refrigerant Management Regulations

EPA has updated the refrigeration management regulations of 40 CFR Part 82 – Section 608, that became effective on January 1, 2017. Previously exempt refrigeration and comfort cooling appliances containing greater than 50 pounds of refrigerant substitutes like hydrofluorocarbons (HFCs), hydrofluoroolefins (HFOs), perfluorocarbons (PFCs), and R-134a are now subject to this regulation. Section 608 of the Clean Air Act deals with the safe handling of refrigerants during the maintenance, repair, or disposal of refrigeration and comfort cooling equipment.

Starting January 1, 2017:

Facilities are required to track equipment containing any type of refrigerant at greater than 50 pounds, including previously-exempt substitute refrigerants (e.g., HFCs, HFOs, PFCs, R-134a).

Only certified technicians can conduct leak inspections and repairs and purchase refrigerants, including substitute refrigerants like HFCs.

Starting January 1, 2018:

Technicians at facilities are required to keep copies of their certificates on-site (until three years after no longer operating as a technician). Certification exams for technicians will be updated to include the revised regulation.

Facilities will be subject to new recordkeeping requirements for disposing of appliances with a charge size between 5 to 50 pounds. Appliance disposal rules have been revised to include substitute refrigerants such as HFCs.

Starting January 1, 2019:

Revised Leak Rate Thresholds

Facilities with industrial process refrigeration (IPR), commercial refrigeration, and comfort cooling containing ≥ 50 pounds refrigerant will be subject to more stringent leak rate thresholds that when exceeded will trigger equipment repair:

  • 30% for (IPR) – lowered from 35%
  • 20% for commercial refrigeration appliances – lowered from 35%, and
  • 10% for comfort cooling and other appliances – lowered from 15%.

Initial and Follow-up Verification Tests for Leak Repairs

Facilities with refrigeration and comfort cooling will be subject to initial and follow-up verification tests for leak repairs, including:

  • Periodic leak inspections (excludes appliances with automatic leak detectors) by certified technicians if leak rate thresholds have been exceeded (until leak rate does not exceed 10% for one year);
    • commercial refrigeration and IPR:
      • every 3 months for systems containing ≥ 500 pounds refrigerant,
      • annually for systems containing 50-500 pounds refrigerant,
    • comfort cooling units containing ≥ 50 pounds refrigerants.
  • Reporting to EPA for appliances exceeding 125% of leak rate threshold for systems containing 50 pounds or more of refrigerant (due March 1 of following year, after event occurs);

Recordkeeping Requirements

Facilities are required to maintain records of the following:

  • Invoices of services performed – adding or removing refrigerant from appliances, leak inspections, waste refrigerant sent off-site, etc.;
  • Documentation of full charge of appliances;
  • Annual calibration of automatic leak detection systems, if applicable;
  • Any report of requests for extensions (to repair/retrofit deadlines) submitted to EPA;
  • Results of leak inspections and verification tests;
  • Records of appliance disposal (includes HFC appliances) and refrigerant recovered for appliances with a charge size of 5-50 pounds, should be maintained by technicians on-site;
  • Invoices of purchases of CFCs, HCFCs, HFC, and substitute refrigerants made by certified technicians at the facility.

Revisions to the rule also affect refrigerant distributors, reclaimers, small appliance recyclers, property managers and supermarkets.

To find out how your facility may be affected, please visit:

On August 10, 2017, EPA published a letter indicating plans to revise the final rule with respect to non-exempt substitutes and providing relief options from the January 1, 2018 compliance deadline (given that sufficient information is received supporting the basis for the relief).

To view the letter, click:

EPS Assistance: If you are a current client of EPS, we will be contacting you shortly to discuss how the new rules affect your operations. If you are not a current client of EPS and would like our assistance, please call us at (404) 315-9113.

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