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  • Writer's pictureTom Petersen

EPA Refrigeration Recycling Regulations Section 608 of the CAA, regulations (40 CFR Part 82, Subpart

Updated: Aug 28, 2023

Some refrigerants have been proven to deplete our stratospheric ozone layer and are regulated under Section 608 of the Clean Air Act. The regulated refrigerants include chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) and their blends. These materials are found in common appliances including motor vehicle air conditioners (MVACs), MVAC-like appliances, home refrigerators and room air conditioners as well as industrial appliances including boilers and chillers. The damage from CFCs and HCFCs causes an increase in the amount of radiation that reaches the Earth’s surface resulting in potential health and environmental risks. The regulations affect the refrigerants themselves, the tools used to service the appliance containing the refrigerant(s) and the technicians performing the service. Major recordkeeping requirements exist for technicians, owners, wholesalers and reclaimers. These requirements do not apply to technicians or owners for appliances containing less than 50 pounds of charge.


All owners of regulated refrigerants are responsible for prohibiting any venting of those materials into the environment while maintaining, servicing, repairing, or disposing of the refrigerant or machinery containing any of the regulated refrigerants. Minimum releases are allowed if the owner proves a “good faith attempt” to control discharges. If the owner detects a significant leak in a machine with 50 pounds of charge or more, it must be repaired within 30 days unless the owner plans to shut down or retrofit the machine within a year. Additional time may be granted under special circumstances. A significant leak is defined as one where the rate of leaking would result in a specified percent loss in charge if the leak were to be ignored for one year. In the commercial and industrial sectors, a leak must be repaired if it would cause a 35% loss in charge over a year. In all other sectors, the trigger loss rate is 15% per year.


A certified technician must complete all appliance maintenance and repairs and refrigerant reclamation and disposal. This includes the addition or removal of refrigerant from an appliance, attaching or detaching hoses and gauges or any other activity that violates the integrity of the appliance. A technician must release less than 1.5% of the refrigerant during a reclamation process and certify to the EPA that the reclamation process was completed in accordance with the regulations. If an appliance requires on-site dismantling for disposal, the refrigerant must be recovered under the same regulations that apply when servicing the appliance. Special requirements exist for equipment that enters the waste stream with the charge intact (MVACs, household refrigerators and freezers and room air-conditioners). The final person in the disposal chain is held responsible for ensuring that the special requirements are met for these appliances. Once a machine enters the waste stream, a technician does not need certification to remove the refrigerant. Hazardous waste requirements may apply to refrigerants or contaminated oils that are not properly recycled or reclaimed.


There are four types of certifications that a technician may achieve that allow the technician to service small, high pressure, low-pressure or all three types of appliances. Technicians also control the purchase and sale of refrigerants enclosed in containers (cylinders or drums) or pre-charged parts. Exceptions include air-conditioners, refrigerators, pure HFC refrigerants and CFCs or HCFCs not intended for use as refrigerants.


Except for minor repairs and repairs of leaky machinery, the technician must vacuum pressurize refrigerant containing equipment before opening and repairing the machinery according to Table 1. Then, the technician must evacuate and recover the refrigerant before working on the equipment. Technicians whose tools were manufactured after November 15, 1993 must recover 90% of the refrigerant. All other technicians must capture and control 80% of the refrigerant. If the recovered refrigerant has not been contaminated it may be reused freely in any equipment operated under the same owner as the repaired machine. Otherwise, the refrigerant is subject to further testing.


EES can help you maintain your regulated appliances to ensure compliance with these regulations. Please contact Tom Petersen at (215) 881-9401 with any questions or concerns regarding your regulated equipment. More detailed information regarding refrigerant regulations.


40 CFR Part 265.1101 Design and operating standards

Hazardous waste containment buildings are subject to strict design and operating standards to protect against leaks and other failures. The building must be completely enclosed and structurally stable enough to withstand any environmental or physical loads it may encounter during its lifespan. The loads includes wind, rain, settlement, uplift, physical contact with the hazardous wastes, and the loads caused by daily operation including the movement of heavy machinery within the containment building. Any windows or doors must not come in contact with the hazardous waste and must form an effective barrier against dust. For liquid wastes, the primary barrier within the containment building must prevent the migration of the waste into the barrier and be equipped with a liquid collection and removal system. The secondary barrier is subject to the same requirements as the primary barrier, but must also detect any leaks in the primary barrier.


The owner of a containment building is responsible for complying with the regulations above and for the containment of all hazardous waste, including dust. The owner must also retain a qualified registered professional engineer to certify that the containment building complies with the regulations. If a condition is detected that may allow for the release of any hazardous waste, a written notice detailing the steps taken to repair the building must be provided to the Regional Administrator within 14 business days. Once all repairs are complete a professional engineer must be retained to verify that the repairs and cleanup were completed according to the plan previously submitted to the Regional Administrator.

EES can help maintain and certify your containment buildings. Please contact Tom Petersen of EES at (215) 704-1506 or tom@eesolutions.net


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