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

In the 1970s, atmospheric chemists discovered something unexpected about the refrigerants used in air conditioners. They learned refrigerants released into the atmosphere can have very long atmospheric lifetimes. Not much happens to them until they gradually diffuse several miles high, into the stratosphere. In the stratosphere, ultraviolet (UV) radiation breaks the refrigerant chemicals (including chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs)), down into products that can react with ozone. It turns out that they have a devastating effect on the ozone layer. A small amount of ozone-depleting refrigerant has the potential to destroy a large amount of ozone through a chain reaction. Stratospheric ozone depletion allows harmful ultraviolet rays from the sun to reach the earth’s surface, which increases the risk of skin cancer and cataracts from increased UV exposure.

As a result, refrigerants including CFCs and HCFCs are now tightly regulated. Refrigerant recovery must be done with the use of EPA-certified recovery 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.

Chemical substitutes for CFCs and HCFCs known as hydrofluorocarbons (HFC) do not deplete the ozone layer but instead are high global warming potential gases which contribute to climate change. Similar to CFCs and HCFCs, HFCs have to be recovered and can not be vented.

This fact sheet will outline the regulations that apply to refrigerant recovery and handling, and will provide links to more detailed information.

Regulations

Refrigerants (Freon, R-12 and R-134a) are the chemicals used in motor vehicle air conditioning (MVAC). By the end of 1995, EPA banned most production and import 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.

Refrigerants must be recovered during all service, repair, maintenance and disposal activities.

• 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 meets virgin specifications.

Spent refrigerants that are not reclaimed or recycled are regulated wastes. EPA requires use of EPA-certified refrigerant recycling equipment when servicing motor vehicle air conditioners. Anyone 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 any service involving refrigerant, including but not limited to refrigerant top-offs. For additional information, see http://www.epa.gov/ozone/title6/609/technicians/609certs.html

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 MVAC recovery only equipment certified to SAE J1732 or J2810. There is no restriction on who performs the recovery. That person does not need to be a certified technician. http://www.epa.gov/Ozone/title6/608/608fact.html#equipcert

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.

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 transfer to the EPA-certified reclaimers.

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 obtain and properly use refrigerant recovery equipment that has been certified for use with motor vehicle air conditioners. The owner of the refrigerant recovery equipment must send a certification form to the appropriate EPA Region. A sample form can be found at http://www.epa.gov/ozone/title6/608/recoveryform.pdf.

• Anyone accepting MVACs for disposal must insure that the refrigerant has been properly removed before disposal by, (1) recovering the refrigerant at your facility or (2) obtaining a written signed statement from your customer verifying thtat the refrigerant ahs been properly recovered from all motor vehicle air conditioners prior to delivery to your facility. Records of recovery must be maintained for 3 years.

• Anyone who sells or distributes 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. A sample form can be found at http://www.epa.gov/ozone/title6/608/sales/sales.html

Links to the Regulations. Use the following links to view the regulations pertaining to refrigerants.

Clean Air Act – Title VI – Stratospheric Ozone Protection
http://www.epa.gov/air/caa/title6.html

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 MVAC recovery only equipment certified to SAE J1732 or J2810.

• A section 609 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.

2. 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 MVAC recovery only equipment certified to SAE J1732 or J2810.

• A section 609 certification form has been completed for the refrigerant handling 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 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 EPA approved refrigerant handling machines when recharging or removing refrigerants.

• 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.

• Avoid mixing R-12 and R-134a because contaminated refrigerant cannot 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 safety risk due to their flammability.

• Be sure to use the proper O-rings, lubricants, etc. when retrofitting MVACs.

• Don’t allow R-12 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, contact the Oregon Department of Environmental Quality (DEQ) at 503-229-5696 or 800-452-4011 (toll-free in Oregon).
2. 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. OR Vehicle Dismantlers webpage

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