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ECAR Fact Sheet for Missouri
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

The common refrigerant used in automotive air-conditioning (a/c) units is chlorofluorocarbon-12, also known as CFC- 12, R-12, or Freon. In December 1995 production of CFC-12 in the United States ended. CFC-12 can still be used, but it is no longer produced. CFCs are chlorine-containing compounds that react with sunlight in a way that destroys the protective ozone layer in the earth's atmosphere. This allows the amount of ultraviolet (UV) radiation reaching the earth's surface to increase. Overexposure to UV rays may cause skin cancer, eye cataracts and a weakened immune system.

As a result, refrigerants (collectively called chlorofluorocarbons – CFCs) are now tightly regulated.  Refrigerant removal must be done with acceptable equipment 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.

The Missouri Department of Natural Resources has prepared a salvage guidance document to help auto recyclers manage refrigerants. Much of that information is included in the fact sheet below. You can access the link to the Department’s salvage guidance document under “Other Relevant Resources.”


Regulations

If you open an a/c system, you must contain all of the refrigerant using equipment approved by the Environmental Protection Agency (EPA). This includes CFC-12 and alternative refrigerants such as HFC-134a. You must recover the refrigerant before discarding, reselling or recycling the a/c unit as part of a dismantling or crushing operation.

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; 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.

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. *An employee of a salvage operation who recovers refrigerant from vehicles bound for disposal does not have to be a certified technician. Technicians servicing or repairing motor vehicle a/c systems must be trained and certified by an EPA-approved organization.

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.

When recycling refrigerant, do not mix CFCs and HFCs. Recycle these separately. Do not add alternate refrigerants (HFCs) to a system using CFC-12. Under federal law, recycled or reclaimed refrigerants are not hazardous if they are not mixed.

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.” Federal law requires labeling of products containing ozone-depleting substances such as CFCs. Therefore, CFC-12 a/c units, refrigerant equipment and any containers must be labeled clearly. The label must read "WARNING Contains CFC-12, a substance which harms public health and the environment by destroying ozone in the upper atmosphere." An a/c system retrofitted to use an alternate refrigerant must have a label telling what refrigerant is in the system.

It is a good idea to label empty refrigerant containers with the word "EMPTY." Check with refrigerant suppliers to see if the containers can be returned for reuse or recycling. If that is not possible, dispose of empty containers in the landfill.

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 motor vehicle air conditioning (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.

If a customer buys a salvage a/c system, you might suggest that the customer consider having the system retrofitted to use an EPA-approved alternative refrigerant. Currently hydrofluorocarbon-134a, also known as HFC-134a and R-134a, is the only alternative to CFC-12 approved by EPA and fully tested and specified by auto manufacturers in their retrofit guidelines.

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. If you do not recover the refrigerant yourself, you must keep copies of signed statements that the refrigerant was removed by someone else before you got the vehicle.
  • 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.

  1. 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.
  1. 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 units when recharging or removing refrigerants.
  • Remove and recover refrigerants prior to crushing and dismantling vehicles.
  • Verify that all vehicles entering the facility without refrigerant have had the refrigerant removed using proper methods.
  • Employ certified technicians for refrigerant recovery. *An employee of a salvage operation who recovers refrigerant from vehicles bound for disposal does not have to be a certified technician. Technicians servicing or repairing motor vehicle a/c systems must be trained and certified by an EPA-approved organization.
  • 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.
  • Don’t allow Freon to mix with oil prior to reclamation or recycling.
  • Sell refrigerant to certified technicians or to certified reclamation facilities that will reclaim the refrigerant to its original purity specifications.
  • Dispose of filters from CFC recapture as hazardous waste.
  • Keep accurate records for at least 3 years.

Contacts

  1. For more information, call U.S. EPA’s Ozone Protection Program at 1-800-296-1996.

Related ECAR Fact Sheets

  1. Hazardous Waste

Other Relevant Resources

  1. Pollution Prevention During Vehicle Salvage


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