What is the HFC Management Rule?

Federal regulations for refrigerants, specified in 40 CFR 82 and 84, implement the Clean Air Act and the AIM Act. These rules apply to all entities handling refrigerants, whether it be technicians, industrial facilities, or reclaimers. Examples of facilities subject to these requirements include industrial facilities with chillers, perishable goods distribution facilities, universities, commercial buildings, supermarkets, and data centers.

40 CFR 82, Protection of Stratospheric Ozone, has been around since the 1990s and regulates ozone depleting substances (ODS). While 40 CFR 82 contains similar types of requirements to 40 CFR 84, 40 CFR 84, Subpart C applies more broadly to many refrigerants that were not regulated under 40 CFR 82 and to appliances with smaller refrigerant charges.

40 CFR 84 Subpart C, Management of Regulated Substances, was published on October 11, 2024, to describe requirements for appliances containing refrigerants. A regulated substance is a hydrofluorocarbon (HFC) listed in the American Innovation and Manufacturing (AIM) Act. 40 CFR 84 Subpart C specifies requirements for maintaining appliances containing more than 15 pounds of regulated substances and substitutes1, in addition to the installation of automatic leak detection systems (ALDS) on commercial and industrial system with more than 1,500 pounds of refrigerants containing regulated substances and substitutes. The compliance dates for 40 CFR 84 Subpart C begin on January 1, 2026.

What are the 40 CFR 84 Subpart C Requirements?

Leak Repair

This subpart describes procedures for the leak repair of refrigerant-containing appliances with a full charge of more than 15 pounds of refrigerant, when the refrigerant contains a regulated substance or a substitute for a regulated substance with a global warning potential (GWP) greater than 532. Three groups of appliances that are subject to the repair provisions: comfort cooling appliances (and anything not otherwise classified), commercial refrigeration appliances, and industrial process refrigeration appliances. Each group subject to repair provisions has a different leak trigger rate as described below.

• Comfort Cooling Appliances, Refrigerated Transport Appliances, or Other Refrigerant-containing Appliances

• Leak Trigger Rate: 10%

• Definition: Air-conditioning appliances used to cool occupied areas or not otherwise classified

• Commercial Refrigeration Appliances

• Leak Trigger Rate: 20%

• Definition: Refrigeration appliances used in retail food and cold storage warehouse sectors

• Industrial Process Refrigeration Appliances

• Leak Trigger Rate: 30%

• Definition: Complex, custom appliances used in chemical, pharmaceutical, petrochemical, and manufacturing industries

Each appliance at the facility will have to calculate a leak rate when refrigerant is added. Appliance leak rates are calculated on either an annual or 12-month rolling average. Both methods are acceptable, so long as the leak rates for all appliances at the facility are calculated using the same method.

If the appliance’s leak rate exceeds the threshold value listed above, 1 of 3 things must be done:

1. The leak should be repaired within 30 days (or 120 days for industrial process shutdown), or
2. The system should be retrofitted within 1 year, or
3. The system should be retired from service within 1 year.

Note, if repair attempts within 30 days of the leak are unsuccessful, there are options to extend the repair window, as described in 40 CFR 84.106(f). Alternatively, the appliance must be retrofitted or retired within 1 year of the plan date per 40 CFR 84.106(h). Once the leak is repaired, the repair must be verified via initial verification testing and subsequent follow-up verification testing within 10 days of the initial verification. Additional leak inspections are required based on the full charge of the appliance and its classification.

If an appliance is found to have a leak rate greater than 125% during a calendar year, it is considered a chronic leaker. Facilities with chronically leaking equipment must submit an annual report to EPA on March 1 of each year, starting March 1, 2027. The report must describe efforts to identify leaks and repair the chronically leaking appliance, along with all information noted in 40 CFR 84.106(m)(4).

Automatic Leak Detection Systems

40 CFR 84 Subpart C also requires ALDS for appliances with more than 1,500 pounds of refrigerants containing regulated substances. New appliances must have an ALDS installed within 30 days of appliance installation. Existing appliances must have an ALDS installed by January 1, 2027.

In the event an ALDS alerts the facility of a leak, the leak rate must be calculated within 30 days. If the leak rate exceeds the relevant trigger rate, the appliance must be repaired within 30 days. ALDS must also be calibrated annually.

Introducing: CoolTracker365™

Trinity has created a Microsoft Excel-based refrigerant tracking tool, which documents information required by 40 CFR 82 and 84. Information recorded in CoolTracker365™ includes:

• Appliance Inventory​

• Certified Technicians​

• Service and Disposal Records​

• Leak Inspections​

• Chronic Leaker Reports​

• ALDS Alarms and Calibrations

If your facility is in need of support to comply with these new refrigerant provisions, reach out to the contacts listed below! Trinity would love to assist you with 40 CFR 84 compliance, whether it be by providing an applicability review or compliance support with CoolTracker365™.

Additional resources regarding refrigerants can be found here:

• New HFC Refrigerant Management Rule – If You Thought You Weren’t Subject, Look Again! – Trinity Consultants

• Refrigerant Management Services (ODS) – Trinity Consultants

Trinity Consultants is here to help! If your facility is subject to 40 CFR 82 or 84 and you need support, please contact:

Jena DeRung, Senior Consultant, Minneapolis, MN, 651.275.9900

Jennifer Markwardt, Managing Consultant, St. Louis, MO, 636.256.5652