ECAR Fact
Sheet for Michigan
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 (collectively called chlorofluorocarbons
– CFCs) are now tightly regulated. Refrigerant removal must be done
with acceptable equipment, by certified technicians, and must be
handled and recycled properly. You also need to keep records.
This
fact sheet will outline the EPA 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. By the end of 1995 all manufacturers were required
to stop production of R-12. However, the use of R-12 is still permitted
until supplies are depleted.
Federal
regulations state that 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 meets resale specifications.
Spent refrigerants that are not reclaimed or recycled are
regulated wastes. EPA requires use of certified refrigerant recycling
equipment when servicing vehicle air conditioners. Anyone in Michigan
who works on vehicle air conditioning systems must also be certified
by an EPA-approved organization. Each facility must either have
a certified person on-site or bring in a person certified to perform
this work.
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 an 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 he or she checks 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/CFC
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/CFCs:
- Use
only approved reclaiming and recycling units when recharging or
removing refrigerants.
- Remove
and recover refrigerants prior to crushing and dismantling vehicles.
- Employ
certified technicians for refrigerant recovery.
- Avoid
mixing R-12 and 134a since contaminated refrigerant can’t be put
back into the vehicle and must be sent to a recycling facility.
- Do
not use alternative refrigerants containing liquefied petroleum
(LP). These refrigerants not only cause contamination, but pose
a health risk due to explosions.
- Be
sure to use the proper O-rings, lubricants, etc. when retrofitting
automobile air conditioning systems.
- Don’t
allow Freon to mix with oil prior to reclamation or recycling.
- Determine
if filters from CFC recapture are hazardous waste due to regulated
amounts of chloroform or other contaminants. For more information
on handling, storing and disposing hazardous wastes, see the Auto Recycling Plain Language
Guide to Solid/Hazardous Waste Management.
- Keep
accurate records for at least 3 years.
Contacts
- For
more information, call the Stratospheric Ozone Information Hotline
at 800-296-1996.
Related
ECAR Fact Sheets
None.
Other
Relevant Resources
None.
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