Trinity Chemical Compliance: Ozone Depleting Substances
Trinity can provide support and guidance to help clients ensure compliance with these regulations, including the following types of tasks:
- Developing refrigerant management compliance programs and operating procedures
- Conducting facility-wide refrigerant management compliance audits and gap assessments, and helping sites resolve the issues identified by these assessments
- Implementing Trinity's Refrigerant Tracking Tool spreadsheet to satisfy recordkeeping requirements for appliance inventories, leak rate calculations, leak repair verification testing, appliance disposal, etc.
- Training technicians and environmental staff to follow updated procedures and maintain required documentation
Trinity has published several articles outlining the regulatory updates associated with this rulemaking. Additionally, Trinity has several recorded webinars listed below that provide valuable training on this regulation.
Refrigerant Management Rule Overview
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 However, in March 2020, EPA rescinded the revisions that extended leak repair provisions to appliances using substitute refrigerants.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.
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.
Other Refrigerant-Related Expertise
In addition to compliance obligations for stationary appliances under 40 CFR 82, Subpart F, several other requirements apply to ODS-containing refrigerants and associated substitutes. Trinity is able to provide compliance support in the following areas:
- Evaluating the economic impacts of the refrigerant phase-out schedule for a facility's operations.
- Assessing a facility's compliance with applicable import and export restrictions on refrigerants
- Identifying applicable requirements and developing compliance strategies for motor vehicle air conditioners (MVAC) under 40 CFR 82, Subpart B
- Significant New Alternatives Policy (SNAP) program approvals
Trinity Can Help - Contact Us Today
Mr. Kirk Lowery is Trinity's foremost expert on refrigerant requirements. Mr. Lowery or a member of his team can be available to provide custom training to your staff or other refrigerant-related services upon request. Please contact Kirk Lowery or Ellen Hewitt if you have any questions or would like to request custom training.
Related articles for more information
- Leak Repair Provisions No Longer Applicable to Substitute Refrigerants - Mar 24 2020
- Refrigerant Management Rule Revisions Released from OMB and sent to EPA to be Finalized - Feb 13 2020
- The Latest Unofficial News on the Refrigerant Leak Repair Provisions: No Compliance Extension -- Dec 17, 2018
- Refrigerant Management Rule - Ready or Not -- Dec 07, 2018
- Refrigerant Rule Revision Final Compliance Deadline Fast Approaching -- Jun 21, 2018
- Are You Ready for the New Refrigerant Management Requirements? -- Jun 20, 2018
- Refrigerant Rule Revisions: Is Your Facility Prepared -- Dec 04, 2017
- ODS Rule Updates - Are You Prepared -- Jun 20, 2017
- EPA Releases Advance Copy of Final Protection of Stratospheric Ozone Rule -- Nov 04, 2016
Webinars - On Demand
- Complimentary Webinar - Final Updates to Refrigerant Management Requirements - Free
- Refrigerant Management Rule Webinar - Preparing for Compliance and Understanding the Proposed Changes - $49.00