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.  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. 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; 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 Virginia 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 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 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.
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 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.
• 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.
• 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

Related ECAR Fact Sheets

1. Hazardous Waste.

Other Relevant Resources

None.

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