EPA 608 Core Chapter 4
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In this module, we will walk through the Clean Air Act (CAA) and the EPA regulations that apply to us as HVAC technicians. Skip to quiz!
History of the Clean Air Act
Did you know that the US experienced severe air pollution in the 1940s and 1950s?
One of the worst cases of air pollution took place in 1948 in Donora, PA.
A thick smog containing harmful air pollutants covered the streets of Donora. In a matter of days, nearly half of the town’s 14,000 residents developed respiratory and other health problems. Nearly 40 people died.
What happened in Donora was part of a pattern happening across the country. Air pollution affected both big cities and small industrial towns. It became clear that air pollution directly affected people’s health. As a response to this, Congress passed the Clean Air Act, making it a federal law.
Clean Air Act Regulations
The purpose of the Clean Air Act (CAA) is to establish standards for the nation’s air quality.
Over the years, Congress passed several amendments to the Clean Air Act to add protections to the environment and to people’s health. In 1990, Congress passed amendments that included Section 608.
Section 608 of the Clean Air Act includes specific provisions regarding ozone protection. For example, it requires that technicians pass this exam in order to handle and buy refrigerants affect the ozone layer.
We will talk more about the specifics of Section 608 later in the blog.
This section of the Clean Air Act is regulated by the Environmental Protection Agency (EPA).
The penalties for any violations of the Clean Air Act include:
Civil fines of up to $44,539 per day per violation (as of 2017)
Criminal prosecution in US Federal Court (5 years, or double if it’s a second offense)
Confiscation of violating substances (refrigerants)
Loss of certification to handle refrigerants
In addition to the Clean Air Act, which is a federal law, many state and local governments impose additional restrictions.
These regulations may be equally or more stringent than those of the Clean Air Act. So in order to operate as a technician, you also need to be up to date on state and local laws.
SNAP (Significant New Alternatives Policy) Program
In a separate section of the Clean Air Act, the EPA also established SNAP, which stands for Significant New Alternatives Policy. The SNAP program was established to evaluate alternative refrigerants that are lower risk for humans and the environment.
SNAP is not just a list of substitute refrigerants. It is an ongoing program that changes recommendations as the EPA evaluates new information on how refrigerants affect the environment.
As technicians, it is your responsibility to keep up with current EPA guidelines.
The Clean Air Act is a key piece of legislation in American history. Its main purpose is to control pollution that was increasingly putting lives at risk.
As HVAC technicians, this matters to us because the refrigerants we used in older systems depleted the ozone layer. Regulation of these refrigerants falls under the Clean Air Act.
Venting Prohibition
In this module, we will walk through what venting is and discuss the venting prohibition included in the Clean Air Act.
Venting Refrigerants
Venting refers to the release of refrigerants into the atmosphere.
The Clean Air Act states that it is a violation to purposely vent refrigerants that deplete ozone. Recall that this is because the ozone layer is essential in protecting humans from harmful UV rays.
Specifically, it is illegal to knowingly vent CFCs, HCFCs, and their substitutes (including HFCs) into the atmosphere.
To prevent venting, technicians must follow all proper procedures during
Servicing
Maintaining
Repairing, and
Disposing of appliances with these refrigerants.
If a technician purposely vents these refrigerants, they are subject to fines and criminal prosecution. As of 2017, penalties for venting include a fine of up to $44,539 per day per violation.
For example, this means that with two violations over three days, you can be fined up to $267,234!
The EPA offers an award of up to $10,000 to individuals who supply information against a technician who deliberately vents. So, if you come across any violations, do contact the EPA.
Illegal Venting
Recall that recovering means to capture the refrigerant in a separate storage cylinder.
In order to not vent affected refrigerants, it is necessary to recover refrigerants before servicing or disposing off equipment that contains those refrigerants. This is to prevent any loss of refrigerant stored in the equipment during servicing or disposal.
At the end of recovery service, technicians need to make sure that there is no liquid refrigerant trapped in the service hose. Any refrigerant trapped in the hose will be vented and this is not allowed under the Venting Prohibition.
Venting does not include losses of refrigerant during routine handling and service, provided that equipment has all appropriate low loss fittings.
If refrigerant is released because your equipment does not have low loss fittings, this is illegal venting.
In addition, you must also evacuate refrigerant to a required evacuation level while servicing equipment that contains the affected refrigerants. This also prevents venting. If you do not perform this step, this is also considered illegal venting under the Clean Air Act.
And lastly, when leak checking an appliance, never add pressurized nitrogen to a fully charged appliance. This will contaminate the refrigerant in the system and make it impossible to reclaim.
In addition, if there is a leak, pressurizing a leaking system with refrigerant inside will only vent the refrigerant still left inside.
Imagine a water balloon with a hole. If you add water to the balloon using a high pressure garden hose, the water will spill faster from the balloon.
To prevent from illegal venting, you must first recover and evacuate the appliance to required levels. This applies to appliances that are fully charged or even partially charged. As long as there is some refrigerant left in the system, you must recover it before leak testing.
De Minimis
What if small amounts of refrigerant are released accidentally during servicing? There is a rule with an exception to the regulation called the ‘de minimis rule’ for this purpose.
De minimis means something is too insignificant to be considered or is too small in amount to lack importance. De minimis provides for conditions out of the technician’s control that are true accidents.
De minimis refers to release of substances during good faith attempts to recapture, recycle, or safely dispose of refrigerants. This rule only applies if technicians have taken all necessary precautions and followed proper servicing protocol.
De minimis release includes:
Catastrophic equipment failure
Accidental release with timely repair of appliances
Releases when connecting or disconnecting hoses to charge or service appliances. (Equipment must be equipped with low loss fittings for this to apply.)
Exemptions
The EPA exempts refrigerants from the venting prohibition when it has determined that these refrigerants do not post a threat to the environment.
Natural refrigerants are exempt from the regulations of venting prohibition. This means that they can be vented.
Natural refrigerants can be vented because they do not cause damage to the ozone layer.
Natural refrigerants include:
- R-290 (propane)
- R-600a (isobutane)
- R-717 (ammonia)
- R-728 (nitrogen)
- R-744 (carbon dioxide)
These refrigerants are substances naturally found in the world around us. Carbon dioxide and nitrogen, for example, are gases that are found naturally in the atmosphere.
In this module, we discussed the venting prohibition portion of the Clean Air Act. The venting prohibition applies to all refrigerants that deplete ozone, as well as their substitutes.
The purpose of the venting prohibition is to prevent these harmful chemicals from being released into the atmosphere and destroying ozone.
Montreal Protocol
In this module, we will walk through what the Montreal Protocol is.
Overview
Signed in 1987, the Montreal Protocol is an international treaty between 197 countries, including the United States. The treaty is a commitment among all 197 countries to protect the ozone layer.
This treaty focuses on phasing out ozone-depleting refrigerants. This meant chlorofluorocarbons (CFCs) and Hydrochlorofluorocarbons (HCFCs) refrigerants. As discussed in our Ozone Depletion module, CFC and HCFC refrigerants destroy the ozone layer.
In 2016, the Kigali Amendment was passed to update the agreements set forth in the Montreal Protocol.
In the Kigali Amendment, member countries committed to also phase out HFCs. This is because although HFCs do not destroy the ozone layer, they contribute to global warming.
Phasing Out Refrigerants
As part of the Montreal Protocol, the United States committed to end the use of substances that deplete the ozone layer. Phase out dates set in the Montreal Protocol indicate the date after which a refrigerant is completely banned from being produced or imported.
However, refrigerant contained in equipment manufactured before the phase out date can still be used, bought or sold.
Note that refrigerant needs to be reclaimed or reprocessed to virgin specifications before it can be sold to another person. We will discuss this process more in the next module.
Technicians can still service equipment that uses CFCs or HCFCs after the phase out date. This includes replacing failed components in equipment that contains these refrigerants.
After the phase out date, if equipment containing CFCs or HCFCs needs to be serviced, refrigerant needs to come from exemptions under the Montreal Protocol. Exemptions refer to refrigerant that is available in recovered, recycled, or reclaimed appliances only.
According to the Montreal Protocol, all countries under the agreement must completely phase out HCFCs by 2030.
In the United States, all CFCs were phased out on December 31, 1995.
Additionally, the U.S. is in the process of completely phasing out HCFCs as well. The most harmful HCFCs were phased out on January 1, 2020. This includes the primary HCFCs used in systems in the U.S., which are R-22 and R-142b.
With the phaseout of R-22 and R-142b in 2020, the U.S. has reduced HCFC consumption by 99.5%. All other production and import of HCFCs will be banned in January of 2030, completing the phase out of all HCFCs.
Recall that R-22 is a CFC refrigerant. Let’s say a technician completes a major repair on a system with R-22 refrigerant today. We know that R-22 has already been phased out, but the technician can still use R-22 that is recovered or reclaimed.
What the technician cannot is top off with a different refrigerant. This would mix the refrigerants and may make the mixture of both of the refrigerants impossible to reclaim. If the mixture is sent to a reclaimer, they may refuse to reclaim it and destroy the refrigerant at the owner’s expense. This can get very expensive!
Let’s take a look at a short video on the effects of phasing out refrigerants.
The Montreal Protocol is an international agreement between 197 countries to phase out the use of chemicals that deplete ozone. Along with the Clean Air Act, the Montreal Protocol has been critical in reducing the amount of ozone depleting substances in the atmosphere.
The good news is that due to the Clean Air Act and the Montreal Protocol, the ozone layer is healing. Ozone is produced naturally in the atmosphere, and without ozone depleting refrigerants, levels of ozone are increasing to their natural levels again.
Because of this, ozone levels should return to normal levels by about 2065.
AHRI Standard 700
In this module, we will go over AHRI Standard 700 and what it means for us as HVAC technicians.
Air Conditioning, Heating, and Refrigeration Institute
AHRI stands for Air Conditioning, Heating, and Refrigeration Institute.
It is a trade association for the manufacturers of HVAC equipment that develops standards and guidelines for modern industry-accepted practices.
The AHRI sets specific standards for recovering and reclaiming refrigerants. Recall that recovering refers to removing refrigerant from a system and storing it in a separate container.
AHRI is one of two certified organizations by the EPA to set these standards.
Reclaiming Refrigerants
Reclaiming refrigerant means to reprocess it. Reprocessing is a set of steps that clean the refrigerant and basically make it new.
You can think of a place that reclaims refrigerants like a dishwasher. A dishwasher goes through cycle that washes your dishes and make them usable again.
It’s the same as reclaiming refrigerant. Reclaiming removes impurities so it’s basically new again.
To reclaim the refrigerant, you must first recover the refrigerant from the appliance. After the refrigerant is recovered, it is then sent to a EPA-certified facility to be reclaimed.
Reprocessed refrigerant must meet the specifications of a ‘new’ refrigerant for resale.
AHRI Standard 700-2016 determines the standard of purity that reclaimed refrigerants must meet. Refrigerant that is ozone depleting has to meet the standards set in AHRI Standard 700-2016 before it can be resold or change ownership.
For example, if you recover R-22 from a system, you cannot use that R-22 refrigerant in other appliances. The only exception is if you use it in other appliances owned by the same owner.
Otherwise, that recovered R-22 refrigerant needs to be reclaimed to virgin specifications according to AHRI Standard 700, before it can change ownership.
The purity of refrigerants can be verified using analytical test procedures described in the AHRI Standard 700.
AHRI is an organization that produces modern guidelines for the HVAC industry. AHRI Standard 700-2016 dictates the specifications of purity that refrigerant must be reclaimed to before being resold.
Section 608 Overview
In this module, we will look at the purpose of Section 608 and determine which refrigerants it regulates.
Purpose of Section 608
Section 608 includes provisions to protect the ozone layer.
Recall that ozone is a gas found in the Earth’s atmosphere. The highest concentration of ozone is found in the ozone layer. Ozone performs the essential task of blocking out harmful ultraviolet (UV) rays from the sun.
As we discussed in the Ozone module, when chlorine-containing refrigerants are released into the atmosphere, they destroy the ozone layer. This results in increased risk of skin cancer, among other threats to human, animal, and plant life.
Section 608 focuses on regulating refrigerant chemicals that contain chlorine. These are the most harmful to the ozone layer.
Affected Refrigerants
So which specific refrigerants are covered under Section 608?
Recall that the refrigerants most harmful to the ozone layer are:
CFCs, or chlorofluorocarbons. Examples: R-11 and R-12
HCFCs, or hydrochlorofluorocarbons. Example: R-22
Section 608 refrigerant management requirements apply to all CFCs, HCFCs, and their substitutes.
This includes HFC refrigerants, which were developed as an alternative to CFCs and HCFCs. HFCs do not destroy ozone, but they do contribute to global warming. This is why HFCs are also subject to Section 608 regulations.
Section 608 regulations apply to all appliances that contain ozone depleting refrigerants.
These appliances include:
Freezers
Air conditioning equipment
Commercial refrigeration equipment
All substances contained in these appliances are considered refrigerants, since they are used for cooling purposes.
Excluded Refrigerants
If a refrigerant is not a CFC, HCFC, or HFC, then the Section 608 regulations, which we will discuss in the next module, does not apply to them.
For example, this would be the natural refrigerants that we discussed in the Venting Prohibition module.
Section 608 regulations on refrigerant management do not apply to natural refrigerants such as:
Carbon Dioxide
Nitrogen, and water
Water
These natural refrigerants are not harmful to the ozone layer.
We will discuss the specific management requirements of the affected refrigerants in the next module. But note that these requirements we will discuss do not apply to natural refrigerants. If you are interested to know more, see 40 CFR § 82.154 for a list of complete exemptions.
Certification
Section 608 certification is necessary for any technician who services a part that comes into contact with affected refrigerants.
For example, if a technician is replacing a system component with R-22, they need Section 608 certification. This is because you would need to first recover the refrigerant to prevent it from illegally venting. And any handling of ozone depleting refrigerants and their substitutes requires Section 608 certification.
To summarize, you would need Section 608 certification for the following services:
Recovering refrigerant
Replacing system component, and
Any activity that violates the refrigerant circuit.
The refrigerant circuit is the flow of refrigerant in the system. If your service interrupts the flow of refrigerant in any way, you need Section 608 certification. If you are not coming into contact with refrigerant and not altering the refrigerant circuit, then you don’t need certification.
An example of a service that does not violate the refrigerant circuit would be replacing an external electrical circuit. External circuits do not touch refrigerant inside the coils where refrigerant is, so you would not need certification.
Section 608 regulates the use of refrigerant chemicals that contain chlorine to prevent ozone depletion. The regulatory requirements apply to CFC, HCFC, and HFC refrigerants and to equipment that contain these refrigerants.
In the next module, we’ll take a look at the specific requirements that we have to follow for these refrigerants.
Section 608 Regulations
In this module, we will walk through the specific regulations of Section 608.
Main Regulatory Requirements
Recall that this set of regulations is regulated by the EPA and subject to change. As a technician, it is your responsibility to be up to date on the latest EPA regulation changes. There likely are additional state and local regulations on refrigerant use that you’ll have to know.
In order to protect the ozone layer, Section 608 regulates the following:
1. Equipment Requirements
2. Sales Restrictions
3. Major Recordkeeping Requirements
4. Safe Disposal
5. Reclamation Specifications
6. Service Requirements
These Section 608 regulations apply to all ozone depleting refrigerants and their substitutes. This includes CFCs, HCFCs, and HFCs.
Equipment Requirements
Any equipment used to service systems with ozone-depleting refrigerants must be certified by an EPA-approved testing organization. Equipment must be up to EPA standards to eliminate the risk of accidentally releasing refrigerant.
Let’s say you are servicing a system containing R-22 refrigerant. All the equipment you are using to service the system must be certified by an EPA-approved testing organization. For example, this includes your recovery device.
Currently, the EPA has approved two bodies to certify such equipment:
AHRI (Air-Conditioning, Heating, and Refrigeration Institute) and
UL (Underwriters Laboratories).
Sales Restrictions
Only certified technicians can purchase ozone-depleting refrigerants or their substitutes.
If you are selling refrigerants, you must check that the buyer has Section 608 Certification or employs a technician that is Section 608 certified.
Recordkeeping Requirements
The following people need to maintain proper records of refrigerants:
Service technicians
Owners and operators of large refrigeration and air-conditioning equipment
Refrigerant wholesalers, and
EPA-certified refrigerant reclaimers
All responsible parties must keep records documenting:
Dates
Refrigerant type
Refrigerant charge amounts (quantity), and
Related information for equipment servicing and disposal
The purpose of these recordkeeping requirements is to keep track of the amount and type of refrigerant in the cylinder.
Refrigerant charge, for example, is need on records because it indicates how much refrigerant is in the cylinder. The refrigerant type also needs to be indicated because technicians cannot mix different refrigerants together.
Safe Disposal
Before disposing off refrigeration and air conditioning equipment, you must make sure that all refrigerant has been removed from the appliance. The final person in the disposal chain is responsible for making sure this happens.
Reclamation
Recall that reclamation refers to the reprocessing of refrigerant to at least the purity level specified in the AHRI Standard 700-2016.
If refrigerant changes ownership, it must be reclaimed to virgin specifications per AHRI Standard 700. This process of reprocessing must be done by a reclaimer that meets EPA certification requirements.
Service Requirements
And finally, technicians need to evacuate air conditioning equipment to established vacuum levels during servicing and disposal.
Recall that evacuating refers to removing unwanted substances from the system. Doing this prevents premature failures of the equipment that can release refrigerant into the atmosphere.
Other Violations
If refrigerant is released during theft or vandalism, this is also a violation of Section 608. All offenders will be subject to the same penalties for Clean Air Act violations as previously discussed.
Something else to keep in mind is that if we are working on a system with Refrigerant A, we cannot top off the system with any other refrigerant. If we are working with a system that runs on R-22, for example, we cannot top off with R-410a or any other refrigerant except for R-22.
If you top off with a different refrigerant than what is in the system, then the mixture cannot be used. The mixture may now be impossible to reclaim and may have to be disposed of. If you send this mixture to a reclaimer, they may refuse to accept it and destroy the refrigerant at the owner’s expense.
If you discover that you have accidentally mixed two refrigerants, you must recover the mixture in a separate recovery cylinder for disposal. You need a separate recovery cylinder because you don’t want this mixture to contaminate the contents of other cylinders.
Section 608 lays out a framework of regulatory requirements. The purpose of these requirements is to set restrictions on the use of refrigerants that are harmful to humans and the environment.
All violations of Section 608 are violations of the Clean Air Act. We previously discussed the fines and legal consequences for such violations. That is why it’s important that technicians are aware and up to date on these regulations, in addition to any state and local laws.
Question #1: Section 608 of the Clean Air Act is:
A set of federal guidelines on limiting air pollutants
Federal law
State law
A global treaty
Scroll down for the answer...
Section 608 of the Clean Air Act is a federal law.
Question #2: What is the purpose of Section 608? (Choose all that apply)
To protect the ozone layer
To regulate use of chemicals that deplete ozone
To raise money through fines
Economic reasons
Scroll down for the answer...
The main provisions of Section 608 are to protect the ozone layer by regulating chemicals that destroy it.
Question #3: What is the fine for violating the Clean Air Act (as of 2017)?
They will lose their certification but will not be charged a fine
$608 per day per violation
$2000 per day per violation
$44,539 per day per violation
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The fine for violating the Clean Air is up to $44,539 per day per violation
Question #4: What penalties can technicians face if they violate the Clean Air Act? (Choose all that apply)
They may lose their Section 608 certification
They may face federal charges
They may have to do community service
They may be fined
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All of these, except for 3, are penalties for violation of the Clean Air Act.
Question #5: State and local regulations _______ (Select all that are true)
Have to be followed in addition to federal CAA regulations
Have to be followed instead of federal CAA regulations
May be stricter than federal CAA regulations
Are a suggestion
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Both federal and local regulations must be followed. Local and state regulations may be stricter. It is the technician’s responsibility to keep up with the changes in legislation.
Question #6: What does SNAP stand for?
Significant New Alternatives Policy
Science New Alliances Policy
Science Neutral Alliances Policy
None of these
Scroll down for the answer...
SNAP stands for Significant New Alternatives Policy.
Question #7: What is the purpose of SNAP? (Select all that are true)
To evaluate alternative refrigerants
To further the goals of the CAA
To consider effects of substitute refrigerants on humans
To consider effects of substitute refrigerants on the environment
Scroll down for the answer...
All of these are true.