EPA 608 Changes in 2020

Are you aware of the EPA 608 changes in 2020? This post will briefly explain what changes have occurred; how they impact your facility; how they impact corporate sustainability initiatives; and what you need to be on the lookout for moving forward.

Because, just when it appeared that all the new compliance requirements per the EPA Update were certain into the foreseeable future for servicing or disposing, it thus proved to be otherwise.

The world of HVAC/R compliance is as fast-changing as ever, as anyone who has ever taken open book certification exams on type I, type II, and type III for certification programs will know. For everything from high pressure appliances to the simplest of operations, there is always something new to be learning. Here’s what you should pay attention to in regards to the EPA changes in 2020 to make sure you are in compliance, as well as to ensure you are meeting environmental sustainability initiatives and decreasing your environmental footprint. 

 

2020 EPA 608 Revises Refrigerant Management Requirements

On March 11, 2020, the EPA published a new final rule, “Protection of Stratospheric Ozone: Revisions to the Refrigerant Management Program’s Extension to Substitutes,” found at 85 FR 14150.

Essentially, this new final rule, which took effect on April 10, 2020, revised certain refrigerant management requirements and testing services a part of the Section 608 Update to maintain service repair. Both Section 608 and 609 are important for HVAC/R technicians, since they need to know about it for EPA certification and pass the exam for universal certification. 

Specifically, it revised the appliance maintenance and leak repair provisions at 40 CFR 82.157 by making this part now only apply to equipment using refrigerants that are ozone-depleting substances (ODS), such as CFCs and HCFCs.

This means that equipment with non-ozone depleting refrigerants, like HFCs and HFOs, are no longer subject to the leak repair provisions. 

Other EPA Requirements Still Apply to Non-Exempt Substitute Refrigerants

It should be made clear that these changes in 2020 do not rescind the other provisions that affect non-exempt substitute refrigerants (HFCs and HFOs), including:

• the sales restriction and technician certification requirement; 
• safe disposal requirements; 
• evacuation requirements; 
• reclamation standards; and
• certified recovery equipment requirements. 

Hence, if you have R-AC equipment with non-ODS, other requirements still apply, so ensure that you and your team act accordingly and your preventative maintenance program reflects this. 

Mixed Messages on HFC Refrigerant Compliance Requirements

Whether these changes to in 2020 offer some sense of finality for HFC refrigerant compliance under this regulatory program remains unclear. 

Consider the fact that, just three days prior to this new final rule on Section 608 taking effect, a new HFC court decision unfolded that went against the EPA. Read all about it on our blog here.

This highlights the multiple entities now involved in solving one of the most pressing climate questions of our time: How refrigerants get managed. This has been an ongoing struggle ever since the Clean Air Act. 

It also thereby begs the question which entity now manages refrigerants in the United States? Is it the EPA, the court, or a bit of both? 

If you are interested in learning more about what refrigerants are acceptable and unacceptable in what applications per U.S. EPA regulations, please check out our free handy Refrigerant Phase Out Chart below now.

This Refrigerant Phase Out Chart is a handy resource in understanding what’s going on at the federal level in terms of refrigerant management. 

And if you’re looking to work with a company that is always staying on top of the latest in compliance and refrigerant tracking, get in touch with us today. We’re a software corporation that has been in the regulatory compliance software and environmental compliance calendar software space for years. As an environmental software provider, we make sure our refrigerant capabilities will keep you in compliance and help with ESG reporting and answering sustainability audit questions. Get in touch with a Refrigerant Geek today. 

As always, thanks for joining us, and stay tuned.