Overview: Proposed Changes to 

EPA’s Section 608 National 

Refrigerant Management Program

Disclaimer: This presentation is for informational purposes only. 

It does not supersede the Code of Federal Regulations or the 

proposed rule published on Nov. 9, 2015, in the Federal Register.
Overview

• Goals and current requirements of the 

National Refrigerant Management Program 

• Why it makes sense to propose changes

• Changes in Proposed Rule

– Goals

– Benefits

• Next steps

• Questions

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Purpose of Section 608 of Clean Air Act: Reduce 

emissions of ozone-depleting substances (ODS) and 

substitute refrigerants during the maintenance, service, 

repair, and disposal of appliances

Current requirements include:

• Prohibition against knowingly venting ODS and substitute 

refrigerants

• Service practices (ODS)

• Safe disposal requirements (ODS)

• Leak repair and leak prevention for larger appliances (ODS)

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National Refrigerant 

Management Program
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Overview of Current

Requirements
Goals of 608 Updates

• Larger context

– Climate Action Plan

– Industry petition to create a level playing field for commonly 

used refrigerants

• Immediate goals

– Extend Section 608 requirements to hydrofluorocarbons (HFCs) 

and other substitutes that are not exempt from the venting 

prohibition (“non-exempt substitutes”) 

– Decrease leaks from large appliances

– Enhance clarity and ease of compliance

– Continue to create incentives that support careful management 

of refrigerants

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Climate Action Plan: HFCs

• Continue international diplomacy

– Lead negotiations under the Montreal Protocol to phase down HFCs

• Global phase down could reduce over 90 gigatons of CO2eq by 2050, 

equal to roughly two years worth of current global GHG emissions 

– Work with partners in the Climate and Clean Air Coalition to Reduce 

Short-Lived Climate Pollutants to promote climate-friendly alternatives 

to high-GWP HFCs, address technical standards, and reduce 

emissions from HFC use 

• Address HFCs through domestic actions

– Use existing Clean Air Act authority of Significant New Alternatives 

Policy (SNAP) Program to approve climate-friendly chemicals, prohibit 

some uses of most harmful

– Provide federal leadership by purchasing 

cleaner alternatives to HFCs whenever feasible 

and by transitioning to equipment using safer, 

more sustainable alternatives

– Announced refrigerant management updates at White House (9/2014)

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Why are HFCs a Concern?

• HFCs are fluorinated greenhouse gases

• Use and emissions of HFCs are rapidly increasing

• 2004 to 2008: Global HFC emissions increased by about 8% per 

year

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• U.S. HFC emissions 

expected to double from 

current levels of 1.5% of 

greenhouse gas emissions 

by 2020, and triple by 2030

• If trends continued, HFC 

emissions could make up 

nearly 20% of total carbon 

dioxide emissions by 2050

UNEP 2011
Proposed Changes: 

Appliance Repair

Proposed Structure

• Calculate leak rate whenever refrigerant is added

• If leak rate exceeds applicable leak rate

- Conduct leak inspection 

- Repair all identified leaks within 30 days

• Time extensions available

• Conduct initial verification test before adding additional 

refrigerant

• Conduct follow-up verification test 

- If leaks cannot be repaired, develop retrofit/retirement plan 

within 30 days of discovering the leak

- Appliance retrofit/retirement must be completed within 1 year

• Time extensions available

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Proposed Changes: 

Appliance Repair

Action/Topic Current Proposed change

Appliances affected All ODS appliances with full 

charge of 50 lbs. or more 

All appliances with full charge of 50 

lbs. or more of non-exempt 

refrigerants (e.g., ODS, HFCs)

Leak rate

Leak rate is 35% for refrigeration 

appliances and 15% for comfort 

cooling

Lower to 20% and 10%, respectively

Would exempt seasonal variances 

from counting toward leak rate

When leak rate 

exceeds trigger rate

Repair leaks within 30 days such 

that the leak rate is brought below 

the trigger rate

Conduct leak inspection and repair all 

identified leaks within 30 days

How to verify repairs

Initial and follow-up verification 

tests required for Industrial 

Process Refrigeration (IPR) and 

federally-owned appliances

Initial and follow-up verification test 

required for all affected appliances

If owner/operator fails 

to repair within 30 days

Must develop a retrofit/retirement 

plan Unchanged

Timeline for 

retrofit/retirement plans

Appliance must be retrofitted or 

retired within 1 year Unchanged 9
Proposed Changes:

Leak Limit

• Establish a 2-year leak limit – Prohibit an appliance from leaking more than 75% of its full charge in 

two consecutive years

– If leak amount exceeded, appliance would need to be retired or 

mothballed

Example

– Appliance leaks 80% of its full charge between Jan. 1 & Dec. 31, 2018 

– From Jan. 1, 2019 to Dec. 31, 2019, the appliance could not leak more 

than 75% of its full charge

– If above 75% in 2019, appliance would need to be retired or mothballed

• Taking comment on

– Whether to allow for retrofit/retirement plan in lieu of mothballing

– Whether to provide an exception for unavoidable catastrophic leaks

– How the timeframe should be set up: two consecutive years? time 

periods based on calendar year or rolling?

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California Air Resources Board

(CARB) Data

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Proposed Changes:

Leak Inspections

• Require regular leak inspections, unless regularly-calibrated 

automatic leak detection equipment installed

– Quarterly for 500+ pound commercial refrigeration & IPR

• Annual inspections allowed if no refrigerant has been added 

in the past 365 days

– Annually for all other appliances with 50 or more pounds

– Proposing lower and higher charge thresholds for annual vs. 

quarterly

• Leak inspection would include examination of the refrigerant circuit 

of an appliance using

– A calibrated leak detection device

– Bubble tests

– Visual inspection for oil residue

• Proposing to allow leak inspections be conducted by staff other than 

a certified technician

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Proposed Changes: 

Recordkeeping/Reporting

• Technicians would provide service and maintenance 

records for owners/operators 

• Owners/Operators would keep all service records, leak 

inspection results, full charge calculations, verification 

test results, retrofit/retirement plans, extension requests, 

etc. 

• EPA encourage owners/operators to use electronic 

recordkeeping systems

• Establishing a new email address to send required 

reports to: 608reports@epa.gov

• Would need to notify EPA if seeking an extension 

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Servicing & Disposal 

Practices

• Currently: Technicians working on equipment containing ODS 

refrigerants must be certified and abide by described practices, 

such as recovering refrigerant from an appliance before 

servicing. 

• Proposal extends requirements to apply to HFCs and other nonexempt substitutes

• Technicians disposing of field-installed appliances required to 

keep records

– Current gap in recordkeeping requirements for equipment 

between 5 and 50 pounds

– Recordkeeping would include the amount of refrigerant 

recovered and the final disposition of refrigerant removed 

from appliances

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Other Proposed Changes 

to 608

• All non-exempt refrigerants in small appliances would need to be 

recovered before disposal

• Technicians would have to be certified to purchase all non-exempt 

substitutes, with exemption for small cans

– EPA did not propose as lead option requiring recertification of existing technicians

– Changes to the language on certification card also proposed

• Distributors would have to keep sales records and verify purchasers are 

(or employ) certified technicians

• Technician certification companies would have to publish lists of who is 

certified (prospective, with opt-out for privacy)

• Would remove reporting requirement for ownership of recovery 

equipment

• Would update standards for recycling/recovery equipment and 

reclamation

• Would restructure regulation to better group requirements

• Other wording changes to improve clarity and effectiveness

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Proposed Compliance Dates

• Small cans for MVAC servicing

– 1 year after final rule published: Newly-manufactured small cans would need 

a self-sealing valve installed

– 2 years after final rule published: Small cans placed into inventory within 1 

year of the final rule could no longer be sold

• Safe disposal of small appliances: 1 year after final rule

• Proper evacuation and servicing requirements: 1 year after final rule

• Technician certification: 1 year after final rule

• Appliance maintenance and leak repair requirements: 18 months after 

final rule

• All other requirements: January 1, 2017

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Benefits

• Rule benefits

\

– 7.5 million metric tons carbon dioxide equivalent 

(MMTCO2eq) of greenhouse gas (GHG) emissions 

reductions is the same as taking about 1.6 million cars off 

the road for a year

– We anticipate the regulated community would also 

experience $52 million in cost savings related to reduced 

purchases of refrigerant

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Annual GHG 

Reductions

(MMTCO2eq)

Annual ODS 

Reductions

(ODP-weighted MT)

Annual Incremental 

Compliance Cost 

(millions)

7.5 116 $63
Outreach and Next Steps

Outreach/Stakeholder Engagement in Rule Development 

Phase

• November 2014 stakeholder meeting, 50+ participants

• More than 50 meetings with industry, environmental groups, 

trade associations, states

Next Steps

• November 9 – Proposed rule published in Federal Register (80 

FR 69457)

• December 9 – Phone call to discuss updating the 608 test bank

• January 8 – Deadline to submit written comments

► We encourage you to submit comments!

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Thank You

Questions?

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Luke Hall-Jordan

Refrigerants Team Lead

Stratospheric Protection Division

U.S. Environmental Protection Agency

Office: 202-343-9591

Email: hall-jordan.luke@epa.gov
Background Slides

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Proposed Changes: 

Repair Extensions

Action/Topic Current Proposed change

Extensions to 30-day 

repair timeline

If appliance or isolated appliance 

component is mothballed Unchanged

Up to 120 days for an industrial 

process shutdown Unchanged

If Federal, state, or local regulations 

prohibit timely repairs (IPR only)

Would be extended to all affected 

appliances

If necessary parts are not available 

(IPR only)

Would be extended to all affected 

appliances but capped at 180 days

If appliance is located in an area 

subject to radiological contamination 

or where the shutting down of the 

appliance will directly lead to 

radiological contamination (federallyowned only)

Would be extended to all affected 

appliances

Extension request required for all but 

mothballing and IPR shutdown Unchanged
Proposed Changes: 

Retrofit/Retirement

Action/Topic Current Proposed change

Extensions to the 1-

year retrofit/ 

retirement timeline

If appliance or isolated appliance component is 

mothballed Unchanged

If Federal, state, or local regulations prohibit 

timely retrofit (IPR only) Unchanged

If a suitable replacement refrigerant with a lower 

ozone depletion potential is unavailable (IPR 

only)

Removed

If a critical component of a custom-built IPR 

appliance is not available on time (IPR only) Largely unchanged

If complications are presented by the federal 

agency appropriations and/or procurement 

process (federally-owned only)

Unchanged

If appliance is located in an area subject to 

radiological contamination and creating a safe 

working environment will require more time 

(federally-owned only)

Unchanged

Up to 18 months if 

replacement appliance 

uses an exempt 

refrigerant 22