Upcoming EPA Refrigerant Regulation Changes: What You Need to Know

For facilities using halocarbon, or Freon-based refrigeration systems, regulatory changes are underway, especially impacting those in California. These regulations, designed to address climate impact, aim to reduce greenhouse gas emissions from refrigeration systems. With the California Air Resources Board (CARB) introducing stringent requirements and the U.S. Environmental Protection Agency (EPA) enforcing broader refrigerant management practices, businesses using high-global warming potential (GWP) refrigerants need to prepare for changes in compliance.

Key EPA Refrigerant Regulation Changes

1. Prohibition on High-GWP Refrigerants
   High-GWP refrigerants contribute significantly to greenhouse gas emissions, and the EPA’s updated regulations, primarily through its Significant New Alternatives Policy (SNAP) program, focus on phasing out refrigerants with high environmental impact. This means:
   • New and Retrofitted Equipment: The EPA’s SNAP program prohibits the use of high-GWP refrigerants, specifically hydrofluorocarbons (HFCs), in both new and retrofitted refrigeration and air conditioning systems.
   • Sale Restrictions: Starting in 2020, the sale of refrigerants with a GWP of 2,500 or higher is restricted. By 2024, this limit will tighten further to refrigerants with a GWP of 1,500 or more.
2. Amendments to Section 608 of the Clean Air Act
   Section 608 of the Clean Air Act enforces guidelines for refrigerant management, emphasizing leak repair, venting practices, and recordkeeping requirements. Technicians servicing air-conditioning and stationary refrigeration systems must comply with practices that aim to maximize recycling and recovery of ozone-depleting substances. The goal is to reduce the release of harmful chemicals, like HFCs, that degrade the ozone layer and contribute to global warming.

Changes in California’s Refrigerant Management Program

California has long been at the forefront of environmental regulations, and its approach to refrigerant management is no exception. Here’s an overview of the changes affecting refrigeration systems in California:

1. Leak Inspection Frequency
   • Quarterly Leak Inspections: For systems containing over 500 pounds of refrigerant, quarterly inspections are now mandatory. This increased frequency helps quickly identify leaks and prevent the release of greenhouse gases.
   • Annual Leak Inspections: Systems containing more than 50 pounds of refrigerant must undergo annual leak inspections. This requirement applies to commercial and industrial refrigeration systems, targeting systems with significant greenhouse gas emissions potential.
2. Operation Ban on Systems with Recurrent Leaks
   California regulations impose strict penalties on systems that experience substantial leaks over consecutive years. Specifically, systems with over 50 pounds of refrigerant that leak 75% or more of their full charge for two consecutive years may be prohibited from operating. This regulation aims to ensure that persistent leaks are addressed promptly and encourages businesses to invest in more sustainable refrigeration systems.
3. Use of Slightly Flammable Refrigerants in New Equipment
   The updated regulations allow for the use of slightly flammable refrigerants in specific applications, but such refrigerants must comply with standards and safety codes before being implemented widely. These refrigerants, though more environmentally friendly, require specialized equipment and handling protocols due to their flammability.
4. Enhanced Safety Measures for End Users
   To comply with new refrigerant regulations, end users are expected to adopt additional safety measures when using refrigerants with flammable properties. These precautions include updated safety equipment, proper ventilation, and adherence to rigorous safety protocols to ensure safe operation in various industrial and commercial environments.

Implications for Facility Owners and Technicians

Facility owners, service technicians, and equipment manufacturers face significant implications due to these regulatory changes. Compliance with both EPA and California standards will require adjustments in equipment choices, maintenance practices, and documentation.

• Recordkeeping and Compliance: Detailed records of maintenance, refrigerant usage, and leak repairs will be essential for compliance. Facilities are advised to maintain meticulous logs of all refrigerant-related activities, including technician inspections and leak repair histories.
• Upgrading Equipment: For some businesses, complying with these new regulations may mean upgrading existing equipment or investing in low-GWP refrigerant options. While initial costs may be higher, the shift to more environmentally friendly refrigerants can reduce operational risks and contribute to long-term sustainability goals.
• Training for Technicians: With evolving safety standards, technicians will require additional training on handling slightly flammable refrigerants, leak detection, and implementing EPA-compliant practices. This training ensures both technician safety and adherence to the stringent standards set forth in these regulations.

Benefits of Compliance with EPA and CARB Regulations

While these regulations may seem demanding, they provide several benefits for both businesses and the environment:

1. Reduced Environmental Impact: Phasing out high-GWP refrigerants contributes to the reduction of greenhouse gas emissions, aiding efforts to combat climate change. Low-GWP refrigerants are more sustainable and align with global environmental goals.
2. Cost Savings from Reduced Leaks: Regular inspections and leak prevention reduce refrigerant losses, saving businesses the cost of frequent recharges. Preventing leaks also extends the lifespan of refrigeration equipment.
3. Enhanced Safety: Safety measures related to slightly flammable refrigerants reduce the risks associated with these materials, protecting both technicians and facility operators.

Preparing for Future Refrigerant Management Practices

Compliance with upcoming refrigerant regulations requires proactive planning. Here are steps businesses can take to prepare:

• Audit Existing Systems: Evaluate all current refrigeration and air-conditioning systems for compliance with new EPA and CARB standards. Identify systems that may require updates or replacements.
• Establish a Preventative Maintenance Schedule: Regular maintenance and inspection schedules can prevent leaks and ensure that systems operate within regulatory standards. Maintenance schedules should align with the new quarterly and annual inspection requirements in California.
• Invest in Technician Training: Ensuring that technicians are familiar with updated refrigerant management practices is essential. Many changes involve handling new refrigerants and using specific tools and techniques for leak detection and repair.

Conclusion

Staying informed and prepared for the upcoming EPA and California refrigerant regulations is crucial for businesses utilizing refrigeration systems. By adopting low-GWP refrigerants, following maintenance protocols, and investing in the necessary training and equipment, businesses can comply with these new standards and contribute to a more sustainable environment.

For guidance on upgrading your refrigeration systems to meet these new standards, Super Brothers provides industry expertise and support to ensure smooth transitions and regulatory compliance.