ECAR Fact
Sheet for
California
Refrigerants
Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
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The
following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.
What You Need to Know
Thirty
years ago, something unexpected was discovered about the fluids
used in air conditioners. Once they get into the air, they
stay there a long time. Not much happens to them until they
gradually diffuse several miles high, into the stratosphere.
At that point, unshielded sunlight breaks them down. It turns
out that they have a devastating effect on the ozone layer.
A little bit of air conditioning fluid vapor destroys a lot of ozone,
through a chain reaction. When that happens, the ultraviolet
(burning) rays from the sun can reach the earth, a condition that
greatly increases the risk that you and your kids will get skin
cancer from being out in the sunshine. It's hard to believe
that being sloppy with refrigerants can have that drastic an effect,
but there is no longer any doubt.
As a result, refrigerants are now tightly
regulated. Refrigerant removal must be done with acceptable
equipment, by certified technicians, and must be handled and recycled
properly. The used filters from the operation must be treated
as a hazardous
waste. You also need
to keep records.
This fact sheet will outline the
special rules that apply to refrigerant recovery and handling, and
will give you links to more detailed information.
Regulations
Refrigerants (Freon, R-12, R-22,
R-134a) are the chemicals used in vehicle air conditioning. It is
illegal to vent any refrigerant to the environment during repair,
service, maintenance, recycling or disposal of refrigeration and
air conditioning equipment because of the harmful effect of these
chemicals on our atmosphere.
Refrigerants must be processed using
one of the following methods:
- Recovery – removing refrigerant
from air conditioning units and storing it in a container without
testing or processing it;
- Recycling – filtering refrigerants
to remove impurities such as oil, air and moisture; or
- Reclaiming – processing refrigerant,
usually by distillation, until all impurities are removed and
it meet resale specifications.
Spent refrigerants that are not reclaimed
or recycled are regulated wastes. Refrigerants must be removed by
trained operators using EPA-approved refrigerant recycling/recovery
equipment, or the facility must contract for refrigerant removal
with a licensed vendor. Additional details are provided below.
Refrigerant Recovery. The
rules for recovery depend on whether the refrigerant will be sent
off-site to a reclamation facility or to a MVAC service center for
reuse without prior reclamation.
If the refrigerant will be sent off-site
to a reclamation facility, then refrigerant must be recovered using
equipment that reduces the system pressure to 102 mm (4 inches)
of mercury vacuum. There is no restriction on who performs the recovery.
That person does not need to be a certified technician.
If the refrigerant will be sent to
an MVAC service facility for charging or recharging into an MVAC
or MVAC-like appliance without prior reclamation, then the same
rule applies, but there is a further restriction. Prior to such
charging or recharging, the refrigerant must be recovered using
approved refrigerant recycling equipment dedicated for use with
MVACs and MVAC-like appliances. The recovery process must be performed
either by a certified technician, or by an employee, owner, or operator
of, or contractor to, the auto recycling facility.
Storage of Refrigerant. Store
refrigerant in tanks that meet the federal Department of Transportation
(DOT) or Underwriters Laboratory (UL) standards. The tanks should
be labeled "Refrigerants."
Sale of Refrigerant. The rules
for sale of refrigerant depend on whether the refrigerant will be
sent off-site to a reclamation facility or to a MVAC service center
for reuse without prior reclamation.
If the refrigerant will be sent off-site
to a reclamation facility, then it can be sent to facilities that
meet EPA standards for reclaiming refrigerants or those that buy
used refrigerant for resale to the reclaiming operations.
If the refrigerant will be sent to
an MVAC service facility for charging or recharging into an MVAC
or MVAC-like appliance without prior reclamation, then it must be
sold to a certified technician, who must recycle the used refrigerant
before recharging into an MVAC.
Recordkeeping and Reporting.
The following are recordkeeping and reporting requirements related
to recovery, and sale of refrigerant:
- Anyone who recovers refrigerant
from MVACs or MVAC-like appliances for purposes of disposal must
certify to EPA by submitting a section 608 form that their equipment
meets refrigeration recovery standards.
- Maintain records for 3 years showing
that for each vehicle with a air conditioning unit that refrigerants
were either (1) recovered at your facility or (2) that the vehicle
was brought into the facility free of refrigerants and that the
refrigerants were removed prior to entering your facility using
proper methods.
- Anyone who sells or distributes
any ozone-depleting refrigerant must retain invoices for at least
three years that indicate the name of the purchaser, the date
of sale, and the quantity of refrigerant purchased.
Links to the Regulations. Use
the following links to view the regulations pertaining to refrigerants.
Clean
Air Act Sec. 609. Servicing Of Motor Vehicle Air Conditioners
EPA's
Final Rule Governing Substitutes for CFC-12 Refrigerant in MVACs
EPA-Certified Refrigerant Reclaimers
Self-Audit
Checklist
When
an inspector comes to your facility, there are certain things they
check to see if you are in compliance with environmental regulations.
It makes good sense for you to perform a "self-audit"
and catch and correct problems before they result in penalties.
Also, there are some compliance incentives associated with self-audits
(see Audit
Policy Page).
Use
the following list to audit your procedures for refrigerant management.
- If
the refrigerant will be sent off-site to a reclamation facility,
verify that:
- The
refrigerant was recovered using equipment that reduces the
system pressure to 102 mm (4 inches) of mercury vacuum.
- A
section 608 certification form has been completed for the
recovery equipment.
- The
refrigerant was sold to facilities that meet EPA standards
for reclaiming refrigerants or to a company that buys used
refrigerant for resell to reclaiming companies.
- You
have retained invoices that indicate the name of the purchaser,
the date of sale, and the quantity of refrigerant purchased.
- If
the refrigerant will be sent to an MVAC service facility for charging
or recharging into an MVAC or MVAC-like appliance without prior
reclamation, verify that:
- The
refrigerant was recovered using equipment that reduces the
system pressure to 102 mm (4 inches) of mercury vacuum.
- A
section 608 certification form has been completed for the
recovery equipment.
- The
refrigerant was sold to facilities that meet EPA standards
for reclaiming refrigerants or those that buy used refrigerant
to resell to the reclaiming operations.
Best
Management Practices (BMPs)
Most regulations tell you what you
have to do to be in compliance, but they don’t explain how to do
it. That’s where "best management practices" come into play.
BMPs are proven methods that help you to get into compliance and
stay there.
The following BMPs are recommended
for management and recycle of refrigerant:
- Remove refrigerants prior to crushing
and dismantling vehicles.
- Employ certified technicians for
refrigerant recovery.
- Dispose of filters from CFC recapture
as hazardous waste.
- Make sure different types of refrigerants
are not mixed.
- Keep accurate records for at least
3 years.
Contacts
- California Department of Toxic
Substances Control: 916-323-2678.
- Public and Business Liaison Hotline:
800-728-6942.
- Office of Emergency Services Warning
Center: 800-852-7550.
Related
ECAR Fact Sheets
None.
Other
Relevant Resources
- Partners
in the Solution Guidance Manual (Developed by the State of
California Auto Demantlers Assn)
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