EPA 608 Technician Certification Clean Air Act and Section 608 Rules Summary

40 CFR 82.154(a) says no one servicing, repairing, or disposing of an appliance may knowingly vent CFC, HCFC, or non-exempt substitute refrigerants such as HFCs. Only a short list of substitutes (for example CO2 or nitrogen, and some hydrocarbons in certain uses) is exempt.

Wrong choices

• Only CFCs and HCFCs: Most substitutes such as HFCs are also covered.
• Only refrigerants in systems over 50 pounds: The venting prohibition applies to appliances of every size.
• Only CFCs: The venting prohibition covers more than CFCs.

R-410A is a high-pressure refrigerant. Servicing or disposing of medium-, high-, or very high-pressure appliances (other than small appliances and motor vehicle systems) requires Type II certification, which is also included in Universal.

Wrong choices

• Section 609 (motor vehicle) certification: Section 609 is for motor vehicle air conditioning.
• Type III: Type III covers low-pressure appliances such as R-123 chillers.
• Type I: Type I covers only small factory-sealed appliances with 5 pounds or less.

Under 40 CFR 82.154(d), used refrigerant may not be sold to a new owner unless it has been reclaimed by a certified reclaimer to the purity standard in Appendix A (based on AHRI Standard 700).

Wrong choices

• It must be mixed with new refrigerant: Mixing does not make used refrigerant legal to sell.
• It only needs to pass through a recycling machine: Recycling cleans refrigerant for the same owner, but it does not meet the standard for sale to a new owner.
• Nothing; recovered refrigerant may be sold as is: Used refrigerant cannot be sold to a new owner without reclamation.

The Montreal Protocol is the international agreement to phase out the production of ozone-depleting substances such as CFCs and HCFCs. The United States carries it out through the Clean Air Act.

Wrong choices

• A U.S. law that sets electrical codes for HVAC equipment: The Montreal Protocol is not about electrical codes.
• An EPA rule for car air conditioning only: It is worldwide and covers all uses of ozone-depleting substances, not just cars.
• A safety standard for refrigerant cylinders: Cylinder safety is covered by DOT rules, not the Montreal Protocol.

EPA lists a few substitutes as exempt from the venting prohibition, including nitrogen, carbon dioxide, and water in any application. CFCs, HCFCs, and HFCs such as R-410A and R-134a may not be vented.

Wrong choices

• R-410A: R-410A is an HFC blend covered by the venting prohibition.
• R-134a: R-134a is an HFC and may not be vented.
• R-22: R-22 is an HCFC and may not be vented.

40 CFR 82.154(c) limits sales of CFC, HCFC, and non-exempt substitute refrigerants such as HFCs to certified technicians (Type I, II, III, or Universal), or to buyers who employ a certified technician and show proof. There are a few exceptions, such as sales for resale.

Wrong choices

• Any licensed electrician: An electrical license does not meet the Section 608 sales restriction.
• Any adult with a photo ID: A photo ID alone is not enough; the buyer must be certified or employ a certified technician.
• Any building owner, for use in their own building: Owning a building does not allow buying refrigerant without certification.

EPA states that Section 608 technician certification does not expire. EPA keeps the right to require recertification in the future by a notice in the Federal Register. Technicians must keep a copy of their certificate at their place of business.

Wrong choices

• 3 years: Three years is a recordkeeping period, not a certification term.
• 1 year: There is no yearly renewal.
• 5 years: There is no 5-year renewal for Section 608 certification.

EPA's ban on production and import of most class I ozone-depleting substances, including CFCs, took effect on January 1, 1996. Existing CFC refrigerant can still be recovered, recycled, and reclaimed for use.

Wrong choices

• January 1, 2020: 2020 is when production and import of HCFC-22 (R-22) ended.
• January 1, 2010: 2010 is when production of HCFC-22 for new equipment ended.
• January 1, 1990: CFC production was still allowed in 1990.

Under the HCFC phaseout, production and import of HCFC-22 ended in 2020. Existing systems can still be serviced with R-22 that was produced before then or that is recovered, recycled, or reclaimed.

Wrong choices

• January 1, 2015: In 2015 limits tightened on other HCFCs, but R-22 production had not yet ended.
• January 1, 2030: 2030 is when production and import of all remaining HCFCs ends.
• January 1, 1996: 1996 is the CFC production ban.

De minimis releases are small amounts released during a good-faith attempt to recover refrigerant while following the required practices, such as when connecting or disconnecting hoses. Knowingly venting any other refrigerant is a violation.

Wrong choices

• Venting the last few pounds to save time at disposal: Venting to save time is a knowing release and is illegal.
• Releasing refrigerant from a cylinder to lower its pressure: Venting from a cylinder is a knowing release after recovery, which is a violation.
• Purging a whole charge to clear air from the system: Purging a whole charge is illegal venting.