Refrigerant Management Services (ODS)

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 However, in March 2020, EPA rescinded the revisions that extended leak repair provisions to appliances using substitute refrigerants.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, including the requirement to submit chronic leaker reports by March 1.

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.