New EPA Refrigerant Regulations for 2020
What do the new EPA refrigerant regulations for 2020 entail, and how does this impact proper refrigerant management practices for HFCs and HFOs? In this article, we provide an important update on what’s been going on with EPA refrigerant regulations in 2020, as ensuring that HVACR systems are compliant is of increasing importance.
In fact, with COVID-19, there has been no lack of excitement for the HVACR world, and stakeholders are scrutinizing their environmental, health, and safety (EHS) best practices and regulatory compliance for HVACR.
How would you and your team rate your refrigerant management practices now for compliance with the EPA Section 608 program? No matter your answer to this question, by the end of this article, you should have a better idea of how you’re doing with ensuring compliant practices and outcomes.
Let’s get started. Here’s an overview of the new epa refrigerant regulations for 2020:
New EPA Refrigerant Regulations for 2020
As you may recall, in November 2016, the U.S. Environmental Protection Agency (EPA) updated the existing refrigerant management requirements in EPA Section 608 and extended the full set of the subpart F refrigerant management requirements (which prior only applied to ODS refrigerants) to non-exempt substitute refrigerants, such as HFCs and HFOs.
Background on the EPA 608 Update
This November 2016 final rule (i.e., 81 FR 82283) is known as the EPA 608 Update, and it came in staggered compliance dates: Jan. 1, 2017; Jan. 1, 2018, and Jan. 1, 2019.
Notably, among the subpart F requirements extended to HFCs and HFOs in the EPA 608 Update include:
- restricting the service of appliances and sales restriction to certified technicians;
- specifying proper evacuation levels before opening an appliance;
- requiring the use of certified refrigerant recovery and/or recycling equipment;
- requiring that refrigerant be removed from appliances prior to disposal;
- requiring that appliances have a servicing aperture or process stub to facilitate refrigerant recovery;
- requiring that refrigerant reclaimers be certified to reclaim and sell used refrigerant;
- establishing standards for technician certification programs, recovery equipment, and quality of reclaimed refrigerant; and
- extending the appliance maintenance and leak repair provisions (82.157).
As you can see, numerous new requirements went into effect for ODS refrigerants and were also extended to HFCs and HFOs.
The last requirement “extending the appliance maintenance and leak repair provisions”—or what is called the leak repair provisions—is what has been called into question and changed in 2020 for non-exempt substitute refrigerants.
Leak Repair Requirements
These leak repair provisions, which had a January 1, 2019, compliance date, included
- requirements to conduct leak rate calculations when refrigerant is added to an appliance;
- repair an appliance that leaks above the threshold leak rate applicable to that type of appliance;
- conduct verification tests on repairs;
- conduct periodic leak inspections on appliances that have exceeded the threshold leak rate;
- report to EPA on chronically leaking appliances;
- retrofit or retire appliances that are not repaired; and
- maintain related documentation to verify compliance.
The Jan. 1, 2019, compliance date for the leak repair requirements originally applied to not only ODS refrigerants but also HFC and HFO refrigerants. (Note: As of April 10, 2020, these updated refrigerant leak repair requirements per the EPA 608 Update only apply to ODS refrigerants. More on that in the paragraphs below.)
EPA 608 2020 Update
However, in March 2020, the U.S. EPA published a new final rule, “Protection of Stratospheric Ozone: Revisions to the Refrigerant Management Program’s Extension to Substitutes,” found at 85 FR 14150, that rescinded the 2016 Rule’s extension of leak repair requirements to HFCs and HFOs. The final rule took effect on April 10, 2020. This complicated the new EPA refrigerant regulations.
What makes this confusing for stakeholders is the that fact other subpart F requirements extended to HFCs and HFOs per the 2016 EPA 608 Update still apply. The other requirements were not rescinded in the April 2020 Update.
In fact, the final rule states, “The agency will continue to apply the other elements of the 608 program, such as the refrigerant sales restriction, technician certification, reclamation requirements, and evacuation standards, to non-exempt substitute refrigerants.”
HFCs and HFOs Still Regulated By EPA 608
Ultimately then, one cannot turn a blind eye to EPA 60 compliance for air-conditioning (AC) and refrigeration equipment that use HFCs and HFOs and blends thereof.
HFCs and HFOs are still subject to proper refrigerant management practices per EPA Section 608 in other ways.
Thus, now is the time to ensure that you have a proper refrigerant management program in place for regulated refrigerants.
Building occupants and customers are becoming increasingly concerned about compliant HVACR systems, so make sure you and your team are doing your part with EPA 608 compliance.
Check out our updated EPA 608 2020 Checklist to get a brief overview of the requirements that still apply to HFCs and HFOs.Get My EPA 608 2020 Checklist
As always, thanks for joining us, and be sure to tune in next week for the latest HVACR insight.
If you have any questions about the new epa refrigerant regulations for 2020, feel free to leave a comment below. 👇👇