Environmental Permitting

9 Tips for Keeping Cool Refrigerant Records

EPA’s regulations for safeguarding and repairing the stratospheric ozone layer include provisions for the servicing and disposal of refrigeration and air-conditioning equipment. Under these regulations, a “refrigerant” is defined as any substance consisting of, or is part of, a Class I or Class II ODS that is used for heat transfer purposes and provides a cooling effect.

The regulations for the servicing and disposal of refrigeration and air-conditioning equipment include:

  • The recapture and recycling of ozone-depleting chemicals from air-conditioning and refrigeration equipment to the maximum degree;
  • Certification requirements for technicians, reclaimers, and recovery equipment;
  • Restrictions on the sale of refrigerant to certified technicians;
  • Requirements that anyone who services or disposes of air-conditioning or refrigeration equipment to certify to the EPA that they have the proper equipment and are in compliance with the rule; and
  • Requirements for the  safe disposal methods for disposed equipment containing refrigerant.

Anyone with equipment with charges of more than 50 pounds (lb) of refrigerant is required to repair leaks in the equipment when the leak rates exceed a certain percentage of the charge over a year. For commercial and industrial process refrigeration, the leak rate requiring repair is 35 percent or more of the charge in a year. For comfort-cooling appliances and other appliances, leaks must be repaired when the leak rate is 15 percent or more. The leak rate must be calculated each time refrigerant is added to the appliance.

Compliance with refrigerant handling and appliance and equipment repair requires a lot of paperwork and recordkeeping.

Join us for the UST Repairs, Inspection, Maintenance and Testing webinar on June 3 to learn how to satisfy UST monthly inspection requirements. Learn more.

All Refrigerant Records

Tip 1: Make sure all records are legible.

Tip 2: Keep all records for a minimum of 3 years.

50 lb or More of Refrigerant

Tip 3: Service records for appliance and refrigeration equipment that normally contain more 50 lb or more of refrigerant must include:

  • Date and type of service;
  • Quantity of refrigerant added, which is usually recorded on an invoice or other documentation provided by whoever performed the service; and
  • Certification of the technician who performed the service.

Tip 4: Records in instances where you add your own refrigerant to equipment that contains 50 lb or more of refrigerant must include:

  • Date and quantity of refrigerant purchased;
  • Date and quantity of refrigerant added; and
  • Certification of the technician who added the refrigerant.

Equipment Repair

Tip 5: Records of repairs to equipment must include:

  • Date and types of repair;
  • Dates, types, and results of all initial verification tests; and
  • Dates, types, and results of all follow-up verification tests.

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Retrofitted or Retired Equipment

Tip 6: Records for appliances/equipment you intend to retire or retrofit must include:

  • Identification of the industrial process facility;
  • Leak rate;
  • Method used to determine leak rate and full charge;
  • Date leak rate above the allowable leak rate was discovered;
  • Location of leaks to the extent determined  to date;
  • Any completed repair work and date it was completed;
  • Certification records of technicians who did the repair work;
  • Plan to complete the retrofit or retirement and if it going to take more than 1 year, the reason why;
  • Date of notification to the EPA; and
  • An estimate of when the retrofit or retirement will be completed.

Tip 7: If the estimated date of completion must be extended, submit a new estimated date of completion to the EPA, along with the reason it had to be moved forward, within 30 days of discovering the need for the change. Keep a dated copy of this submission.


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