July 2018 - Top 5 Things Facility Managers Should Know About New Refrigerant Management Requirements

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Managing refrigerant and refrigeration systems can be a challenge for facilities and facility managers due in part to expanding regulatory requirements.  Section 608 (Refrigerant Management Requirements) of the Clean Air Act was updated to expand requirements for managing ozone-depleting substance (ODS) refrigerants to now also include ODS substitutes.  ODS substitutes which are now regulated include hydrofluorocarbons (HFCs) (e.g., R-410A, R-407C and R-134a), perfluorocarbons (PFCs) (e.g., R-116), and hydrofluoro-olefins (HFOs) (e.g., 1234YF).  These are collectively referred to as “non-exempt ODS substitutes.” 


New Requirements Become Effective January 2019

Additional regulatory requirements related to ODS and non-exempt ODS substitutes will become effective in January 2019 that include more stringent requirements for repairing leaks in larger appliances, including lower leak rate thresholds that trigger repair requirements and new reporting, recordkeeping, and inspection requirements.  Here are the top five things all facility managers should be aware of related to these new requirements.

1.       Expanded Training Requirements.  The update rules revised the EPA Section 608 Technician Certification Exam to now cover knowledge of ODS substitutes; however, the rule does not change certification requirements for currently certified technicians.  As of January 1, 2018, only certified technicians may purchase ODS substitutes or open/service appliances containing non-exempt ODS substitutes.  Technicians must handle non-exempt ODS substitute refrigerants and appliances containing them in the same manner that they now handle ODS refrigerants.

2.       New Recordkeeping Requirements for Refrigerant Disposal.  Technicians are now required to keep the following records for the disposal of appliances containing between 5 to 50 pounds of ODS or non-exempt ODS-substitute refrigerant.  These records must be maintained by the technician and not the owner or operator of the appliance.

  • Company name, location of the appliance, date of recovery, and type of refrigerant recovered for each disposed appliance.

  • Quantity of refrigerant (by type) recovered from all disposed appliances in each calendar month.

  • Quantity of refrigerant (by type) transferred for reclamation and/or destruction, the person to whom it was transferred, and the date of the transfer.

  • 3. More Stringent Leak Detection Requirements. Starting January 1, 2019, quarterly/annual leak inspections or continuous monitoring devices are required for refrigeration and air-conditioning equipment that have exceeded the threshold leak rate, until the leak has been corrected. Owners/operators must identify and repair leaks within 30 days of when the ODS or non-exempt ODS substitute refrigerant is added if the calculated leak rate exceeds:


  • 30% for industrial process refrigeration (previously 35%),

  • 20% for commercial refrigeration (previously 35%), and

  • 10% for comfort cooling (previously 15%)

  • 4. New Leak Reporting Requirements. Beginning January 1, 2019, owners/operators are required to submit reports to EPA if systems containing greater than or equal to 50 pounds of ODS or non-exempt ODS-substitute refrigerant leak 125 percent or more of their full charge in one calendar year. Reports are due by March 1 the following year.

 5.       New Recordkeeping Requirements for ODS Substitutes.  Starting January 1, 2019, service records and leak rate calculations that formerly applied to refrigeration units containing 50 pounds or more of Class I and Class II ODSs have been expanded to include units that contain non-exempt ODS substitutes. 

It is important to note that not all ODS substitutes are affected by these changes.  A handful of refrigerants are exempt, depending on their end-use application.  The table below provides an overview of the exempt refrigerants and end-uses.

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As a facility manager, one of the most important things you can do to achieve and verify your compliance with Section 608 is to maintain all records related to your refrigerant management program, including the following:

  • Inventory of all appliances containing refrigerant, including the refrigerant name/type and full charge amount.

  • Service and maintenance records, including refrigerant added/removed and leak detections/calculations for each event.

Please feel free to contact John Ribar, P.E. (JohnR@phe.com) or Brian Whipple, P.E. (BrianW@phe.com) if you have questions about environmental compliance at your facility.