New Refrigerant Management Rules Take Effect Soon

The USEPA has finalized two new rules concerning ozone-depleting substances (ODS) that are the latest in a series of actions aimed at reducing emissions of ODSs.  In the first rule, the EPA has identified safer and more environmentally friendly refrigerants for industrial equipment.  The impacts of this rule will likely be noticed more when purchasing or replacing equipment.  The second rule impacts equipment containing ≥50 pounds of refrigerant and will impact the refrigeration repair industry.  Both rules are scheduled to be effective on January 1, 2017. 
 
Under Section 612 of the Clean Air Act (CAA), Significant New Alternatives Policy (SNAP) program, EPA is: 

1. ​​Adding to a list of safer and more climate-friendly chemicals that must be used in refrigeration and air conditioning and fire suppression equipment;
2. Listing several new substitutes as unacceptable in specific end-uses in the refrigeration and air conditioning sector; and
3. Changing the status to non-acceptable of several substitute materials that were previously listed as acceptable in the refrigeration, air conditioning and foam blowing sectors.  

Under Section 608 of the CAA, EPA is expanding the refrigerant management program and extending the regulations to non-ozone depleting substitutes such as hydrofluorocarbons (HFCs) and other substitutes.  This action lowers the leak rate at which large air conditioning and refrigeration appliances must be repaired and incorporates industry best practices such as verifying repairs and conducting regular leak inspections on appliances.  Significant changes include:

• Extends the requirements of the Refrigerant Management Program to cover substitute refrigerants, such as HFCs.  (Note that EPA has previously exempted some substitutes from the Section 608 venting prohibition through previous rules.  Such substitutes are also exempt from the requirements of this rule.) 
• Lowers the leak rate thresholds that trigger the “duty to repair” for air conditioning equipment containing ≥ 50 pounds of refrigerant as follows:

• Industrial process refrigeration - 35% to 30%
• Commercial refrigeration - 35% to 20%
• Comfort cooling - 15% to 10% 

• Requires quarterly / annual leak inspections or continuous monitoring devices for refrigeration and air-conditioning equipment that have exceeded the threshold leak rate. 
• Requires owners / operators to submit reports to EPA if systems containing 50 or more pounds of refrigerant leak 125% or more of their full charge in one calendar year.
• Extends the sales restriction to HFCs and other non-exempt substitutes, with the exception of small cans (containing 2 pounds or less) of non-exempt substitutes (e.g., primarily HFC-134a) for motor vehicle air conditioner servicing.  
• Requires technicians to keep a record of refrigerant recovered during system disposal from systems with a charge size from 5 to 50 pounds.

More information can be found at the following USEPA links:

• Notification of New rule​
• ​USEPA: Section 608 Refrigerant Management Rule Changes

•  SNAP Regulations

•  Fact Sheet on the 40CFR82 Rules affecting facilities