2018 was the year we all started to see HVAC/R (refrigerant) regulations come into focus, with changes at the federal and state level impacting both maintenance requirements and record keeping.
What did not change in 2018 was the employment situation, there are simply not enough new people coming into the HVAC/R trades to support the work on the units and to handle the documentation and record keeping.
In the past, the regulations were driven by the federal government and they were frustrating at times, but simple. We had to pay attention to leaks of refrigerant and usage, but only on certain types of equipment. Our work world is changing rapidly and not everything is driven by regulations, some of the change is happening in record keeping needs at the client level, or even how the records are collected - paper is no longer the preferred means to get things done.
There are 5 things that are beyond the traditional maintenance requirement that are driving the marketplace and you need to know what they are so you can remain relevant and prepared for the even bigger changes to come in 2019 and beyond. Here is a list of 5 uncommon things effecting HVAC/R performance and decisions:
1. The traditional invoice is not enough.
The trend in property management is to require vendors to log in to a work flow product, record an event and then submit the needed documents through a vendor controlled portal. Often times service teams are billed for gaining, access to these portals and the portals only record certain aspects of the transaction - missing compliance record needs or trying to shift the record keeping for the appliance or the service to the maintenance team. If improperly managed, this activity can add 1-2 hours of paperwork for each service event.
2. Regulations have changed.
New triggers require new actions. 20 years of familiar and repeated service now needs to adapt to new requirements that dictate when and what to do and then how to record it, where to keep the records and who is responsible. But that isn't the biggest news in regulations effecting 2019. The biggest thing to impact HVAC/R are changes at the state level and more planned over the next 3 years.
Your clients might be getting a bad score because of poor maintenance. HVAC/R accounts for between 30-60% of energy used in commercial properties and in 24 markets there are now reporting requirements and owners/managers residing in these markets have to at least report usage and they get rated on their results but in many places limits are being placed on the amount of energy that can be consumed. in 2018 we reported on this trend and the impacts it will have on properties. If you consider that leaks can have a 1-1 correlation to energy increases, then the common building might be experiencing as much as 25% (average leak rate in the US) increase in energy - this will reflect badly on them and you as the data becomes public
4. Changes are coming to the Mechanical Codes.
New refrigerants & new insulation means new regulations but this round of regulations won't be coming from the EPA, but rather the adjustments to the International Mechanical Codes and these updates will vary widely by state, but you can be sure that as these regulations go into effect, they will impact every piece of equipment and every service provider. These regulations will address flammability, safety as well as placement and size of various systems.
5. End of Life options for refrigerants and the systems they came from.
Wow, this will be complicated. Everyone that works in this industry is familiar with the challenges of recovering and dealing with R-410. With at least 5 more refrigerants coming into the market over the past 2 years, this means have the right tools to recover all the different refrigerants and then a variety of cylinders for both new refrigerants and the recover cylinders to hold each safely. As a former refrigerant reclaimer, I can tell you first hand that the volume of mixed refrigerant was nearly 25%, meaning 1 out of every 4 pounds returned had to be destroyed or separated - this is both costly and time consuming. If you get this wrong, it impacts end of life reports needed by the EPA and could impact record keeping as reclaim certificated could conflict with origin paperwork.
Regulations will continue to proliferate but the pace will expand as it will start occurring at the local and state level. Expect new requirements to impact how you do your job, but keep in mind that reporting and record keeping changes will effect how you and your team manage the data - "think beyond the invoice". From here on out you will need new tools and a new way of thinking. Here are a few things that need some discussion by your team: \
1. Consider that in many cases the inside people doing the data entry are not trained at all on EPA regulations and that they might not even be aware of the shift in regulations. Because the EPA offers only a training for techs we don't think about training other people on the team ( we have a plan for this).
2. Assets - do you know what your working on? You and your clients might not even know what your servicing and the extent of impacts?
3. Are you still using an invoice as the basis of your communication? It is not enough, it doesn't convey the change to the asset, required impact from regulations, the safety needs or let the financial folks know what adjustments they have to make to depreciation or expenses - if this process could be streamlined, then it would reduce paperwork, improve communication and result in better management of assets.
4. Are you an owner? Are you treating all assets the same? Does your maintenance process treat HVAC/R differently than plumbing? Are you using a fancy system that tells you what happened yesterday or are you guiding outcomes and managing results?
The KPI's (Key Performance Indicators) we have historically used to qualify performance are undergoing a massive change and the skills needed to survive are driving that change, some come from government regulations and others from client governance. Please subscribe to Trakref as we keep you up to date as regulations and expectations change in the HVAC/R space.
(In these free slides, find out what the EPA 608 Update requires of you!)