5 Things to Know About the Update to EPA Section 608 - New EPA Refrigerant Regulations

February 15, 2017 / by Elizabeth Ortlieb

Elizabeth Ortlieb

In 2018 & 2019, new EPA refrigerant regulations (known as the EPA Section 608 update) will go into effect. 

Here’s what affected HVAC/R stakeholders need to know about the new EPA refrigerant regulations:

Own or manage a property’s heating and cooling? Then, you realize how your HVAC equipment performs makes a difference in the everyday lives of occupants and tenants. Of course, when maintaining, servicing, repairing or disposing of certain refrigerants in your equipment, there are many safe handling requirements that must be followed, in accordance with EPA 608, the National Refrigerant Management Program.

(Update: If you'd like to know the top requirements that take effect on Jan 1, 2018, please download our free checklist the Top 6 Compliance Requirements to Know for EPA 608 2018.)

In November 2016, changes to these handling requirements were finalized, and as of January 1, 2017, they went into effect. Being that fluorocarbon refrigerants (HCFCs and HFCs) comprise the majority of global refrigerant consumption, this EPA 608 update has widespread reach, affecting U.S. HVAC/R stakeholders at multiple levels.

Here’s the 5 things you should know about the update to EPA 608 to prepare your workplace:

  1. Requirements extend to non-exempt substitute refrigerants, like HFCs and HFOs. The requirements of EPA 608 have been extended to include non-exempt substitute refrigerants, like hydrofluorocarbons (HFCs), and this will require technicians to handle these substitutes in the same way as ozone-depleting potential (ODP) refrigerants in order to remain in compliance.
  2. Phasein of new requirements and changes occurs over the next two years. Compliance dates are staggered to allow for adequate preparation, and the key dates are namely January 1, 2017; January 1, 2018: and January 1, 2019. In fact, as of January 1, 2017, reclaimers must pay heed to reclamation standards for HFCs, PFCs, and HFOs based on AHRI Standard 700-2016, and reclaimers must document various reclamation activity. 
  3. EPA regulations on refrigerant leaks change—Allowable leak rate limits will decrease. Right now, industrial process refrigeration and commercial refrigeration have a trigger rate of 35; comfort cooling has a trigger rate of 15%. On January 1, 2019, two major changes take effect to the leak rate thresholds: (1) They will extend to appliances containing non-exempt substitute refrigerant, like HFCs, and (2) They will become more stringent. Industrial process refrigeration's leak rate limit will drop from 35% to 30%. Commercial refrigeration's limit will drop from 35% to 20%. Comfort cooling's limit will drop from 15% to 10%.
  4. Periodic leak inspections will be required if a leak rate threshold is exceeded. If the new leak rate limits effective 1/1/2019 are exceeded, then a leak inspection(s) must be conducted in accordance with the schedule(s) outlined in 40 CFR Part 82.157(g). For instance, "for commercial refrigeration and industrial process refrigeration appliances with a full charge of 50 or more pounds but less than 500 pounds, leak inspections must be conducted once per calendar year until the owner or operator can demonstrate through the leak rate calculations ... that the appliance has no leaked in excess of the applicable leak rate for one year."
  5. New recordkeeping requirement for technicians evacuating refrigerant from appliances with a full charge 5-50 lbs of refrigerant for purposes of disposal. On January 1, 2018, this new recordkeeping requirement takes effect and records must be kept documenting the activity for at least three years. 

Ultimately, these changes to EPA 608 are best practices that maximize the recovery, recycle, and reclaim of refrigerant with high ODP and global warming potential (GWP).

Keep in mind that, by 2030, the global demand for energy will grow by 50% (US NIC 2012), and energy conservation measures will be necessary to meet this demand for a healthy, sustainable planet for all. 

Well, that concludes our top 5 things to know about the update to EPA 608!

It’s our job to help you prepare for the new EPA refrigerant regulations.

So here's a fast and easy way to prepare you and your workforce: Our free handy EPA 608 Update presentation slides. 

Get Your Free EPA 608 Update Presentation Slides

(We created these slides, so that you can refresh yourself on the EPA 608 Update in a fast and easy way!)

Don't be at the whim of regulatory changes!

Get the slides now. 

Topics: HVAC/R, Compliance Reporting, Industry Insights, Refrigerant Compliance, Refrigerant Management

Elizabeth Ortlieb

Written by Elizabeth Ortlieb

With an extensive background in public affairs and communications, Elizabeth serves as the Policy & Content Manager at Trakref, where she tracks HVAC/R policy trends and provides updates to multi-level stakeholders. Email the author at eortlieb@trakref.com