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We assist clients through a combination of consulting support, technology-based solutions, professional training, and staffing services.

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Refrigerant Management Services (ODS and HFC)

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Stay Compliant and Protect Operations with Expert Refrigerant Management Solutions

The use of refrigerants, including ozone-depleting substances (ODS), hydrofluorocarbons (HFC), and their substitutes, is tightly regulated under 40 CFR 82, Subpart F and 40 CFR 84, Subpart C. In addition, several states, such as California, Washington, and New Jersey, have additional requirements that need to be met in addition to the federal requirements. These rules impact a wide range of facilities - from office buildings to chemical plants - creating compliance obligations that are often overlooked. We help clients navigate these complex requirements with comprehensive refrigerant management services, ensuring compliance, reducing risk, and safeguarding operations from costly violations.
Service Specifics

Our Refrigerant Management Services

See how Trinity helps organizations design, implement, and maintain effective refrigerant management programs.

We develop refrigerant management compliance programs and operating procedures that align with federal regulations and industry best practices.

Our team conducts facility-wide compliance audits, identifies gaps, and provides practical solutions to resolve compliance issues efficiently.

Trinity implements CoolTracker 365™, a powerful tool for tracking appliance inventories, leak rate calculations, verification testing, appliance disposal, and more.

We prepare chronic leaker reports, support leak repair verification testing, and ensure accurate recordkeeping to satisfy regulatory requirements.

We train technicians and environmental staff to follow proper procedures, maintain required documentation, and stay current with regulatory updates.

Beyond stationary appliances, we also support compliance with import/export restrictions, motor vehicle air conditioner (MVAC) regulations under 40 CFR 82 Subpart B, SNAP program approvals, Technology Transitions implications, and economic evaluations of refrigerant phase-outs.

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In this issue of EHS Quarterly, we examine how environmental consulting plays a pivotal role in turning regulatory challenges into project advantages. By embedding proactive environmental management and permitting strategies early in the capital project lifecycle, organizations can reduce risk, improve outcomes, and create measurable value.
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Refrigerant Management Services for your Industry's Unique Needs

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Refrigerant Management Services FAQs

The refrigerant management regulations in 40 CFR 82, Subpart F were established in the 1990s with substantial updates in 2016 to promote recovery, recycling, and reclamation of ODS used in stationary appliances. The HFC Management Rule in 40 CFR 84, Subpart C is effective on January 1, 2026. The requirements of both rules include leak repair, disposal, technician certification, and recordkeeping.

Yes. In 2016, EPA revised 40 CFR 82, Subpart F, extending requirements to some substitute refrigerants and overhauling leak repair provisions for large appliances. In 2020, EPA rescinded the leak repair requirements for substitutes but retained other provisions, including the requirement to submit chronic leaker reports by March 1 each year. In 2024, EPA finalized the 40 CFR 84, Subpart C requirements that require leak repair for HFCs and substitutes similar to 40 CFR 82, Subpart F.

Any facility with refrigerant-containing equipment may be subject to these regulations. This includes small appliances, office cooling systems, and large industrial chillers at plants and refineries. Because facilities often rely on outside contractors, compliance obligations are frequently misunderstood or overlooked.

Facilities with appliances that repeatedly leak refrigerants above a certain threshold must submit annual chronic leaker reports to EPA. These reports document leaks, repairs, and compliance efforts, and failure to submit them can result in enforcement actions.

Trinity provides full-spectrum support, including program development, audits, chronic leaker reporting, staff training, and implementation of digital tools like CoolTracker 365™ to streamline compliance and reduce risk.

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