Refrigerants: The next deadline approaches
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December 28, 2017
Refrigerants: The next deadline approaches
By Timothy P Fagan, Senior Legal Editor - EHS

The second of three compliance dates for the revised refrigerant management regulations under 40 CFR 82 is quickly approaching. Do you know how the new requirements going into effect on January 1, 2018, will impact your organization’s reliance on certified refrigerant technicians?

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The most significant change the Environmental Protection Agency (EPA) made to the federal refrigerant management requirements was to extend the regulations for ozone-depleting refrigerants to non-ozone-depleting substitutes through an amendment to the definition of “refrigerant.” The revised definition of refrigerant now reads “any substance, including blends and mixtures, consisting in part or whole of a Class I or Class II ozone-depleting substance (ODS) or substitute that is used for heat transfer purposes and provides a cooling effect.”

As of January 1, 2018, this revised refrigerant definition is applied to additional provisions within the refrigerant regulations. As a result, tasks that previously required certified technicians for ODS refrigerants, now also require certified technicians for substitute refrigerants.

So be sure you are using certified technicians when necessary, or you may be facing enforcement actions.

Who is a certified technician?

A refrigerant technician is any person who could reasonably be expected to release refrigerants (i.e., ODS and nonexempt substitute refrigerants) into the environment during maintenance, service, repair, or disposal of an appliance. Therefore, anyone who attaches or detaches hoses and gauges to and from the appliance, adds or removes refrigerants or components to or from the appliance, or cuts a refrigerant line is likely considered a refrigerant technician. All refrigerant technicians must be certified, which requires passing an exam offered by an EPA-approved technician certification program.

Increasing reliance on certified technicians

New recordkeeping requirements and the continuing phase-in of the revised definition of refrigerant expand the responsibilities of certified technicians in the following areas:

  • Purchasing restrictions. Up to this point, being a certified technician was only required for the purchase ODS refrigerants. However, as of January 1, 2018, the revised definition of refrigerant will be extended to the sales restriction on refrigerants, meaning that the sale of ODS refrigerants and any substitute refrigerant is restricted to certified technicians. So now all refrigerants, other than those specifically exempted under 40 CFR 82.154, must be purchased by a certified technician.
  • More appliances to service. A certified technician is now required to maintain, service, repair, or dispose of appliances containing substitute refrigerants in addition to those containing ODS refrigerants. All of the procedures and precautions that were taken to recover ODS refrigerants must now be employed to recover substitute refrigerants.
  • More records to keep. After January 1, 2018, certified technicians will be required to keep records pertaining to the disposal of mid-sized appliances (i.e., appliances with between 5 and 50 pounds of refrigerant), which they were not previously required to do. Under the new requirements, for each mid-sized appliance disposed, a certified technician must maintain records of the following for 3 years:  
    • The location, date of recovery, and type of refrigerant recovered for each disposed appliance;
    • The quantity of refrigerant, by type, recovered from disposed appliances in each calendar month; and
    • The quantity and type of refrigerant transferred for reclamation or destruction, the person to whom it was transferred, and the date of the transfer.

These changes go into effect in just a few weeks. So now is the time to reevaluate what type of refrigeration appliances you have on-site and what types of refrigerants are being used in those appliances and to make sure you have access to and are using certified refrigerant technicians where appropriate.  

Looking ahead

One year from now, we will be approaching the final of the three refrigerant compliance dates. As of January 1, 2019, the revised requirements for refrigerant leak detection and repair will go into effect. These changes are the most extensive and will have significant impact on facilities with refrigeration equipment, so it is not too soon to start thinking about compliance with these requirements as well.
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