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What Do You Know About The Tracking Of Refrigerant Usage And Recovery?

The Environmental Protection Agency, or EPA has issued a rule that updated the Clean Air Act. In particular, it impacted Section 608, which covers refrigerant management requirements. The rule was first published in the official Federal Register on the 18th of November in 2016. It went into effect just over a month later, on the first day of 2017. It extended the then-existing sales restrictions and requirements concerning ozone-depleting refrigerants. Limitations were placed regarding certain substitutes, and leak rate thresholds that would trigger repair requirements were lowered. It also established new requirements for record keeping, reporting, and inspections.

If your company services or even operates equipment containing refrigerants, then odds are good that this rule is going to impact you. So that you can be in compliance, keep reading to learn more about this rule.

Ozone-depleting substances are also known as ODSs. They’re typically chemicals of human origin. While they have many practical uses in technology and society, in the environment, they damage the ozone layer of the stratosphere. This layer is needed to shield life on Earth from the ultraviolet radiation of the sun. By the 1970s, there was genuine concern about ozone layer damage by ODSs in particular. This prompted international support for regulatory work to deal with such chemicals. Within the United States, the EPA handled regulations in 1993 that established the first refrigerant management program across the nation. The first requirements for refrigerant recovery equipment were created, and refrigerant sales were restricted so that only actually qualified technicians were allowed to buy it. Requirements were also put into place for all ODSs to be removed from appliances before they were disposed of. Also, repairs would be mandated if comfort cooling appliances exceeded 15 percent annual leak rates. Commercial refrigeration appliances were allowed a 35 percent annual leak rate. A number of regulatory updates were made from 1994 to 2014. Those included procedures for suspending or revoking approvals for certifying technicians or recycling equipment. Record keeping requirements were also revised.

Given the risks that ODSs present to the atmosphere above, and what it means for UV radiation hitting the surface, it became necessary to explore and develop a number of alternative refrigerants. Some hydrofluorocarbons, or HFCs, turned out to be common replacements. Regrettably, a number of the new HFCs presented issues of their own. Human health risks are among them, and they also have significant potential to contribute to global warming or climate change. The EPA saw a growing need for revisions to the regulatory requirements of refrigerant management so that the widespread use of these HFCs could be better handled, for the sake of both human safety and health, as well as environmental concerns.

So, what does this rule do? It establishes a new set of requirements for the appropriate use and handling of all HFCs or ODSs while harmonizing the requirements for refrigerant management across all the types. The rule also has provisions that impact owners and operators of appliances containing refrigerants as well as any technicians that service them.

Still, not everything about the new rule is actually new. Many of the previous requirements regarding moving away from ODSs to HFCs and other substitute refrigerants were left in place. However, some of the ODS rules are now extended to newer options. For instance, it used to be that with ODSs only, it was necessary to document any amount of refrigerant that was added or removed to an appliance. However, this documentation is now also mandatory for substitute refrigerants as well.

One big change is that the leak rate threshold at which repairs are triggered for equipment containing refrigerant are now lowered. Anything with 50 pounds of refrigerant or more are now impacted. Starting on the first day of 2019, owners and operators must identify and then repair a leak that exceeds 30 percent for any industrial process refrigeration. The previous level was 35 percent. The commercial refrigeration level drops from 35 to 20, and the comfort cooling level drops from 15 to 10. That’s all within the first 30 days of an ODS or substitute refrigerant getting added. A leak must get repaired so that the new leak rate is then under the applicable rate of acceptable leakage.

If you’re a technician that was certified prior to the start of 2018, you don’t have to face new certification requirements just yet. However, if you’re not certified prior to 2018, then you’ll have to pass an exam which now reflects the new rules and regulations. The certification program must be an approved one if you hope to do work involving the maintenance, service, repair, and disposal of appliances that have ODSs or any substitute refrigerants. Technicians need to keep a copy of their certifications within their place of business. That copy must be maintained for three years following the date they stop working as a technician.

It’s worth noting that while the rules were put into place to establish greater regulatory reach for many refrigerants that Section 608 did not previously address, there are also a number of various ODS substitutes that were specifically exempted. These include carbon dioxide, water, and nitrogen in all applications. Also, in specific appliances or attributions, exceptions were carved out for ammonia, hydrocarbons, isobutene, chlorine, propane (R-290), and ethane (R-170).

Any owning or operating equipment containing air conditioner refrigerant has to be in compliance with the obligations of this new rule, as does any applicable technician. However, having the proper tools in place will help you do so. Finding the right audit and inspection solution can be done through a third-party vendor or provider if you can’t do it yourself or would like help. In doing so, you can efficiently schedule and then track any leak-rate inspections done according to the rule. You can also manage all related follow-up activity, which might include necessary repairs to reduce known leak rates.

Being in compliance with all these new rules is not just a matter of avoiding fines, penalties, and potential suspension of licenses and certificates, but also a matter of helping out the planet.

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