It has been more than 20 years since the U.S. Environmental Protection Agency (EPA) enacted legislation prohibiting individuals from intentionally venting refrigerants into the atmosphere while maintaining, servicing, repairing, or disposing of refrigeration equipment. Today, recovering refrigerant from a system during major repairs is a routine practice for technicians and contractors.

In addition to prohibiting the intentional venting of refrigerants into the atmosphere, there are several other requirements in Section 608 of the Clean Air Act of 1990 that technicians and contractors must follow. One of these is the recordkeeping of refrigerant usage. Technicians, equipment owners, wholesalers, and refrigerant reclaimers all have some type of recordkeeping responsibility under this law.

Technician Requirements

Technicians servicing appliances that contain 50 or more pounds of refrigerant must provide the owner of the equipment with an invoice that indicates the amount of refrigerant added to the system. The EPA does not require technicians or contractors to record their usage or keep refrigerant usage records. Recording the amount of refrigerant added to a system on the customer’s invoice should be sufficient.

In addition to this requirement, technicians must keep a copy of their proof of certification at their place of business and may need to present it when purchasing chlorofluorocarbons (CFCs) and hydrochlorofluorocarbon
(HCFC) refrigerants.

Although it is not a requirement of the EPA, keeping refrigerant usage records may be beneficial to a contractor. With all the different refrigerants in use today, it may be difficult at times to keep all the types they commonly use in stock. With a refrigerant recordkeeping program, they could analyze which refrigerants are used most often.

As noted, it is the owners or operators of systems containing 50 or more pounds of refrigerant that must keep servicing records documenting the date and type of service as well as the quantity of refrigerant added. There are several software tools and websites available to assist in this recordkeeping. Although this is not the responsibility of a technician or contractor, informing and perhaps assisting customers with this requirement might be a valuable service they can provide.

Wholesaler and Reclaimer Responsibilities

Wholesalers who sell CFCs and HCFCs also must abide by EPA requirements. They must retain invoices indicating the name of the purchaser, the date of sale, and the quantity of refrigerant purchased.

Additionally, refrigerant reclaimers must maintain records of the names and addresses of contractors sending them refrigerant for reclamation and the quantity of refrigerant sent for reclamation. This information must be maintained on a transactional basis.

The EPA does perform random inspections, responds to tips, and pursues potential cases against violators. Under the act, the EPA is authorized to assess fines of up to $37,500 per day for any violation of these regulations.

For more information on this or any other EPA refrigerant handling requirements, visit It is good practice to occasionally review the EPA’s website for any changes to Section 608 of the Clean Air of 1990. It is the responsibility of a certified technician to keep up on any changes implemented by the EPA.

Publication date: 11/3/2014

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