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Dick Shaw, ACCA’s technical education consultant, and John Herzog, director of government relations, presented their recommendations to the standard known as IRG-2.
As it now stands, IRG-2 allows contractors to recover refrigerant in the field as the law requires, but it “underestimates the contractor’s skill, knowledge, and expertise relative to refrigerant recycling,” according to the association’s statements.
“It also fails to recognize that many contractors were recycling refrigerant well before the [Clean Air Act] of 1990.”
Shaw stated that “Working hand in hand with the EPA and the rest of the industry, our organization has been actively involved in the refrigerant recycling issue.”
ACCA contends that the rule concentrates only on refrigerant quality and not the contractors’ cost of doing business; and fails to ensure that any greater quantity of refrigerant will be reclaimed.
Proposed changesSpecifically, Shaw asked the EPA to:
- Develop financial incentives such as rebates, deposits, refunds, tax credits, etc., for all refrigerant that is reclaimed;
- Reduce purity standards to a “realistic” level that encourages recycling;
- Enforce the Clean Air Act so that there is parity within the industry; and
- Update the 608 certification tests to include current standards and regulations.
“Give us the tools to manage our resources that are essential to our business and to our customers’ safety, well-being, and quality of life” said Shaw. “And just maybe, a win-win situation can evolve.”