• SkillCat Team

EPA Regulations for HVAC Technicians - Part 1

Updated: Apr 8

EPA Type 1 Chapter 1

Get your EPA 608 Certification for FREE


Introduction: Type 1


In this module, we will take a look at how the EPA defines small appliances and what the Type I certification covers. Skip to quiz!


Type I Certification


Recall that the purpose of Section 608 is to regulate ozone-depleting substances, or ODS, and their substitutes. As you can tell by their name, these substances destroy the ozone layer.

In Core, we learned that ozone destruction increases the risk of skin cancer and cataracts in humans.


Ozone-depleting substances are CFCs and HCFCs. Their substitutes include HFOs. Appliances containing these refrigerants are subject to Section 608 regulations.


Type I certification is for technicians to service, maintain, and repair small appliances that contain CFCs, HCFCs, or HFCs.


Technicians can have either Type I or Universal certification which includes Type I to service appliances covered under Section 608.


Type I appliances must be:

  • Hermetically sealed

  • Fully charged, and

  • Contain less than 5 lbs of refrigerants.

We will discuss each of these properties in more detail.


Type I appliances are hermetically sealed. This means that internal components are sealed from outside elements and airtight. Think of this as your phone. The internal circuits and other parts of your phone are sealed in a neat device.


Recall that charge is the amount of refrigerant in a system.

Type I appliances are also factory charged, meaning the refrigerant inside the appliance was put into the appliance in the factory where it was manufactured.


So technicians do not need to charge the appliance. All the refrigerant that the

the appliance needs to operate is already in there and ready to go.


And lastly, Type I appliances contain a maximum of five pounds of refrigerant. We will go over examples of these appliances so you get a sense of their size.


Types II and III cover appliances with higher amounts of ozone-depleting refrigerants such as chillers and commercial freezers. Type II covers high-pressure


appliances and Type III covers pressure appliances. Universal includes all three types of appliances.

Small Appliance Definition


Like we discussed, small appliances are systems that are

  • Hermetically sealed,

  • Factory charged, and

  • Contain 5 lbs or less of refrigerant.

Recall that 1 lb = 16 ounces.

Small appliances must contain less than five pounds of refrigerant or less than 80 ounces of refrigerant.

For the exam, we’ll need to know the number of ounces in a pound. This lets us determine if a certain amount of refrigerant

belongs in a small appliance. For example, the exam might ask if a small appliance can have 20 ounces of refrigerant. The answer would be yes because 20 ounces is less than 5 pounds.


Generally, small appliances would be items that are made for domestic use and not for industrial applications.


Examples of small appliances include household items such as:

  • Refrigerators

  • Freezers

  • Window AC units

  • Dehumidifiers, and

The following are appliances that are not necessarily for household use but still considered small appliances:

  • Water coolers

  • Under the counter ice makers, and

  • Vending machines

Type I appliances contain smaller amounts of refrigerant than Types II and III appliances.

You can think of Type I appliances as things you would see in your everyday life like your freezer or your window AC unit, or even a vending machine.


To reiterate, Type I regulates small appliances that contain ODS.

For example, if a water cooler contains three pounds of R-22, which is an HCFC, it would require Type I certification to handle and dispose of.

A desiccant dehumidifier, on the other hand, does not require Type I certification.

That is because a desiccant dehumidifier uses silica gel to remove humidity, not refrigerant.

On the other hand, if a dehumidifier contains R-410a refrigerant, it would require Type I certification to handle and dispose of it.


Examples of appliances that are not small appliances would be:

  • Supermarket refrigerators, which are Type II appliances

  • Chillers, which are Type III appliances

MVAC and MVAC-like systems are also not covered under Type I. MVAC stand for Motor Vehicle Air Conditioning. These are cooling systems found in cars and other motor vehicles. MVAC service and repair are covered under Section 609, not Section 608.

Disposal and other procedures for MVACs and MVAC-like systems are covered under Section 608 Type II. This is because disposing and other procedures mean working directly with refrigerants that are ozone-depleting.


For example, this includes buses that use R-12 (a CFC). These buses would be covered under Type II, not Type I. Recall that this is because the bus specifically contains CFC, which is ozone-depleting.


It’s important to remember that Section 608 regulates substances that are harmful to the ozone layer.

In this module, we went over what Type I certification means and why we would need it.


We compared Type I certification with Types II and III to see the differences between them.

We also looked at examples of appliances that are and are not small appliances under Type I.


Regulation Review


In this module, we will review the key regulations of the HVAC industry. These regulations apply to all technicians who maintain, service, repair, or dispose of Type I equipment that could release refrigerant into the atmosphere. Skip to quiz!


CAA Regulations


Section 608 is part of the Clean Air Act and focuses on regulating ozone-depleting substances (ODS). ODS is how the EPA will refer to these refrigerants in their documents and updates. Recall that it is your responsibility

Technicians must have Section 608 certification in order to purchase refrigerants that are ozone-depleting substances (ODS) and their non-exempt substitutes.

So this sales restriction applies to CFCs, HCFCs, HFCs, and HFOs.


Exempt substitutes are refrigerants that are considered by the EPA to be not harmful to the environment. An example of an exempt substitute is R-744, which is carbon dioxide, or CO2.


Small cans of non-exempt substitutes are not covered by the sales restriction. Small cans contain 2 lbs or less of non-exempt refrigerant. This exemption is mostly used for small cans of HFC-134a.


For example, if you do not have Section 608 certification, you can buy small cans of less than 2 lbs of HFC-134a.

As discussed in Core, there are additional requirements on recovery devices, recordkeeping, disposal, etc. If specific Section 608 regulations are unclear, feel free to reference our Core module on Section 608 Regulations.

Venting Prohibition


The Venting Prohibition is part of Section 608. Recall that venting means releasing refrigerants into the atmosphere. The Venting Prohibition states that it is illegal to intentionally vent ODS and their non-exempt substitutes.

To ensure that harmful refrigerants are not accidentally released, technicians need to recover refrigerants before servicing appliances. If we don’t do this, the refrigerant will be released into the atmosphere while we are working.

Technicians also need to use low-loss fittings to prevent loss of refrigerant from hoses.

Low-loss fittings work by blocking

the flow of refrigerant from leaving the hoses. Otherwise, refrigerant can be released through refrigerant hoses — this would be venting.

The EPA exempts refrigerants from the Venting Prohibition when it has determined that these refrigerants do not pose a threat to the environment. These include natural refrigerants — these are refrigerants that occur naturally in the atmosphere.

Natural refrigerants can be vented.

These include:

  • Hydrocarbon (HC) refrigerants

  • R-744, which is carbon dioxide,

  • R-717, which is ammonia, and

  • R-728, which is nitrogen.

Trace gases that are used in leak detection are not considered refrigerants under the EPA’s refrigerant management policies. So they are considered exemptions to the Venting Prohibition.


Another example of acceptable venting is when we use nitrogen to pressurize or blow debris out of a system. Of course, all refrigerant in the system has to be recovered before we can do this. Note that we cannot put nitrogen into a system that is fully charged.


In this case, the refrigerant in the system has been recovered. So the nitrogen used in the system can be vented because it is not mixed with refrigerant. Any refrigerant left in the system would be at trace amounts that are not significant.


In this module, we reviewed Section 608 regulations including the Sales Restriction and the Venting Prohibition. We discussed which refrigerants are subject to these regulations, and also which ones are exempt.



Question #1: Up to how many pounds of refrigerant can Type I appliances contain?

  1. 3

  2. 5

  3. 15

  4. 50

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Answer: 5

Type I appliances can contain a maximum of five pounds of refrigerant.



Question #2: Type I systems can have 3 pounds of refrigerant.

  1. True

  2. False

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Answer: True

Type I systems can have up to five pounds of refrigerant. So they can have any amount of refrigerant less than five pounds.


Question #3: Type I systems need to be charged before using.

  1. True

  2. False

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Answer: False

Type I systems are factory charged. This means technicians do not need to charge the appliance. All the refrigerant needed is already contained inside the appliance.

Type I appliances can be used straight out of the box.

Question #4: Hermetically sealed systems are systems that cannot lose refrigerant.

  1. True

  2. False

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Answer: False

Hermetically sealed systems are contained and sealed from outside components. But they can still leak over time and lose refrigerant.

Question #5 Small appliances include:

  1. Commercial freezers

  2. Commercial refrigerators

  3. Window AC units

  4. All of these

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Answer: Window AC units

Of this list, only window AC units are considered small appliances.

Commercial freezers and commercial refrigerators are not small appliances. These appliances will have more than five pounds of refrigerant.

Only household freezers and household refrigerators are considered small appliances.

Question #6 If a water cooler has 14 ounces of R-134a, is it considered a Type I appliance under Section 608?

  1. Yes

  2. No

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Answer: Yes

This water cooler is considered a Type I appliance under Section 608 because:

  • 14 ounces is less than 5 lbs (or 80 oz), and

  • R-134a is an HFC refrigerant, which is covered under Section 608.

(Recall that 16 ounces = 1 lb)


Question #7 If a humidifier has 60 ounces of R-32, is it considered a Type I appliance under Section 608?

  1. Yes

  2. No

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Answer: Yes

This humidifier is considered a Type I appliance under Section 608 because:

  • 60 ounces is less than 5 lbs (or 80 oz), and

  • R-32 is an HFC refrigerant, which is covered under Section 608.

Question #8 If a humidifier has 90 ounces of R-32, is it considered a Type I appliance under Section 608?

  1. Yes

  2. No

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Answer: No

This humidifier is not considered a Type I appliance under Section 608 because:

  • 90 ounces is greater than 5 lbs (or 80 oz)


Question #9 MVACs are considered Type I appliances under Section 608 but MVAC-like systems are not.

  1. True

  2. False

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Answer: False

Neither MVACs or MVAC-like systems are considered Type I systems.

Review the previous slides if this is unclear.


Question #10: Section 608 is part of the Clean Air Act.

  1. True

  2. False

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Answer: True

Section 608 is regulated under the Clean Air Act. All violations of Section 608 are subject to CAA fines and punishments.



Question #11: Which of the following refrigerants is not covered by the sales restriction of Section 608?

  1. R-717

  2. R-134a

  3. R-22

  4. R-12

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Answer: R-717

R-717 is ammonia and is exempted from the Section 608 sales restriction.

R-134a is an HFC refrigerant. All containers of R-134a greater than 2 lbs are subject to the sales restriction.

R-22 is an HCFC refrigerant, and R-12 is a CFC refrigerant. Both are covered by the sales restriction.



Question #12: If I don’t have Section 608 certification, I can buy 3 lb cans of R-134a.

  1. True

  2. False

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Answer: False

The small can exemption only covers cans of non-exempt substitute refrigerant up to 2 lbs.

Since R-134a is an HFC, it is a non-exempt substitute. So if you were to buy a can of R-134a with certification, the can have to be less than 2 lbs.

Question #13: We have to recover refrigerants only before servicing systems containing CFCs and HCFCs.

  1. True

  2. False

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Answer: False

We need to recover refrigerants before servicing any system containing CFCs, HCFCs, and their non-exempt substitutes. This includes HFC and HFO refrigerants as well.

Question #14: Low loss fittings are required for servicing systems containing ODS in order to comply with the Venting Prohibition.

  1. True

  2. False

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Answer: True

Using low-loss fittings allows us to be compliant with the Venting Prohibition. It prevents loss of ODS. Failure to use low-loss fittings is considered a violation of the Venting Prohibition.

Question #15: Trace gases used for leak detection cannot be vented because they contain ODS.

  1. True

  2. False

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Answer: False

Trace gases are not considered refrigerants under Section 608.

Recall from Core that refrigerant has to be recovered before we can mix in nitrogen with the remaining small amounts of refrigerant to check for leaks. The amount of refrigerant left is considered to be negligible because we have recovered most of it.

This trace gas is not considered a refrigerant under EPA refrigerant management guidelines.

Question #16: Which of these can be vented? (Select all that apply)

  1. R-717

  2. R-744

  3. R-728

  4. R-134a

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Answer: R-717, R-744, R-728

R-717 is ammonia,

R-744 is carbon dioxide, and

R- 728 is nitrogen.

These three can all be vented. They are exemptions from the Venting Prohibition.

R-134a is an HFC refrigerant and cannot be vented under the Venting Prohibition because it is a non-exempt substitute of CFCs and HCFCs.

Question #17: Nitrogen can be used to pressurize or blow debris out of a system containing a half charge of refrigerant.

  1. True

  2. False

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Answer: False

The refrigerant in a system should be fully recovered before using nitrogen to pressurize the system or blow debris out.

Question #18: If we use nitrogen to pressurize a system or blow debris out (after fully recovering the refrigerant in the appliance), we can

  1. Recover the nitrogen into the same recovery tank as the refrigerant

  2. Vent the nitrogen

  3. Vent the refrigerant because it’s useless

  4. All of these

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Answer: Vent the nitrogen

Only (2) is correct. The nitrogen can be vented.

We cannot recover nitrogen into the same tank of the refrigerant because it would mix the substances and make the refrigerant unusable. We also cannot vent the refrigerant if it is an ODS or a non-exempt substitute.


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