The U.S. Environmental Protection Agency (EPA) is making changes to its Section 608 Refrigerant Management Program regulations and modernizing the certification exam. These changes are designed to reinforce the existing program by forcing contractors and technicians to follow the best possible practices.
The EPA estimates the annual emissions reductions from this rule will be approximately 7.3 million metric tons of carbon dioxide equivalent (MMTCO2eq) and 114 ozone-depletion weighted metric tons (ODP tons).
One of the more significant aspects of these sweeping changes comes from the new recordkeeping requirements for appliances containing 5-50 pounds of refrigerant. Per Jeremy Arling, refrigerants team lead, stratospheric protection division, EPA, technicians who dispose of mid-sized appliances will need to keep records of the location, date of recovery, and type of refrigerant recovered for each disposed appliance; the quantity and type of refrigerant recovered from disposed appliances in each calendar month; and the quantity and type of refrigerant transferred for reclamation or destruction, the person to whom it was transferred, and the date of the transfer. These records must be maintained by individual technicians and not the owners or operators of the appliance.
Robert Stringham, HVAC instructor, Northern Virginia Community College, Springfield, Virginia, said the reason for the tougher record keeping requirements is to allow for better enforcement.
“The EPA is more than likely not going to come to a technician or a company and randomly ask to see the refrigerant logs,” he said. “It’s more of a follow-up if a complaint or video ever surfaces on someone blatantly venting refrigerant.”
This may seem like a tough burden for technicians, and many in the industry believe it is, but there are efforts being made to try and help alleviate some of the encumbrance.
MAKING AN ADJUSTMENT
“The technicians who are aware of these recordkeeping changes mainly think it is an extra step that takes too much time,” said Jason Obrzut, director of education, HVAC Technical Institute, Oak Lawn, Illinois. “They will really start to see the value in it once they see the price of R-22 refrigerant go up. This will hopefully get more companies and technicians to reclaim R-22.”
As Obrzut alluded to, the price of R-22 has steadily risen over the last few years as the phasedown of the products has registered on a larger scale. Production and importation of R-22 went from 51 million pounds allowed in 2014 to 22 million pounds in 2015, 18 million pounds in 2016, 13 million pounds in 2017, 9 million pounds in 2018, and 4 million pounds in 2019. After Jan. 1, 2020, no new or imported R-22 will be allowed in the U.S.
Because of this, Obrzut himself is a fan of the Section 608 changes.
“I love them,” he said. “I feel we don’t do enough. If you look at R-22 projections, we need to do more. Every year the recovery and reclamation efforts are well below what they should be. Hopefully this set of changes helps keep the price down.
He also added that some smaller contractors are saying they aren’t going to enforce the changes at all.
“The bigger ones are the ones taking it seriously,” Obrzut said. “They are looking for ways to take in all the information without killing a small forest and are planning on being compliant by any means necessary.”
Stringham said he can tell a lot of people, especially students, are wondering why they are learning about recordkeeping right now.
“They just don’t see it as relevant to what they are doing today,” Stringham said. “Techs that have been out in the field for a long time are kept abreast of changes coming up, but they really don’t see the relevance to what was being tested before.”
Stringham highlighted the rising costs of refrigerants, noting, “With the changes coming up, all technicians need to pay attention to things like leak-rate requirements, and even though it’s not regulated to where between 5-50 pounds they have to fix leaks, with the cost of refrigerants going up, you still have to be mindful of the cost basis for everything.”
Bryan Orr, co-owner and vice president of service at Kalos Services Inc. in Orlando, Florida, and the founder of HVACRSchool.com, said he hears a combination of complaints about the additional work as well as questions about what will be required.
“There is a lot of misinformation out there about what a tech will and won’t be required to do starting in 2018,” he said. “First and foremost, many techs ask if recertification will be required, and it will not.”
In his experience, Orr said only a minority of technicians believe that the 608 regulations will have a positive effect on the environment.
“Among those who don’t believe in the importance of venting regulations, the feeling seems to be that their time is increasingly being wasted by these additional processes,” he said. “Among those who do believe in the importance of the regulations, the complaints mostly surround the lack of enforcement. While many in this camp feel these changes are a step in the right direction, they still doubt that any effective enforcement campaigns will be brought to bear.”
A POTENTIAL ANSWER
While paper-and-pencil recordkeeping or an individualized method of electronically doing so remains an option for technicians, Stringham hopes he has created an easier solution to the EPA’s requirements in the form of the R-Log mobile application. The app, available on both Android and iOS, allows technicians to complete the requirements in a few steps.
Per Stringham, the data can be exported to a spreadsheet for tabulation and compliance. Reports are automatically generated with the tap of a button, ready to send to customers and owners of equipment for systems containing more than 50 pounds, which allows them to stay in compliance.
“A desktop version is also in the works for larger companies to easily manage the data,” he said. “Back-up services and a report generator will also be available on www.r-log.com for smaller companies or individual technicians who simply want peace of mind while staying compliant.”
Obrzut said people are generally excited about the app and can immediately see its benefits.
“With any new technology, you will have early adopters and people who wait until 2018 before downloading it and actually doing what needs to be done,” he said. “We used it in class, and the students really liked it. While people right now are going to have to adjust and learn how to do this recordkeeping, future generations will be used to it from the ground up, and it will just be expected.”
The app was actually developed for students in Stringham’s classroom and expanded from there.
“I have 100 kids in class who are all taking out refrigerants or putting refrigerants into different systems, and it just became a logistical nightmare to have them write everything down or have me keep track of all the refrigerant that is coming in and out, so that’s kind of where the electronic recordkeeping really came from on my end,” said Stringham.
Orr said it’s important to keep in mind that with major changes like these, things can get political pretty quickly.
“While I am as opinionated as the next guy, I try to keep the politics out of my profession because it can cloud my thinking,” he said. “I think these changes make sense if the intent is for the EPA to have a better leg to stand on to actually prosecute contractors who vent regularly. I like the fact that better ‘teeth’ to enforcement can lead to a more even playing ground with the contractors who abide by the rules being at less of a disadvantage to those who do not.”
When discussing the predicted outcomes of the entire set of Section 608 changes at the 2017 National HVAC Educators and Trainers Conference, Arling highlighted consistent treatment of commonly used refrigerants, an incorporation of best management practices to reduce leaks from large appliances, a focus on ensuring repairs are effective, and more.
With efforts like these, and innovative apps like R-Log becoming available, hopefully the new recordkeeping requirements for technicians will prove to be a much more manageable task than it would seem.
Publication date: 7/31/2017