3 EPA Section 608 Type I Requirements

When Type I certification applies

Type I certification covers technicians who maintain, service, or repair small appliances containing refrigerants subject to Section 608 requirements. Certification is required when the work could reasonably be expected to breach the refrigerant circuit. This can include connecting gauges or hoses, adding or removing refrigerant, replacing refrigerant-circuit components, or cutting refrigerant lines.

Routine work that does not affect the refrigerant circuit, such as rewiring an external electrical circuit, generally does not require technician certification. Certification is based on the appliance type, not simply on the refrigerant used.

A Type I credential is limited to small appliances and does not qualify a technician to service other Section 608 appliance categories. An apprentice may perform covered work before certification only while closely and continually supervised by a properly certified technician. There is a narrow disposal exception: certification is not required solely to recover refrigerant from a small appliance at disposal.

Which appliances qualify

To qualify as a small appliance under 40 CFR § 82.152, a device must be fully manufactured, charged, and hermetically sealed in a factory, and contain five pounds or less of refrigerant. All of these criteria matter; compact size or a charge of five pounds or less is not sufficient by itself.

Examples include:

• Household, commercial, and consumer refrigerators and freezers

• Medical or industrial research refrigeration equipment

• Room air conditioners, including window and portable units, and packaged terminal heat pumps

• Dehumidifiers

• Under-the-counter ice makers

• Vending machines

• Drinking-water coolers

Recovery before opening or disposal

Do not knowingly vent covered refrigerant during service or repair. Before opening a small appliance, use recovery and/or recycling equipment certified for the applicable use. The same requirement applies when recovering refrigerant before disposal.

Under 40 CFR § 82.156(b), the recovery or evacuation options depend on the recovery equipment's manufacture date and, for equipment manufactured on or after November 15, 1993, whether the compressor functions:

• Equipment manufactured before November 15, 1993: recover $80\%$ of the refrigerant.

• Equipment manufactured on or after November 15, 1993, with a functioning compressor: recover $90\%$.

• Equipment manufactured on or after November 15, 1993, with a nonfunctioning compressor: recover $80\%$.

• As an alternative, evacuate the appliance to $4$ inches of mercury vacuum.

For example, before opening a refrigerator that meets the small-appliance definition, a technician using equipment manufactured on or after November 15, 1993, may recover $90\%$ if the compressor functions or $80\%$ if it does not. The technician may instead evacuate the appliance to $4$ inches of mercury vacuum.

Use recovery equipment according to its manufacturer's instructions unless those instructions conflict with the regulation. EPA requires recovery equipment to meet applicable certification standards. Recovering refrigerant means removing it and storing it in an external container; this process alone does not necessarily clean or reclaim the refrigerant.