Your Refrigerant Management Program: 10 Questions to Answer
A refrigerant management program (RMP) ensures efficient maintenance operations; a well-equipped team; environmental sustainability; and compliant outcomes. But do you know what to look for in a refrigerant management program and how to stay compliant with the Environmental Protection Agency requirements? And what should be included in it to decrease your environmental footprint while meeting corporate sustainability standards?
Even if the answer to this question isn’t immediately clear to you, don’t fret. We know you’re busy with your neverending list of countless other building management responsibilities. And, simply put, a comprehensive refrigerant management program only adds on to those responsibilities.
Can You Answer These 10 Questions About Your Refrigerant Management Program?
Registration. Reporting. Leak repair. Automatic Leak Detection Systems. Keeping refrigerant at full charge. Leak inspections. Recordkeeping. It is difficult to manage all these refrigerant management program requirements for refrigeration equipment; keep up with service events; and monitor equipment activity facility-wide, including activity from high GWP refrigerant.
You need to know all the elements that you should consider in a refrigerant management program. It’s important for compliance, as well as ESG reporting and answering sustainability audit questions. Knowing the answers (or knowing how to easily get the answers) to the following 10 questions is a good place to start.
1.) What is the refrigerant use in your facility (e.g., installed, where, how much, maintenance inventory, etc)?
Know the refrigerant types and the environmental impact of them, including pounds of high GWP gases, as described below.
HCFC (e.g., R-22, R-142a, and R-123), which have ozone-depleting potential and global warming potential.
HFC (e.g., R-410A, R-407c, and R-134a), which have global warming potential.
HFO (e.g., R-1234yf), a new alternative refrigerant with emerging environmental issues.
Once you are sure of the various refrigerants utilized throughout your facility, you should know if and when any, some, and/or all of these refrigerants are impacted by a refrigerant phase out.
2.) Are the refrigerants in your various systems impacted by a phased out or phase down?
Various refrigerant types, including CFCs, HCFCs, and HFCs, are being phased out by multi-level regulatory controls—that is, at the federal, state, and local levels.
At the federal level, you have programs like EPA Section 608 and SNAP. There are also various state programs to consider, like CARB’s Refrigerant Management Program. In addition, ever since the SNAP Rule 20 lawsuit, numerous states have adopted or are working to adopt new HFC regulations. Not to mention, there are also long-standing local requirements, like SCAQMD’s Rule 1415.
Your team should be aware of these complex regulatory requirements and pay attention to the fast-changing nature of them, which leads us to our next question:
3.) Has a refrigerant manager or refrigerant management team been assigned for your organization?
Your organization should ensure that all responsible employees and contractors are aware of and will comply with all applicable refrigerant management compliance requirements.
Such stakeholders should have access to a birds-eye view of HVAC/R assets, including an accurate and comprehensive inventory of your companies installed appliances, leading us to question #4.
4.) Do you have an accurate and comprehensive inventory of your companies installed HVAC/R appliances?
Yes, it happens more often than you think: Equipment missing from your inventory. This common mistake can lead to several problems, including understated assets, mismanaged repair budget, inability to repair leaks, and underestimated electricity needs and demands.
A refrigerant management program and plan must include an accurate and comprehensive inventory of your HVAC/R equipment.
5.) Do you have a way to keep management aware of compliance violations?
Noncompliance is risky. Did you know violations of refrigerant compliance requirements can come with lefty fines, like tens of thousands of dollars a day?
Therefore, your team should have a way to mitigate and minimize compliance violations. This is important to do now. In fact, the EPA announced that the temporary enforcement policy due to COVID-19 will “terminate in its entirety” at 11:59PM ET on August 31, 2020.
Have a plan in place to ensure you are up-to-date with compliance requirements.
Gauge your organization’s state of refrigerant management program preparedness. Get our free Refrigerant Management Checklist now!Get My Free Checklist
6.) Does your recordkeeping include the proper leak rate calculations?
For regulated EPA Section 608 appliances, you must calculate your refrigerant leak rates with the proper method.
7.) Do you know if and when leak inspections are required based on the size and type of equipment?
Your equipment may be subject to quarterly or annual leak inspections depending on compliance boundaries and certain conditions.
8.) Will you be able to produce three or five years of service records and leak rate calculations?
Depending on where your facilities are located, your HVAC/R equipment may need to keep three or five years of records for compliance. Per EPA Section 608, regulated entities must keep records for three years; per CARB RMP, regulated entities must keep records for five years.
9.) Are your policies, procedures, and work instructions updated to reflect EPA SNAP Program listings?
In addition to the EPA Section 608 program, you also must pay attention to the EPA SNAP Program, which lists acceptable and unacceptable substitute refrigerants in refrigeration and air-conditioning end-uses.
In recent years, the HFC refrigerant ban has caused much confusion.
10.) Has your organization evaluated the potential use and maintenance of flammable refrigerants?
New flammable alternative refrigerants are on the rise, and buildings must plan accordingly. Typically, these flammable refrigerants are subject to use conditions under the EPA SNAP Program (see #9).
For example, use conditions may include meeting the applicable UL Standard requirements; displaying warning labels; having distinguishing red color-coded hoses and piping; and others.
Have a Plan to Achieve Optimal Compliance Outcomes
As you can see, there are many considerations that you must make in your refrigerant management program, including various regulatory requirements at the federal, state, and local level as well as new safe-handling requirements for flammable alternative refrigerants.
Ultimately, these 10 questions are just the beginning.
For a complete checklist to gauge your organization’s state of refrigerant management program preparedness, check out our free Refrigerant Management Program Checklist.Get My Free Checklist
A documented refrigerant management program not only provides you with a platform to provide regulatory agencies with required records but also guides you to effectively and efficiently manage expensive HVAC assets as well as all of the related services associated with those assets.
HVAC equipment and related functions comprise a major expense line item for any company that owns the equipment and is responsible for its maintenance.
By beginning to ask key questions on and around your refrigerant management program, you will minimize downtime and save money normally spent for unnecessary repairs and equipment replacement.
And if you’re looking to up your refrigerant tracking and management game with technology, get in touch with us today. We’re a software corporation that has been in the regulatory compliance software and environmental compliance calendar software space for years. As an environmental software provider, we make sure our refrigerant capabilities will keep you in compliance. Get in touch with a Refrigerant Geek today.
Thanks for reading, and be sure to tune in next week.
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