The U.S. Environmental Protection Agency (EPA) has expanded refrigerant management requirements under 40 CFR Part 82 to strengthen control of ozone-depleting substances (ODS) and certain substitute refrigerants, including hydrofluorocarbons (HFCs). These updates reflect EPA’s continued implementation of Clean Air Act Title VI and alignment with broader climate initiatives. The revisions significantly increase the number of regulated systems, expand reporting obligations, and reinforce certification requirements for both personnel and equipment.
A key change is the expansion of applicability to appliances containing 15 pounds or more of refrigerant, reduced from the previous 50-pound threshold. This substantially increases the number of refrigeration and air-conditioning systems subject to federal leak repair, inspection, and recordkeeping requirements. Facilities must now monitor smaller systems and ensure compliance with leak repair provisions, documentation, and reporting where applicable.
Leak repair requirements remain in place with defined annual leak rate thresholds of 10% for comfort cooling, 20% for commercial refrigeration, and 30% for industrial process refrigeration, but EPA has strengthened enforcement expectations related to timely repair, verification testing, and documentation. Facilities exceeding applicable thresholds must promptly repair leaks, conduct follow-up testing, and maintain defensible records demonstrating corrective actions.
The updated rule also reinforces requirements that only EPA Section 608 certified technicians may service regulated equipment. Additionally, all refrigerant recovery and recycling equipment must be EPA-certified, properly maintained, and capable of meeting federal refrigerant recovery efficiency standards. Facilities are responsible for ensuring both employees and contractors use properly certified equipment and maintain documentation of equipment certification, model numbers, and proper use.
The prohibition on intentional venting remains a central requirement. Refrigerant must be recovered using certified equipment prior to servicing, repair, or disposal. Recovered refrigerant must be properly stored, reclaimed, or disposed of in accordance with EPA requirements.
EPA has also strengthened recordkeeping and reporting requirements, particularly for systems subject to leak repair provisions and specified leak events. Facilities must maintain documentation including technician certifications, recovery equipment certifications, leak inspection and repair records, and refrigerant management activities. These records must be retained for at least three years and be available for regulatory inspection.
These revisions significantly expand compliance applicability and increase regulatory scrutiny of refrigerant management programs. Facilities operating refrigeration or air-conditioning systems must ensure certified technicians and equipment are used, leak detection and repair programs are implemented, and refrigerant management records are complete and defensible. Failure to comply may result in substantial civil penalties and regulatory enforcement.
Overall, the changes to 40 CFR Part 82 increase the regulatory burden on equipment owners and operators and require more proactive refrigerant management practices to ensure compliance and minimize environmental and regulatory risk.
