Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

BACK to VIRTUAL TOUR

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 1990, Wisconsin enacted laws to prohibit the release of certain refrigerants (CFCs, HCFCs) that destroy the earth's stratospheric ozone layer, which protects life from the sun's harmful ultraviolet rays. In 2006, these regulations were amended to apply to other refrigerants that cause global warming (HFCs and PFCs).

Under regulations administered by the Wisconsin Department of Natural Resources (WDNR), these refrigerants cannot be released to the environment when salvaging or dismantling any type of refrigeration or air-conditioning equipment. They must be properly recovered, using approved equipment operated by qualified technicians. The facility recovering these refrigerants must be registered with the DNR, keep records of their recovery activities, and supply documentation that the refrigerants were properly removed to whoever receives the scrapped equipment.

As of Nov. 1, 2006, anyone applying for a new or renewed Salvage Dealer License from the Wisconsin Department of Transportation (WDOT) has to provide documents from the WDNR showing that the salvage yard is in compliance with stormwater runoff and refrigerant recovery regulations.

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

The State of Wisconsin regulates auto recyclers who salvage vehicles or other equipment that may contain the regulated refrigerants under Chapter NR488, Wisconsin Administrative Code (see link below).

Compliance Options. Vehicle salvage businesses can choose from four options to comply with these requirements:

1. EVACUATE THE UNITS YOURSELF - Purchase approved refrigerant recovery equipment, send the operator(s) to the appropriate state-approved training course (usually 4-6 hours at a technical school), become registered with the WDNR and comply with other requirements (recordkeeping, documentation to scrap processor).
2. HAVE SOMEONE ELSE EVACUATE THEM UNDER YOUR WDNR REGISTRATION - You can arrange for someone who is qualified (a service station or certified technician who has the proper equipment and training) to evacuate the units while they are in your possession.  YOU MUST STILL REGISTER WITH THE WDNR, supplying equipment, operator certification and identification information on whoever is doing the refrigerant recovery for you. You must also comply with the recordkeeping and documentation requirements.
3. ARRANGE FOR SOMEONE WHO IS CURRENTLY REGISTERED WITH WDNR TO EVACUATE THE UNITS WHILE IN YOUR POSSESSION - Another vehicle salvager or a scrap metal processor who has obtained WDNR registration can recover the refrigerants from your vehicles. They must keep detailed records of these recovery activities. You will not have to register with the WDNR, but you should get copies of those records to verify your compliance.

Refrigerant Recovery Registration. Any facility recovering refrigerants from vehicles air conditioners or any other equipment being salvaged must register annually with the WDNR.  This is done by completing Form 4500-129, Registration to Salvage or Dismantle Refrigeration Equipment (available at web site below). You must provide information on the type of equipment you will salvage, your certified technicians, and your recovery equipment, as well as submit the proper fee.

If you arrange with someone else to perform refrigerant recovery and who is NOT registered with the WDNR, you must still register with the WDNR. The facility doing the recovery must use approved recovery equipment operated by qualified operators, and you must keep records of recovery activities. You must describe this "subcontractor" type of arrangement in your registration application.

Recovery Equipment. You must use recovery equipment approved by the WDNR. The equipment must be approved for safety and efficiency by a recognized national laboratory, and capable of recovering at least 90% of the refrigerant.

Technician Certification. To operate refrigerant recovery equipment, technicians must complete a mobile air-conditioning certification program through the Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) or be directly supervised by someone who has completed the program.

Registration Fee. The annual registration fee is $250, or $125 if you are already registered with DATCP to repair vehicle ACs and your salvage or dismantling activities are a “minor activity” incidental to providing your repair services.

Recordkeeping.  You must keep the following records for three years and have them available for inspection by WDNR staff:

• Training certificates for all supervisor and operators of recovery equipment;
• The brand, model number and serial number of each recovery unit;
• Records of the repair and maintenance of recovery equipment, including date and nature of each repair or maintenance action;
• The type and quantity of equipment, the serial number or other identification number of each individual unit of refrigeration equipment salvaged or dismantled, and the date that the person either recovers the regulated refrigerant from that unit or determines that no regulated refrigerant remained in that unit. Examples of records suitable to identify individual units of refrigeration equipment include make, model and vehicle identification number (VIN) for vehicles with air conditioning, and numbering or marking which uniquely identifies each unit of refrigeration equipment salvaged or dismantled. A sample document for keeping these records is available on the WDNR web pages (see link below).
• A copy of the "documentation of refrigerant recovery" you have supplied to whoever receives the equipment for metal recycling.

Documentation of Refrigerant Recovery. If you sell, give or transport salvaged refrigeration equipment to a scrap metal processor, you must provide a signed statement that all remaining refrigerant has been properly recovered by yourself or another registered business. If you receive equipment to salvage and the supplier claims to have already removed the refrigerant, you must obtain the signed statement from that supplier. Sample forms for this documentation are available on the WDNR web site (see below for link).

Sale of Refrigerant. You should keep records of the quantity, type, receiver and date for all transfers of refrigerant to other parties. You may sell or transfer used refrigerant removed from vehicle air conditioners to:

• Persons registered by Wisconsin DATCP to service vehicle air conditioners and who will purify and reuse the refrigerant to service the air conditioners.
• Persons authorized by the U.S. Environmental Protection Agency to reclaim the refrigerant to original purity standards before resale.

Transportation. If you transport refrigerated appliances for the purposes of salvaging or dismantling which may still contain refrigerant, you must certify annually to the WDNR that you will use methods to safely transport the equipment to prevent refrigerant releases. See the web pages below for the certification form.

Safe transport means using methods such as lift-gate trucks, trailers with ramps, loading docks, or securing appliances in roll-off boxes. Common sense and worker safety awareness are good guidelines.

Penalties. For each release of refrigerant or other illegal actions, the WDNR can issue citations from $100 to $1,000.

Links to the Regulations. Use the following link to view Wisconsin regulations on handling items to be salvaged that that may contain refrigerants:

Wisconsin Regulations for Refrigerant Recovery from Salvaged or Dismantled Refrigeration Equipment (Ch. NR 488, Wis. Admin. Code)

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. Are you registered with the WDNR and properly trained to use recovery equipment? If your facility recovers refrigerant or arranges for another business to perform the recovery that is NOT registered with the WDNR, you must register your business with the WDNR. You can also arrange for a business that IS registered with the WDNR to do the recovery work. Anyone who uses recovery equipment must be properly trained and certified or working under direct supervisions of someone who is certified.
2. Are you using proper and approved refrigerant recovery equipment? Make sure your recovery equipment is approved by the WDNR, approved for safety and efficiency by a recognized national laboratory, and is capable of recovering at least 90% of the refrigerant.
3. Is recovered refrigerant properly stored? Make sure recovered refrigerant is stored according to federal DOT requirements.
4. Are you selling recovered refrigerant to approved persons/facilities? You can sell recovered refrigerant only to facilities that are registered in Wisconsin to purify and reuse the refrigerant to service vehicle air conditioners, or to companies approved by the U. S. EPA to purify and resell it.
5. Are you keeping proper records? Make sure you record each vehicle that comes in with air conditioning and the date you determined it was empty or the date you or another registered party recovered the refrigerant. Other required records are described above. Maintain all required records for at least three years.

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:

• Check each vehicle for AC when it comes in and check system with a "sniffer" for refrigerant. If the AC is empty, mark "NR" on windshield and record. If refrigerant is present, mark the car and set aside for recovery. Record date refrigerant is recovered.
• Remove and recover refrigerants prior to crushing and dismantling vehicles.
• Use only approved recovery units when removing refrigerants.
• Employ certified technicians for refrigerant recovery.
• Collect "Documentation of Recovery" for all vehicles brought in by persons claiming to have already recovered the refrigerant.
• Store recovered refrigerants in color-coded and labeled storage tanks approved by the U.S. Department of Transportation.
• Avoid mixing R-12 and 134a since contaminated refrigerant can’t be put back into vehicles and you may pay to have them processed by a reclaiming or destruction facility.
• Sell recovered refrigerant only to businesses registered to repair vehicle air conditioners or to certified reclamation facilities that will reclaim the refrigerant to its original purity specifications.
• Keep accurate records for at least 3 years.
• Do not use alternative refrigerants containing liquefied petroleum (LP). These refrigerants not only cause contamination, but pose a health risk due to explosions.

Contacts

1. For more information, contact the Wisconsin DNR Refrigerant Recovery Program Coordinator at 608-264-6049 or Lance.Green@Wisconsin.gov .
2. For more information on all Wisconsin environmental regulations affecting salvage operations, contact Wisconsin’s DNR Auto Salvage Sector Resource Specialist at 715-831-3263.
3. For information on other Waste issues, contact the WDNR Regional Office in your area. For northern Wisconsin, call 715-635-2101 or 715-365-8900; West Central Wisconsin, call 715-839-3700; Northeast Wisconsin, call 920-492-5800; Southeast Wisconsin, call 414-263-8500; and, for South Central Wisconsin, call 608-275-3266.
4. All spills should be immediately reported using Wisconsin’s 24-hour toll free hotline at 800-943-0003. If you discover a discharge through analysis of soil or water, use the Hazardous Substance Release Fax Notification Form.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Wisconsin Department of Natural Resources ­ Refrigerant Recovery Regulations - For complete regulatory information, registration forms, sample record keeping and recovery documentation forms, a flyer describing the regulations and a list of registered businesses.
2. Wisconsin DNR Auto and Scrap Recycling Website ­ Environmental regulatory information and resources for auto and scrap recyclers.
3. Wisconsin Department of Transportation Salvage License Website ­ Requirements and forms for obtaining a Salvage Dealer License.
4. Wisconsin's DATCP Mobile Air Conditioning Service Regulatory Information ­ Regulations and registration information for businesses that repair vehicle air conditioners.

BACK to VIRTUAL TOUR