Making Your Business Compliant

To comply with federal and state laws regulating refrigerant emissions, HVACR contractors should develop policies and procedures for their employees to follow. PhaseOutFacts.org has prepared the following checklist to help you make your business compliant with these laws. This list is not meant to be exhaustive, but rather a simple checklist to cover the basics.
  • Your technicians must have EPA Section 608 certification if they are servicing refrigeration and air conditioning equipment containing CFCs or HCFCs.
  • Require all technicians to locate and repair leaks instead of “topping-off” leaking systems. Prohibit technicians from intentionally releasing any refrigerant when servicing, repairing, or maintaining equipment. In most cases, they should use EPA certified refrigerant recovery equipment during service, maintenance or repair.
  • Complete and submit EPA's Refrigerant Recovery and Recycling Device Acquisition Certification Form to certify, in writing, that you have and will properly use EPA-certified refrigerant recovery and recycling equipment.
  • Require technicians to recover refrigerant during servicing.
  • Make sure your technicians understand the difference between “recovered,” “recycled” and “reclaimed” refrigerant.  
    • A recovered refrigerant is one that was removed from refrigeration or air conditioning equipment and stored in an external container WITHOUT necessarily being tested or processed in any way. Reuse is restricted to the system that it was recovered from, or in any other system owned by the same equipment owner.
    • A recycled refrigerant has been extracted and cleaned for reuse WITHOUT being tested for compliance with the stringent AHRI Standard 700 purity specifications required for reclaimed refrigerant. Reuse of recycled refrigerant is restricted to the system that it was recovered from, or in any other system owned by the same equipment owner; otherwise, it must be sent to an EPA-certified reclaimer to restore it to AHRI Standard 700 purity specifications prior to resale.
    • A reclaimed refrigerant has been reprocessed using specialized machinery and tested to meet AHRI Standard 700 purity specifications.
  • Before disposing of equipment, you are legally responsible for properly recovering HCFCs from existing refrigeration and air conditioning systems. You may send recovered HCFC refrigerants to be reclaimed or destroyed.