EPA Section 608 Changes

Effective January 1, 2018 new regulations impacting the way refrigerants are handled and sold go into effect. Additional regulatory changes will go into effect on January 1, 2019.

Effective January 1, 2018

HFC and HFO refrigerants are now included in the sales restriction. These refrigerants may only be sold technicians certified under Section 608 and Section 609 of the Federal Clean Air Act.

Wholesalers and others who re-sell refrigerants must maintain invoices that indicate: purchaser name, sale date, and the quantity of CFC, HCFC, HFC and HFO refrigerants purchased. These records must be maintained for no less than three years.

Employers must require proof of certification for technicians and must maintain a copy of their certification at their place of business for three years after a certified individual leaves the employer.

New record keeping requirements for appliances containing 5 to 50 pounds of refrigerant become effective.

Technicians must keep records of; the location, date of recovery, and type of refrigerant recovered for each disposed appliance, the quantity of refrigerant by type recovered from disposed appliances in each calendar month. In addition, the quantity of refrigerant, and type, transferred for reclamation or destruction, the person to whom it was transferred, and the date of the transfer.

All requirements for the maintenance, service, repair and disposal of CFC and HCFC are extended to HFC and HFO refrigerants.

The EPA requires new wording on certification cards issued January 1, 2018 and beyond. As a result, any new and replacement certification cards will have a new look.

The wording on new certification cards includes: “[Name of person] has successfully passed a [Type I, Type II, Type III, and/or Universal, as appropriate] exam on how to responsibly handle refrigerants as required by EPA’s National Recycling and Emission Reduction Program.”

 
Cards issued issued prior to January 1, 2018 remain valid.

Additionally, the EPA requires that Section 608 Certification holders be included in a public online directory to simplify locating their certification records. While ESCO Institute has maintained a public directory for many years, we wanted to remind you of this feature as it will allow you to quickly verify one's credentials even if you did not proctor their exam.

A new Section 608 EPA Certification Exam has been developed to incorporate the new regulations. It is currently being reviewed by the EPA prior to release.

When the new exam is available, all registered proctors will be notified. Until such notification, registered proctors should continue to use the current exam. It should be noted that currently certified Section 608 technicians do not need to be re-certified.

Effective January 1, 2019

Section 608 regulations include new leak inspection and verification test requirements for owners/operators. Leak inspections are required for appliances that have exceeded the applicable leak rate, per the information below. All visible and accessible components of an appliance must be inspected, using a method or methods that are appropriate for that appliance.

Comfort Cooling with a charge of 50 or more pounds must have a leak inspection once per calendar year until the owner/operator can demonstrate through the leak rate calculations that the leak rate has not exceeded 10% for one year.

Commercial Refrigeration and Industrial Process Refrigeration (IPR) with a charge of 50 to 500 pounds must have a leak inspection once per calendar year until the owner / operator can demonstrate through the leak rate calculations that the leak rate has not exceeded 20% commercial refrigeration or 30% IPR for one year.

Commercial Refrigeration and IPR with a charge of over 500 pounds must have a leak inspection conducted once every three months until the owner/operator can demonstrate through leak rate calculations that the leak rate has not exceeded 20% for commercial refrigeration or 30% IPR for four quarters in a row.
 
Resources
EPA Presentation
Fact sheets for specific industries affected by the revised 608 regulations
2019 Leak Rate Calculations for Appliances that Contain Non-Exempt Substitute Refrigerants
Full Regulations

Original article found here: https://www.linkedin.com/pulse/epa-section-608-update-howard-weiss