• SkillCat Team

Regulation Review

Updated: Mar 2

EPA 608 Type 1 Chapter 2 (Take the full course for free)


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!


1. 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.



2. 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.



3. Conclusion

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: Section 608 is part of the Clean Air Act.

  1. True

  2. False

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This is true.

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


Question #2: 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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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 #3: 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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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 has to be less than 2 lbs.


Question #4: We have to recover refrigerants only before servicing systems containing CFCs and HCFCs.

  1. True

  2. False

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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 #5 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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This is 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 #6 Trace gases used for leak detection cannot be vented because they contain ODS.

  1. True

  2. False

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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 #7 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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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 #8 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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The refrigerant in a system should be fully recovered before using nitrogen to pressurize the system or blow debris out.


Question #9 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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Only (b) 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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