Understanding EPA Refrigerant Regulations
In 2016, the EPA proposed an amendment to its existing National Recycling and Emission Reduction Program, more commonly known as Section 608, including tightening the allowable leak rate thresholds, requiring more accountability on the part of contractors and technicians, increasing the frequency of system inspection, and expanding the number of refrigerants that are regulated.
How to Understand Government Laws for Refrigerant Gases (R-22 HCFCs) Management, Tracking, and Reporting
In the United States, the Environmental Protection Agency (EPA) has set strict standards for regulating and monitoring a refrigerant leak. The Montreal Protocol and Kyoto Protocols were both created to establish similar environmental standards internationally. These regulations include protocols for repairing refrigerant leaks or disposing of systems within a certain timeframe.
Refrigerant gases are those used in climate control in commercial and business facilities such as warehouses, stores and office buildings. The refrigerants used in commercial heating, ventilating and air conditioning (HVAC) or regular air conditioning (AC) units include hydrofluorocarbons (HCFCs), chlorofluorocarbon (CFCs) and perfluorocarbon (PFCs).
Hydrofluorocarbons (HCFCs), perfluorocarbons (PFCs), and chlorofluorocarbons (CFCs) are destructive Greenhouse Gases (GHGs) as well as harmful to the upper ozone layer. HCFCs do not have any of the organic chemicals chlorine or bromine, but they still do have a possibility of causing ozone depletion.
These refrigerant gases are not only considered Ozone Depleting Substances (ODS) but many of them also have very high Global Warming Potential ratios which results in their detailed tracking, monitoring, and reporting related to their Global Warming effects.
While perfluorocarbons do not contribute to the depletion of the ozone layer, scientists worry that PFCs can contribute to global warming since they have a very high global warming potential (GWP). GWP is a ratio developed to determine which chemical substances and refrigerant gases released into the atmosphere create more warming. The most common greenhouse gas (GHG) talked about the most often is carbon dioxide (CO2) or just carbon for short.
CFCs have been used since the early 1930s and were found to deplete ozone in the 1970s. A chemical reaction caused by ultraviolet (UV) radiation breaks off the chlorine atom in CFCs. This chlorine atom binds with oxygen already in the atmosphere. The depletion of the ozone is the result of chemical reactions where chlorine and oxygen are split apart.
Refrigerant Management for Environmental Safety
Refrigerant management and knowing, down to the pound level where all refrigerant gases reside, is critical for the safety of the environment and to limit the release of Greenhouse Gases (GHG). The result of refrigerant emissions is either ozone destruction or increased Global Warming, both contributing to climate change.
EPA inspectors, governmental regulators, as well as many state officials are responsible for monitoring commercial AC and HVAC systems. They can conduct spot checks of the refrigerant service records, purchase orders, transit logs of gas transport for destruction, as well as many other pieces of data related to refrigerant gas management.
The refrigerant gas management laws were revised in 2009. The new regulations have specifications for system owners and service technicians to more accurately track leaks and to ensure recycle, recovered, or virgin refrigerants are documented correctly.
Due to the connection between refrigerant gases and their effect on climate change, many legislative bodies including various US states and the EPA have stepped up and increased the detailed refrigerant reporting requirements.
The U.S. Clean Air Act (Section 608) has technical specifications and certification requirements for AC or HVAC service technicians. In most cases, technicians must be EPA certified before working on systems containing refrigerant gas.
The EPA has detailed regulations on the purchase of refrigerant gas. For the most part, service technicians must be certified to even purchase gas in cylinders as small as 20 pounds. Nobody can buy any amount of refrigerant unless they are certified.
The U.S. Environmental Protection Agency (EPA) has four certification classes. Type 1 is for small appliances. Type 2 is for high and very high pressure. Type 3 is a low pressure certification. Type 4 EPA certification is universal, meaning technicians can work on a variety of AC/HVAC systems of different pressures and gas types. Any technician with a particular certification type can only fix or recover equipment that is specified for the certification type.
Becoming effective in 2010, new legislation starting in California will have strict requirements on the monitoring and tracking of refrigerant gases. In some cases, AC/HVAC systems containing 50 pounds of refrigerant will be required to keep service records, history of all gas purchases and sales, and to submit refrigerant usage reports to regulators annually.
AC/HVAC systems above 2,000 pounds will be required to have automatic leak detection systems and monitoring. This will result in more specific reporting and system registrations.
For service technicians and those who own or operate AC and HVAC systems containing refrigerant gas, it is required by law to monitor, manage, and report refrigerant usage for every system in operation.