GUIDE TO REFRIGERANT TRACKING AND COMPLIANCE
Refrigerant management is becoming more complex. Several states have enacted more restrictive regulations. HVAC contractors now face greater liability risks for improper tracking and documentation.
No one likes paperwork but tracking refrigerant means you need an accurate system of documenting the chain of movement through your organization. This is especially relevant even in the event of loss from theft, as well as damage or mechanical failure of a cylinder or system.
Section 608 of the Clean Air Act and the ER&R portion of the Aim Act lists regulations key to refrigerant tracking. Every pound of refrigerant purchased is require to be tracked through inventory to its destination as well as every pound recovered sent to a wholesaler or reclaimer so be prepare to show an accounting.
Resulting penalties for non-compliance are stiff and can amount to more than $52,000 per day! Insurance will not cover fines or attorney fees resulting from your actions. Knowing how much new and recovered refrigerant is on your truck is critical to getting fully reimbursed by insurance.
It may also result in an individual having his EPA certification revoked. The EPA also publishes violators publicly. Accurate and correct documents will save further scrutiny by EPA.
The Major Liability Concerns surrounding refrigerant regulations are:
- – Lack of Training – including confusion over the RULES and BEST PRACTICES
- – A Lack of Adequate Documentation – If you can’t prove it – You didn’t do it!
Documentation therefore is your best Defense. Be sure to properly document chain of movement. Your cell phone is a high definition video – use it.