How to Start 2019 Compliant

January 23, 2019 / by Ted Atwood and Joel Punausuia



Your building is the epicenter of activity and a beacon of admiration for those passing by. It is more than just concrete and steel and helping maintain it directly impacts the lives of tenants, workers and your wallet. Air conditioning and refrigerant are at the core of what makes it work and without them the building is almost uninhabitable. Although it is the largest energy expense for commercial properties, continuing a cycle of poor maintenance and temporary fixes could cost significantly more in the future. Compliance is key here and the silver lining is this: achieving compliance leads to the potential for substantial savings in both energy and expense.

The always-changing regulatory compliance requirements from the EPA can be confusing, so our experts have read them for you. Relax and comply:

10 Things to Know to Keep You Compliant in 2019

1. ALL refrigerants are subject to federal regulatory requirements like recordkeeping, leak rate limits and safe disposal

This began in 1989 with the Montreal Protocol. This international agreement, one of the first universally ratified treaties in UN history, phased out Class I refrigerants like CFCs and Class II refrigerants like HCFCs. The United States amended the Clean Air Act in 1990 to implement this.

2. Substitute refrigerants are now included which impacts maintenance, reporting, recordkeeping and refrigerant choices

Build your building for the future not today. What equipment currently contains controlled substances and which contain substitutes?

3. It is illegal to dump ALL non-exempt refrigerants during maintenance, service, repair or disposal

The current leak rate in the United States is 25 percent and high concentrations can be detrimental to human and environmental health. This venting violation makes economic sense as costs rise and the refrigerant market tightens.

4. Pay attention to anything at or over 25 tons!

It could be at or over 50 pounds of refrigerant! The date, type of service and amount of refrigerant added must be kept for a minimum of three years. This requirement also includes HFC and other substitute refrigerants.

5. New leak rate thresholds are lower than last month and continue to tighten

Industrial process and commercial refrigeration had a trigger rate of 35 percent; comfort cooling and all other appliances 15 percent. This includes appliances with substitute refrigerants and will get stricter. The trigger rate has drop to 30 percent, 20 percent and 10 percent for industrial processes, commercial refrigeration, comfort cooling and all other appliances respectively.

6. You only have 30 days to fix a leak when it is above the allowable limit

If this is not feasible, you have to mothball the system until the repairs can be made before the 30 days or develop a retrofit or retirement plan. Fixing leaky systems minimizes cost and maximizes energy efficiency.

7. Technicians can only work on systems that match their certification

Ask your techs if their certification is in line with the equipment size and type they are maintaining. The EPA has four types of certification: Type I, Type II, Type III and Universal. You are out of compliance having a technician work on equipment they are not certified for.

8. Anything disposed of between five and 50 pounds must now have a disposal record

Reducing emissions of controlled substances is a key component of Section 608 and this is fulfilled through capturing and recycling. Safe disposal requirements must be met when an appliance reaches the end of its life.

9. The EPA is fast racking refrigerant phase-out

The amount of R-22 that was allowed to be produced until the end of this year was aggressively lowered four years ago.  With R-123 chiller production ending this year, the amount of New R-123 available is extremely low if you do not have a long-term plan.

10. Local and federal regulations are evolving throughout the country

Be on the lookout for mechanical code change that will affect access to and use of your systems. Are you in compliance? Things to think about include the installed inventory, what refrigerant is onsite, how did it get there and where did it go.


Your assets are a critical component to your success and need to be treated differently. Staying up-to-date with the thousands of documents that change yearly can be complicated, especially without a compliance expert on staff. Again, compliance is key. Download our Building Management Inventory form below to DIY 2019 right. This isn’t enough to be compliant but is a great place to start!

Download Building Inventory Form

This is where our program comes in handy. Trakref is a crowdsourced environmental management software designed with the mechanic in mind. All of this regulation is built-in and compliance 100 percent guaranteed with a simple push-button design. We’re here to empower industrial evolution with accessible solutions.

Topics: HVAC/R, Compliance Reporting, Refrigerant Compliance, Refrigerant Management, compliance, epa 608, performance