Compliance Management Plan

To comply with the Clean Air Act, an equipment owner needs a defined and documented refrigerant compliance program. The checklist below provides a number of required and recommended actions your facility should take to make sure you are in compliance. Simple Checklist

Develop Policy and Procedures
  • Develop an unintentional refrigerant venting, leaking, and reporting policy for your refrigerant appliances, equipment, and refrigerant inventory.
  • Develop a policy for conducting annual internal refrigerant-compliance GAP-analysis surveys to ensure that your organization is in compliance with all EPA requirements.
  • Develop a refrigerant-inventory management policy including disbursement, cradle-to-grave record keeping, and audit tracking of all refrigerants.
  • Develop a process and infrastructure to collect, distribute, and communicate the various refrigerant regulations updates and amendments issued by the EPA.

Required Documentation
  • Keep copies of the various EPA regulations and requirements applying to refrigerants and their uses and make sure employees managing air conditioning and refrigeration equipment understand these regulations and requirements and how they impact their jobs. Be sure to stay abreast of the various updates, amendments, and changes the EPA has issued on the original refrigerant regulations.
  • Make sure you and your HVACR employees are aware of EPA's non-compliance penalties and enforcement actions.
  • Maintain EPA certifications for all in-house and contracted technicians working at your facility.
  • Develop a written statement that documents your "intent to comply" with EPA refrigerant-regulations. provides a SAMPLE Refrigerant Management Policy for Facilities.
Sample Policy PDF
Sample Policy Word Document

Operations Fulfillment, Personnel
  • Have a written job description for a facility manager, responsible for refrigerant management and compliance with regulations, as EPA recommends in its Action Guide.
  • Officially designate someone as your refrigerant compliance manager. The EPA will want to speak to this person during a refrigerant-compliance inspection.
  • Have your refrigerant-compliance manager formally trained in EPA refrigerant regulations compliance management to ensure effective and complete implementation of your refrigerant compliance program.
  • Make sure your refrigerant-compliance manager has the financial resources and authority to implement your organization's refrigerant compliance program.
  • Develop a written refrigerant purchase policy and a designated certified technician or contractor responsible for all purchases.
  • Provide all maintenance personnel with written EPA refrigerant compliance policies and procedures manuals.
  • Communicate EPA refrigerant compliance policies and procedures to all affected personnel by holding documented compliance training sessions.
  • Conduct ongoing EPA refrigerant regulations training for your technicians and other affected personnel that includes updates, amendments and changes issued by the EPA.

Operations Fulfillment, Record Keeping
  • Establish an EPA-required refrigerant usage record keeping policy, including a defined and uniform method of collecting, maintaining, and making records available to EPA inspectors upon request.
  • Establish a written appliance-servicing policy including EPA compliance requirements and specific refrigerant handling procedures.
  • Establish a written labeling policy for refrigerant cylinders and appliances using refrigerants per EPA requirements;
  • Establish a written refrigerant inventory and storage policy incorporating national and state regulations and building codes.

Operations Fulfillment, Safety/Liability Concerns

  • Develop a written leak-testing process and defined service procedures for positive-pressure equipment to ensure EPA compliance.
  • Develop a written refrigerant emergency-response plan including policy for major venting incidents, maximum exposure levels, and evacuation procedures.
  • Add "contractor EPA refrigerant-compliance requirements" language into your service-maintenance agreements to ensure that your contractors are not exposing you to liability.

Operations Fulfillment, Equipment/Materials Handling
  • Develop a written policy for disposal of refrigerant equipment and parts.
  • Develop a written policy for disposal of used refrigerant lubricants.
  • Develop a written policy for shipping and transporting refrigerants, both into and out of your facility.
  • Develop a written refrigerant safety policy for handling all refrigerants, including required safety equipment and procedures.