The Fine Line Between Reckless and Responsible
A lapsed car registration effects everyone no matter what you drive, whether it is a gas guzzler producing more smog than a Beijing city street or an emissions-free electric vehicle. You can’t go back to the gas station and blame them because you failed to take care of your car. It wasn’t the gas that caused a failure but owner neglect. The same applies to your HVAC/R units, their owners and the contractors that service them. Do you know what you’re responsible for?
IF YOU ARE A SERVICE PROVIDER
You are the professionals and we salute you, but you have responsibilities when you are contracted out. It all starts with employing universally certified technicians. This means that they can work on any type of appliance and should keep records of their tech cards on file for three years. Any contractor hiring technicians with other certifications are opening themselves up to more violations. Outside of this, your main responsibility is accuracy and validity. Here are some things to consider:
✔ Is the asset inventory accurate by independent circuit?
DID YOU KNOW? Grocery store racks have a lot of circuits, but they usually are not independent circuits!
✔ Is the net amount of refrigerant added clearly shown and accurate?
✔ Was there a breakdown? What did you find, what was the solution, how long was it down, were there any parts ordered?
✔ Was there an Initial Leak Verification Test or Follow-Up Leak Verification Test done? Test used, date and results must be documented
You are not expected to be an expert on the regulations. From big to small, the rules have changed many times over 25 years. 2016 alone had more than 500 pages of new regulatory language and adjustments! You are expected to implement them correctly, though. It is a service provider’s responsibility to have that open conversation with an owner about any concerns they may have, identifying the problem and solving it. Any penalties or fines that come from incomplete and inaccurate repairs that you are contracted out to provide are your responsibility. Fines are not fine when they lose you clients over time.
IF YOU ARE AN OWNER
Your assets are directly tied to your profitability and expenses, so it is your responsibility to take every measure to ensure they are running smoothly… and cooly. Think of it like a car. It is not the mechanic’s responsibility to keep up with when you need an oil change, only to do them when you pay for it. Your HVAC/R units are no different!
When you hire a contractor you need to review their technicians’ certifications. Hiring a contractor who employs technicians with a universal certification provide you the best success.
Here are some of the records that you have to keep on hand for three years:
✔ copies of the EPA 608 certifications of the technicians hired
✔ asset disposal records for systems over 5 lbs. (guess what, they are all over 5 lbs.)
✔ service records showing refrigerant added and removed
✔ Was a new system charged? Install date, size, type and refrigerant type are all required
✔ leak rate calculations and the scheduling of annual/quarterly leak inspections. This is a scheduled event and preventative maintenance. An owner is responsible for scheduling this
DID YOU KNOW?
Any system 500+ lbs. must have a leak inspection every 3 months until it has not leaked for 12 months in a row! And every system over 50 lbs. require an annual leak inspection
Owners must review any and all records when service is complete. Again, we are not expecting you to be a rules expert (that’s what Trakref is for). Because you hold the checkbook and pay service contractors, though, you are ultimately liable for everything. If there is a violation and the EPA comes knocking, you are on the hook for it. Records are expected to be on-site and available at short notice. That usually means 2 weeks and, if it is bad like a safety violation, then short is same day. The EPA and local/state officials know that it is your responsibility if a system leaks because you control the money that would either limit or enable technicians to do the work. Do you?
The most important thing to remember is to have an open conversation with your contractor. Start talking about the regulations and how you can work together to achieve compliance. You won’t get fined and they won’t lose their license or clientele. Cold air and cheap fixes are no longer good enough.
There are a couple different ways to go about this: digital or paper. Either require management of the process and digital is far more efficient. If only there was an easy and simple way to navigate through these ever-changing waters… Oh wait, there is with Trakref.
We are a climate-conscious crowdsourced environmental management software specializing in compliance and performance. Do you work with a lot of contractors? This is where we shine. With a mobile application for technicians to record on the go and a cloud-based document pool for complete owner portability, we cater to both.
Check out our handy responsibilities chart below and start compliant today!