See the latest EHS federal and state regulatory updates due to COVID-19

Refrigerant Management Services

Trinity Chemical Compliance: Ozone Depleting Substances

Trinity can provide support and guidance to help clients ensure compliance with these regulations, including the following types of tasks:

  1. Developing refrigerant management compliance programs and operating procedures
  2. Conducting facility-wide refrigerant management compliance audits and gap assessments, and helping sites resolve the issues identified by these assessments
  3. Implementing Trinity's Refrigerant Tracking Tool spreadsheet to satisfy recordkeeping requirements for appliance inventories, leak rate calculations, leak repair verification testing, appliance disposal, etc.
  4. Training technicians and environmental staff to follow updated procedures and maintain required documentation

Trinity has published several articles outlining the regulatory updates associated with this rulemaking. Additionally, Trinity has several recorded webinars listed below that provide valuable training on this regulation. 

Refrigerant Management Rule Overview

The refrigerant management regulations contained in 40 CFR 82, Subpart F have been in place since the 1990s. The regulations promote the recovery, recycling, and reclamation of refrigerants used in stationary appliances through a prohibition on intentional venting, sales restrictions, technician certification requirements, disposal requirements, and leak repair provisions for large appliances (i.e., those appliances with at least 50 pounds of regulated refrigerant in a single circuit).

In late 2016, EPA significantly revised Subpart F, including extending the requirements to cover substitute refrigerants that do not contain ozone-depleting substances (ODS), overhauling the leak repair provisions for large appliances, and requiring more stringent recordkeeping for appliance disposal. However, in March 2020, EPA rescinded the revisions that extended leak repair provisions to appliances using substitute refrigerants. All other portions of the 2016 rule remain in place.

Who Needs Refrigerant Compliance Support?

The types of equipment that are covered under this regulation range from window air conditioners in offices to large chillers at chemical plants and refineries. Due to the commonplace nature of refrigerant-containing equipment, a wide range of industries are impacted by this regulation. Additionally, many facilities rely on contractor technicians to work on these units. As a result, the compliance obligations associated with 40 CFR 82, Subpart F are commonly misunderstood and/or overlooked.

Other Refrigerant-Related Expertise

In addition to compliance obligations for stationary appliances under 40 CFR 82, Subpart F, several other requirements apply to ODS-containing refrigerants and associated substitutes. Trinity is able to provide compliance support in the following areas:  

  • Evaluating the economic impacts of the refrigerant phase-out schedule for a facility's operations.
  • Assessing a facility's compliance with applicable import and export restrictions on refrigerants
  • Identifying applicable requirements and developing compliance strategies for motor vehicle air conditioners (MVAC) under 40 CFR 82, Subpart B
  • Significant New Alternatives Policy (SNAP) program approvals  

Trinity Can Help - Contact Us Today

Mr. Kirk Lowery is Trinity's foremost expert on refrigerant requirements. Mr. Lowery or a member of his team can be available to provide custom training to your staff or other refrigerant-related services upon request. Please contact Kirk Lowery or Ellen Hewitt if you have any questions or would like to request custom training.

Related articles for more information

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