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Dakota Software's Blog for EHS and Sustainability Professionals

Complying with EPA's Refrigerant Management Requirements

April 25th, 2017 ProActivity News

Complying with EPA's Refrigerant Management Requirements

Considered a leading cause of the hole in the protective ozone layer and global warming, ozone depleting substances (ODS) are being phased out of production. EPA first issued rules related to refrigerant recycling in 1993 – the “no-venting rule.” Subsequent amendments have included revisions and clarifications, differentiating between ODS and non-ODS refrigerants. Requirements related to non-ODS and smaller appliances are currently limited. However, EPA has clear expectations for large refrigerant-containing appliances – currently defined as having a capacity of at least 50 pounds ODS.

Service and maintenance, including leak repair, must be performed by appropriately certified technicians. Technicians must use properly certified equipment to recover and recycle or reclaim refrigerant. For large appliances, the leak rate must be calculated each time refrigerant is added to the appliance. If a leak rate meets or exceeds a trigger rate, the appliance owner or operator is required to take action within 30 days. Testing is required to verify the appliance is repaired before it can be returned to service. An appliance owner or operator may choose to use in-house technicians or hire a reputable contractor to conduct some or all of the service, maintenance, and repairs, easing some of the burden. However, much of the recordkeeping requirements are directed to the owner or operator; they cannot be shifted to the contractor.

Imagine a site that has multiple refrigerant-containing appliances of varying sizes and types of service, holding a variety of refrigerant types. Now, imagine a company with several such sites – or dozens. The required recordkeeping can become a nightmare.

Dakota Software’s Refrigerant Management application collects the owner/operator required information for each refrigerant-containing appliance, certified technician and on-site refrigerant inventory. It allows attachments so a copy of the technician’s wallet card can be included as part of the technician record. In addition to manual adds and deducts for purchases and discards, the refrigerant inventory form tracks refrigerant added or removed during transactions.

These forms are the basis for an appliance service or transaction. The user populates the transaction form by selecting the appliance, the service company, and technician, and using drop-down menus to select the type of action. The transaction form automatically calculates the leak rate, displays the date when a repair or other action is required, tracks the actiontakenand documents verification tests and displays warnings where appropriate. For example, a warning is displayed if the selected technician is not properly certified to service the selected appliance.

While designed for the large stationary appliances covered by Section 608, the application can be applied to any sized appliance or refrigerant type. This flexibility allows organizations to begin tracking leaks and repairs for those non-ODS appliances that will be covered under the November 2016 revision. Click here to learn more about Dakota’s Refrigerant Management application.

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