Environmental Protection Agency (EPA) Refrigerant Management Changes On The Way Reply

Section 608 of the Clean Air Act requires EPA to develop programs that protect the stratospheric ozone layer and prohibits the knowing release of ozone-depleting substances (ODS) and substitute refrigerants during the course of maintaining, servicing, repairing, or disposing of appliances or industrial process refrigeration. On November 9, 2015, EPA published a proposed rule to amend these refrigerant management program regulations.

Here is a brief summary of the changes EPA has proposed.

  • Extend the regulations to cover substitute refrigerants to non-ozone-depleting substitute refrigerants, including but not limited to hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs).
  • Strengthen the requirements to repair leaking appliances containing 50 or more pounds of refrigerant by lowering applicable leak rates for
    • industrial process and commercial refrigeration appliances from 35 percent to 20 percent, and
    • comfort cooling appliances from 15 percent 10 percent
  • Require regular leak inspections or continuous monitoring of refrigeration and air conditioning systems including:
    • annual inspections for systems normally containing 50 pounds or more of refrigerant
    • quarterly inspections for commercial refrigeration and industrial systems normally containing 500 pounds or more of refrigerant
  •  Extend the current sales restriction on ODS refrigerants to substitute refrigerants with the exception of small cans (two pounds or less) of motor vehicle air conditioning (MVAC) refrigerant
  • Prohibit operation of systems normally containing 50 pounds or more of refrigerant that have leaked 75% or more of their full charge for two consecutive years.
  • Extend current recordkeeping requirements for appliances with less than 5 pounds and more than 50 pounds of refrigerant to appliances containing between 5 and 50 pounds of ODS and non-ODS substitute refrigerants. The change will require all technicians to keep records of the amount of ODS and substitute refrigerant recovered when disposing of all appliances.
  • Update the Technician Certification Program to require certification for servicing appliances containing non-exempt substitutes and also require certifying organizations to publish lists or online databases of technicians that have been certified.

EPA is proposing that most of the final rule become effective on January 1, 2017 but recognizes that for certain requirements, stakeholders will need additional time to comply. Therefore, EPA is proposing compliance dates from one year to 18 months after publication of the final rule for appliance maintenance and leak repair requirements.

If you own, operate, or use refrigeration contractors to service your industrial refrigeration or comfort cooling equipment, be aware that these changes may impact you, your facility, your equipment, and your regulatory reporting obligations.

For more information or if you seek assistance, please contact Bob King, CIH, CSP, at 508-970-0033 ext. 113 or bking@capaccio.com.

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