Is Your Facility in Compliance with the Updated Refrigerant Rules?

U.S. EPA regulates refrigerant containing equipment, including motor vehicle air conditioners (MVAC), at 40 CFR Part 82 – Protection of Stratospheric Ozone.  This rule is focused on minimizing the release of refrigerants to the atmosphere as they have the potential to negatively affect the earth’s ozone layer.  Some important and impactful updates were made to the refrigerant rules within the past few years and it’s important for facilities to evaluate their applicability, especially with U.S. EPA keeping a closer eye on this rule.

In 2018, U.S. EPA published final updates to 40 CFR Part 82 requirements.  The updates broadened the scope of affected units by:

• Including rules for equipment that contains any amount of refrigerant. The rule previously only regulated units that contained large amounts of refrigerant.
• Expanding the definition of “refrigerant” to include substitute refrigerants.

A general summary of the most recent updates to 40 CFR Part 82 is discussed below.

What refrigerant equipment are now subject to the regulations?

Prior to the 2018 updates, the regulations focused on requirements for equipment that contained greater than 50 pounds of refrigerant.  Requirements included work practice and recordkeeping for service and disposal events performed by certified facility technicians.  The 2018 revisions expanded rule applicability to include requirements for the servicing of equipment that contain refrigerant in amounts as small as 5 pounds.  Affected small capacity equipment are now subject to safe disposal and safe evacuation requirements.  The impact of this revision is important for facilities to integrate into their servicing, disposal, and recordkeeping for equipment with small amounts of refrigerant.  The specific requirements include:

• Equipment that contains less than 5 pounds of refrigerant are subject to safe disposal requirements. Technicians disposing refrigerant appliances must ensure that refrigerant is disposed of properly.
• Equipment that contains between 5 and 50 pounds of refrigerant are subject to safe evacuation requirements. Technicians servicing or disposing these units must ensure that refrigerant is evacuated and/or disposed properly.

What is the definition of a refrigerant as it applies to 40 CFR Part 82?

Historically, U.S. EPA regulated Class I and Class II refrigerants [e.g., chlorofluorocarbons (CFC) and hydrofluorocarbons (HFC)].  Over time the Class I and Class II refrigerants have been phased out of use and instead, “substitute” refrigerants are in use.  U.S. EPA has determined that these “substitute” refrigerants are also potentially damaging to the ozone layer.  “Substitute” refrigerants include materials such as R-134A and R-407C.  Thus, 40 CFR Part 82 now also regulates the use of substitute refrigerants.  It is important for facilities to consider whether the use of these “substitute” refrigerants now requires your facility to comply with requirements that previously did not apply.

U.S. EPA established a compliance date of January 1, 2019 for the revised requirements.  So, now is a good time to take a closer look at the equipment at your facility that contains refrigerant and confirm that you are complying with the revised regulations.  As always, ALL4 is available to answer any questions you may have.  If you’re interested in having ALL4 conduct a refrigeration training at your Facility, contact Christina Lynch at clynch@all4inc.com.