5 Refrigerant Compliance Practice

Identify the refrigerant and check its use

Start with the equipment’s nameplate and service history to identify both the appliance and its refrigerant. Do not guess at the refrigerant or mix refrigerants.

Next, check the rules for that specific refrigerant, equipment type, and end use. EPA’s SNAP listings apply to a particular substitute, the substance it replaces, and the end use. A listing that says a substitute is acceptable does not necessarily permit it in every application; confirm current restrictions and any applicable Technology Transitions requirements.

Also verify compatibility with the equipment and any safety conditions, including conditions related to flammability or toxicity. A general statement that a refrigerant is “EPA approved” is not enough to establish that it is permitted for the intended use.

Understand refrigerant phaseouts

Ozone-depleting substances (ODS), including CFCs and HCFCs, are being phased out under the Clean Air Act. Most new production and import of HCFCs in the United States had been phased out as of 2020, although some HCFC refrigerants remain in existing equipment.

Many HFC substitutes do not deplete ozone, but they can still affect climate. Environmental and regulatory checks therefore remain important even when a refrigerant is not ozone-depleting.

Confirm who may perform the work

Section 608 certification generally applies to technicians whose work could release refrigerant from stationary appliances. The certification type required depends on the equipment. Motor-vehicle air-conditioning work follows separate rules.

Connecting or disconnecting gauges and adding or removing refrigerant are covered technician activities. Do not assign an apprentice unsupervised refrigerant-circuit work. Apprentices may qualify for an exemption only when they are closely and continually supervised by a certified technician.

Protect people and prevent releases

Follow the equipment and refrigerant safety instructions, use suitable personal protective equipment and ventilation, and use recovery equipment and cylinders that are compatible and properly rated. Do not knowingly vent refrigerant during service or disposal, except for releases covered by a regulatory exception.

Recover refrigerant rather than intentionally releasing it when equipment is removed for disposal. Keep refrigerant types separate and make sure container labels clearly identify their contents. If a cylinder has no reliable contents label, do not add its refrigerant to a cylinder containing a known refrigerant based on color. Quarantine and identify the contents using an appropriate process, with a suitable cylinder and recovery procedure.

Route recovered refrigerant correctly

The terms describe different handling steps. Refrigerant recovery removes refrigerant into an external container. Refrigerant recycling cleans it for reuse in equipment of the same owner. Refrigerant reclamation processes it and verifies that it meets the required purity specification.

If recovered refrigerant changes ownership, it generally must be reclaimed by an EPA-certified reclaimer before resale. Refrigerant recovered from an appliance may generally be reused in another appliance owned by that same customer, subject to applicable requirements. Keep refrigerant types separate to avoid contamination and protect the recovery and reclamation path.

Keep the required disposal records

For disposal of a mid-sized appliance containing 5–50 pounds of refrigerant, the applicable Section 608 records include:

• The appliance’s location.

• The recovery date and refrigerant type.

• The quantity recovered from disposed appliances of each type during each calendar month.

• If refrigerant is transferred for reclamation or destruction, the type and quantity transferred, the recipient, and the transfer date.

For this disposal scenario, a record that says only “refrigerant recovered” is insufficient. The required records may be kept on paper or electronically and must be retained for three years.

Match service records to the job

A useful service entry can include the customer and service-site location; appliance type and identifying information; refrigerant type and amount recovered or added; recovery date and technician; recovery-cylinder identification and destination; and, for a transfer, the recipient, date, refrigerant type, and amount. Notes on leaks, repairs, verification, or unusual contamination may also be useful.

Not every item in this template is required for every appliance or job under federal rules. Determine which requirements apply to the equipment, refrigerant, work performed, and any disposal or transfer. State, local, workplace, and contract requirements may also add obligations. Keep records complete and legible, and make sure they match the specific job.

Apply the decision process

Before refrigerant work, identify the equipment and refrigerant, verify the current rules for the intended use, and confirm that the person doing the work is appropriately qualified. Protect people, prevent avoidable releases, and recover refrigerant into suitable containers. Route it for reuse or reclamation as allowed, then document the work according to the requirements that apply to that equipment and job.