Washington State Refrigerant Regulations: Everything You Need to Know

If you manage refrigeration and air conditioning assets, then you’re probably already familiar with the challenges presented by leaks of refrigerant gasses, whose repeated phase transitions enable cooling. 

In addition to the maintenance and uptime impacts, leaks of hydrofluorocarbons (HFCs) can be thousands of times more potent than carbon dioxide, and are now responsible for the fastest-growing greenhouse gas emissions in the world.

The impact of refrigerant leaks for facilities can really add up. As part of their Environmental, Social & Governance (ESG) reporting, Walmart disclosed that onsite refrigerant emissions contributed approximately 53% of their Scope 1 emissions and 29% of their overall operational emissions in 2022 (Walmart).

The state of Washington is now taking a more aggressive stance on HFCs with new refrigerant management requirements for reporting, inspecting, and repairing cooling assets to reduce refrigerant leakage. 

Expectations and Requirements 

In 2018, the EPA estimated that refrigeration and air conditioning equipment in homes, commercial buildings, and industrial operations were responsible for about 75% of HFCs in the United States. And according to the State of Washington Department of Ecology, if HFC use isn’t curbed, emissions will increase to 7–19% of global greenhouse gas emissions by 2050. In Washington, HFCs account for 4% of the state’s total greenhouse gas emissions. To stem the tide, new Washington state refrigerant regulations were introduced in November 2023, which went into effect January this year. 

Known as Chapter 173-443 WAC, the rule zeroes in on HFCs and other fluorinated greenhouse gasses. Beyond meeting maximum global warming potential (GWP) thresholds for HFCs, owners and operators of air conditioning or refrigerant management systems will need to comply with a refrigerant management program that requires:

• Registration
• Leak inspection and repair
• Recordkeeping and reporting

According to the Department of Ecology, the net effect of the new refrigerant management program will be the equivalent of helping to mitigate what comes out of the tailpipes of about 740,000 cars each year. 

How Do I Know If My Business is Affected?

Businesses of all sizes are impacted by the Washington state refrigerant regulations, however the size of the refrigerant systems and types of refrigerants used are determining factors. Chief among those affected are:

• Commercial refrigeration operations such as supermarkets, restaurants, cold storage warehouses, and ice rinks
• HVAC contractors that are responsible for systems that use refrigerants
• Industrial facilities that rely on refrigeration systems for process cooling
• Cold storage, warehousing, and distribution/transportation businesses that use refrigerant management systems for perishable goods
• Ice rinks and recreational facilities that have cooling systems in place

When Do I Need to Register?

While the registration and reporting requirements are being phased in over the coming years, larger facilities—such as those with at least 1500 pounds of GWP refrigerant—are already accountable. 

Registration deadlines:
>1,500 pounds (large)	March 15, 2024
200 < 1,499 pounds (medium)	March 15, 2026
50 < 199 pounds (small)	March 15, 2028

 

For more information, you may visit the State of Washington Department of Ecology’s Refrigerant Management Program. 

 

What Are My Leak Inspection and Repair Requirements?

Inspections

Among the stipulations of the Washington state refrigerant regulations, relevant refrigerant-containing assets must undergo inspections on a regular basis with a certified technician. 

Inspection Schedule
Large facilities	Monthly
Medium facilities	Quarterly
Small facilities	Annually

 

In addition to the above schedule, system leak inspections must also be conducted:

• At the time of verification tests;
• Each time refrigerant is added in an amount equal to or greater than 5 pounds, or 1% of the full charge, whichever is greater;
• Each time oil residue is observed, indicated a potential refrigerant leak

With each inspection, leak rates must be calculated based on this formula:

(Pounds of refrigerant added over previous 365-day period) ÷ (Pounds of refrigerant normally contained in the system at full charge) x (100%).

Leak Rate Compliance Thresholds

Depending on the type of end use of the refrigerant-containing asset, the leak rate compliance threshold varies. The chart below from the Washington State Department of Ecology outlines the limits.

 

End Use	Leak Rate Threshold
Cold Storage Warehouse or Retail Food Refrigeration	16%
Industrial Process Refrigeration (IPR)	24%
Air Conditioning	8%

A refrigerant leak must be repaired within 14 days from the date of detection—a notably sharp reduction of the EPA’s required timeline of 30 days. 

Notably, if repairs are not completed by the deadline, the owner/operator may be required to deliver a retrofit or retirement plan for the leaking system.

Recordkeeping and Reporting

Medium- and large-sized facilities—or systems that carry a full charge of 200 pounds or more of a high-GWP refrigerant (GWP greater than 150)—must submit a facility report annually. 

When it comes to record-keeping, however, size does not matter. The Washington state refrigerant regulations require all facilities that have a refrigeration or air conditioning system with a minimum charge of 50 pounds of a High-GWP refrigerant to maintain a comprehensive collection of documents from registration through the lifecycle of the refrigerant-containing system.

Keep Complexity in Check with Trakref: A Fexa Solution

Refrigerant management system upkeep and leak rate compliance can be complex. With Trakref, Fexa’s refrigerant management software, teams can simplify the process and keep a step ahead of evolving regulations.

Trakref builds in timely alerts and guidance to help system owners ensure refrigerant leak rate compliance with federal regulations as well as the growing patchwork of regulations at the state level, such as those being rolled out in Washington today. 

Trakref simplifies the recordkeeping process for managing refrigerant assets through auditable and compliance-ready workflows. New alerts, designed specifically for the latest regulations, ensure that system owners and operators can stay on track with all recordkeeping, deadlines, and leak detection activities.

“We’ve designed rules to reflect the new Washington state refrigerant regulations,” explains Cynthia Rollins, Trakref Product Owner. “Now, customers can take advantage of this new feature that informs them when their systems are impacted by the regulations. Whether it’s reminders and follow-up alerts centered around leak rate compliance deadlines or built-in guidance to help with long-term planning to stop leaks, we want to simplify the compliance process and help customers mitigate the negative impact of refrigerant emissions.” 

With capabilities such as built-in logic to flag compliance risks; rules and reporting that reflect audit questions and evolving regulatory standards; and multi-location, multi-system and multi-vendor asset management, Trakref provides refrigerant and compliance managers/owners with a trusted solution to ensure requirements are fully met.

Learn more about Trakref capabilities by requesting a demo.