Motor Vehicle Air Conditioning (MVAC) Inspection Program &lt;Training Manual&gt;


           United States
           Environmental Protection
           Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC
EPA 455/B-92-002
March 1992
Revised June 1992
           Stationary Source Compliance Training Series
&EPA  MOTOR VEHICLE
           AIR CONDITIONING (MVAC)
           INSPECTION PROGRAM:
           TRAINING  MANUAL

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                                                EPA 455/B-92-QQ2
MOTOR VEHICLE AIR CONDITIONING (MVAC)
            INSPECTION PROGRAM

               TRAINING MANUAL
                        by

              Midwest Research Institute
             401 Harrison Oaks Boulevard
              Gary, North Carolina 27513
              Contract No. 68-02-4463
             Work Assignment No. 92-52
   EPA Work Assignment Manager: Belinda Breidenbach
           EPA Project Officer: Aaron Martin
      US. ENVIRONMENTAL PROTECTION AGENCY
         Stationary Source Compliance Division
       Office of Air Quality Planning and Standards
               Washington, DC 20460
                   March 1992
                Revised June 1992
               Mil]

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                    TABLE OF CONTENTS
 Chapter 1.0  Introduction to the Motor Vehicle Air
 Conditioning (MVAC) Program.,	,	Page -j


 Chapter 2.0  Summary of the Requirements of Section
 609 of the Clean Air Act Amendments (CAAA)	Page 5


 Chapter 3.0  Descriptions of Level 1 and Level 2 MVAC
 Inspections	v	Page 12


 Chapter 4.0  Inspection Checklists	Page 31


 Chapter 5.0  Recordkeeping Requirements	Page 43


 Chapter 6.0 Example Forms	page 45


 Chapter 7.0  A Copy of Section 609 of the CAAA	Page 49


Chapter 8.0  A Certificate of Completion	Page 52

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       CHAPTER 1
 Introduction to the Motor Vehicle
Air Conditioning (MVAC) Program.

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Chapter 1.0  Introduction to the Motor Vehicle Air Conditioning
        (MVAC) Program
Chapter Summary
     This chapter briefly provides:
                                             ^y
     •    General background as to why regulations have been
          developed; and
     •    Explanation of the reasoning behind inspecting MVAC service
          facilities.

Specific MVAC regulatory authority is given by Section 609 of the Clean Air
Act Amendments (CAAA). Section 609 is included in Chapter 7.0 of this
manual, and is discussed in lay person language in Chapter 2.0.

     EPA proposed regulations for servicing MVACs on September 4,
1991. The Final Rule is pending promulgation.

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Background
     Montreal Protocol on Substances that Deplete the Stratospheric
.Ozone was signed by 75 nations, including the United States.


     •    The Montreal Protocol called for production and consumption of
          ozone depleting CFCs and halons to be frozen at 1986 levels,
          and a 50 percent reduction of the 1986 level by 1998.

     •    1990 London Conference Amendments added the chemicals
          carbon tetrachloride and methyl chloroform, and called for a
          complete phaseout of ozone depleting substances by the year
          2000 (except for methyl chloroform, in the year 2002).

          Clean Air Act Amendments of 199Q (CAAAl include measures to
          protect the stratospheric ozone and comply with the Protocol.

     •     Title VI of the CAAA calls for a complete phaseout of CFCs by
          the year 2000.  This includes CFC-12 which is the most
          common refrigerant used in motor vehicle air conditioners. Title
          VI also requires that refrigerants must be recycled when
          servicing MVACs.

     •     CAAA Section 606 allows for acceleration the phaseout date for
          Class I and Class II chemicals, except for methyl chloroform to
          December 31,1995. The regulations are expected to be
          proposed in late 1992.

     •     CAAA Section 609 requires approved refrigerant recycling
          (recover/recycle or recovery only) equipment and proper
          training and certification for the technicians that perform the
          service.

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 The MVAC Program

      An EPA inspector charged with confirming that MVAC service facilities
 are complying with Section 609 of the CAAA may be asked why strict
 compliance is so important.  Simply put:

      •    The ozone layer in the upper atmosphere, or stratosphere,
           protects the earth from harmful ultraviolet (UV) radiation;
      •    CFCs deplete or destroy the ozone layer;
      •    Depletion of the ozone layer allows increased UV radiation to
           reach the earth;
      •    The increased UV radiation causes increases in:
      - skin cancer, melanoma:
      - cataracts:
      -- crop loss:
      - forest loss:
      - damage to the human immune system:
      -- deterioration of materials: and
      - damage to aquatic organisms.
Continued depletion of the ozone will adversely impact the quality of life on
earth.  Compliance with Section 609 of the CAAA is needed to help protect
the ozone, and thus our quality of life.

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      An EPA inspector may funner be challenged to identify why the MVAC
 service industry has been "singled out" for regulatory scrutiny, and asked to
 bear the associated financial and paperwork burdens. For their part in
 protecting the stratospheric ozone and our quality of life, MVAC service
 operations can have a tremendously positive impact, if compliance with
 Section 609 can be ensured, because:

      •     CFC-12, also referred to as R-12 or Freon, accounts for more
           than 20 percent of allCFC use in the United States;
      •     CFC-12 is the predominant refrigerant used in MVACs; and
      •     Eliminating emissions of CFC-12 from MVACs can significantly
           reduce further ozone depletion.
MVAC recovery and recycling equipment and service technician training
programs are available to assist the industry in complying with Section 609.
Hence, reducing or eliminating CFC emissions during MVAC servicing is
more feasible if inspectors confirm that the proper equipment is in use, and
that it is being used by properly trained personnel.

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           CHAPTER 2
Summary of the Requirements of Section 609
  of the Clean Air Act Amendments (CAAA)

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Chapter 2.0  Summary of the Requirements of Section 609 of the
        Clean Air Act Amendments (CAAA)
Chapter Summary
     Section 609 of the CAAAs of 1990 outline specific requirements for
establishments that service motor vehicle air conditioners. This chapter
covers the requirements and definitions in Section 609:
     •    Refrigerants
     •    Approved equipment
     •    Trained and certified technicians
     •    Standard form for facility certification
          •     Small Entity Certification
          •     Equipment Owner Certification
     •    Small containers
     •    Definition of service

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      The requirements are briefly restated below in lay person language.
 Chapter 7.0 of this manual contains a reference copy of Section 609 of the
 Clean Air Act Amendments of 1990.

 Effective January  1, 1992
      •    Shops servicing MVACs must:

           •    purchase approved recover only or recover/recycle
                equipment; and

           •    have technicians performing MVAC service trained by an
                EPA accredited training program and properly using the
                equipment.

      •    Shops that serviced less than 100 MVACs in 1990 have until
          January 1,1993 to comply. They must certify as a small
          business by January 1,1992.

Effective November  15, 1992
     •    Small containers, less than 20 pounds, can only be sold to
          certified technicians.  For additional discussion, see the "SMALL
          CONTAINERS" heading at the end of this Chapter. There is no
          restriction on the sale of containers 20 pounds or over.

Effective January 1,  1993
     *    All service facilities must have certified to EPA that they have
          purchased approved equipment and  their technicians are
          properly trained and certified. A sample form follows.

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MAC RECOVER/RECYCLE EQUIPMENT
CERTIFICATION FORM
Ntm» of EftiMttimw*
Straw
City. State. Zip Cod*
(ATM Cod*) Tctophon* Numbw
N«m« e( Equipment Manufacturer and Modtf NunMr
S«W Numbtr(s) Yav

3 l certify that I have acquired approved recover/recycle
•qulpmtnt under Section 600 of the Clean Air Act I cer-
tify that only property trained and certified technicians
operate the equipment and that the Information given
above la true and correct
Small Entity Certffieatlon.
I certify that fewer thanlOO Jobs toveteag refH-
0«rant were performed it the establishment
named In Pert 1 of tMa form during 19«0.1 will
purchase ipproved equipment and certify this to
I*A by January 1,1903.
N«mt(P
TKM
Signttm el Ouww/Opn
Send this form to:
MACt Recycling Program Manager
Stratospheric Ozone
Protection Branch
(ANR-445) •
401 M Street, S.W.
Waahlngton, D.C. 20480
TIM
MAC RECOVER/RECYCLE EQUIPMENT
CERTIFICATION FORM INSTRUCTIONS
Motor vehicle recover/recycle equipment mutt bo aqutredby January 1 ,1 992 and certified to IPA on or before
January 1 , 1 993 under Section (09 of the Clean Air Act To certify your equipment, please complete the above
form according to the following Instructions and mad to EPA at the following address: MAC* RecyeUna Pro*
gram Manager, Stratospheric Ozone Protection Branch, (ANR-448), 401 M Street, S.W., Waantogton" D.C.
20460.
equ/pmem/s/ocafetf.

3 Thoce/tfflcMonsrafavneytf/iKMtea/gnetftyintpevro
4 (tht person may tw tne owner of tte earaW/iftmenr or anomer wspona/fcrt <^(^. 7T>e person wfioa/orw/s
certifying ttitttf*ytuv9 aequ/nKftntequ/pmenT, Wtf eac/i/ntfMtfoa/autfJorfzetf fo use tf»ecutenw.T»/a prop-
•fy tn/netf and certffetf,
4 Smalt entity Certification. Sendee esraW/snrrwntf tnatsorv/eeo* /ewev tnan 100 Jots Involving nfrieefv* dur-
ing 1990 v» not nqulrrt to purchunqulpmwt until Jtnuvy 1, 1993. To qua/fly for tfj/s one year vasnston, tne
'
owner must fie aWe ID prove ff sewteetf/ewertftafl 100 lots In 1990. Sma//e«We*/7xaf6oy approved eou/p-
m«nf antf certfly to £R4 tyJvtuvy 1, 1993.
FIGURE 1. EPA STANDARD FACILITY CERTIFICATION FORM FOR MVAC
SERVICE FACILITIES

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  Summary of Section 609 of the CAAA

       REFRIGERANTS

       Refrigerants covered under section 609 include those listed in
 Section 602 of the CAAA as "class I and class II substances."  Substances
 can be added to the lists. Class I substances include chlorofluorocarbons
 (CFCs), halons, carbon tetrachloride, and methyl chloroform.  Class II
 substances include hydrochlorofluorocarbons (HCFCs) exclusively. CFC-
 12 is covered under Section 609 as a class  I substance.

      CFC-12 is the most common refrigerant used today. The industry is
 developing new refrigerants, such as HFC-134a. This chemical is not a
 CFC or HCFC so it is not currently covered. However, as of November  15,
 1995 any refrigerant used in a motor vehicle air conditioner, or any
 substitute refrigerant for CFC-12, must be recycled.

      APPROVED EOUIPMFNT

     The CAAA requires that only certified, or "approved refrigerant
 recycling equipment," be used in MVAC servicing. To be approved,
 equipment must at a minimum meet The Society of Automotive Engineers
 (SAE) standards for approval. Recover/recycle equipment must meet SAE
standard J-1990. Recover only equipment must meet SAE standard J-
2209. At present, Underwriter Laboratories  (UL) approves equipment.
ETL, another testing laboratory,  may also certify equipment.
                                8

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      Approved equipment should have a label indicating that the
equipment is "design certified to meet SAE standards."  Chapter 6.0
includes an illustration of UL's certification label.  Chapter 4.0 includes a list
of UL-approved MVAC servicing equipment. MVAC service facilities must
use only approved equipment consistent with deadlines in Chapter 2.

      TRAINED AND CERTIFIED TECHNICIANS

      The CAAA does not assume that a MVAC service shop will eliminate
CFC emissions simply by using approved equipment. The Act requires that
the equipment be used "properly." The strict definition of properly using the
equipment is doing so to at least the standards of the Society of Automotive
Engineers. These standards are referred to as SAE standard J-1989 and
are in the appendices of the Final Rule.

      To ensure that equipment is used properly, Section 609 requires that
persons servicing MVACs become properly trained and certified. See
Chapter 2.0 for effective dates. Chapter 6.0 includes examples of
certificates from several of the first technician training programs. Various
training programs have been developed to meet this industry need, and the
inclusion of the sample training certification  forms in this manual is not an
endorsement of one training program over another.

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 STANDARD FORMS FOR FACILITY CERTIFICATION
      Equipment Owner Certification

      Certification to EPA by the facility must be made to document that
 approved equipment has been purchased and the persons performing
 MVAC service are properly trained and certified. The certification must
 include the name and address of the establishment; manufacturer, model,
 and the serial number of the equipment to be used; and the name and
 signature(s) of the facility owner or other responsible person.  All facilities
 must submit the equipment owner's certification by January 1,1993. The
 example form for this required submittal is included previously in this
 Chapter and also in Chapter 6.0.

      Equipment owner certifications are not transferable. If the shop is
 sold, the new owner must submit a new equipment owners certification.

      Small Business Certification

      Shops that performed service on less than 100 motor vehicle air
conditioners in 1990 are considered small entities and have until January 1,
1993 to purchase equipment and train technicians.  To qualify for this
extension, a shop must certify to EPA by January 1,1992 that  it is a small
entity. The certification must include the name and address of the facility,
and the signature of the facility owner or responsible party.
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      SMALL CONTAINERS

      Small containers of refrigerants are defined as those containing less
 than 20 pounds of refrigerant. Effective November 15, 1992, only certified
 technicians may purchase small cans. Purchasers of small cans will have to
 show proof of technician certification. The sale of containers of 20 pounds
 or more is not restricted.

      DEFINITION OF SERVICE

      MVAC service covered by Section 609 includes any service to a
 MVAC that in any way may release refrigerant, including adding charges of
 refrigerant, replacing refrigerant, working on a MVAC, or performing any
 other service that may release the refrigerant.  MVAC service may be
 performed by service shops, repair shops, service stations, new or used car
 or truck dealerships, rental establishments, fleet shops (i.e., trucking
 companies, car rental agencies, corporate or government fleets), or
vocational technical schools. The only work excluded is that done for free.
                                11

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       CHAPTER 3
Descriptions of Level 1 and Level 2
      MVAC Inspections

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Chapter 3.0   Descriptions of Level 1 and  Level 2 MVAC
        inspections
Chapter Summary

     The following descriptions of Level 1 and Level 2 MVAC inspections
provide simple discussions of each, including:

     •    Differences between Level 1 and Level 2 MVAC service facility
          inspections;

     •    When to expand an inspection to Level 2;

     •    The Level 1 small can retailer inspection; and

     •    "Gray areas" that inspectors might encounter.
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     LEVEL 1 MVAC SERVICE FACILITY INSPECTIONS

     Level 1 inspections are essentially "walk-throughs" of a MVAC facility,
and may be as simple as completing the Level 1 Inspection Checklist
included in Chapter 4.0.  For facilities that understand the requirements and
are reasonably well organized, an inspector should:

     •     Identify yourself and ask for the appropriate facility
           representative, owner, or responsible person;

     •     Note how the facility owner became informed about the MVAC
           requirements (this checklist item will be used by EPA in
           targeting new or better ways of communicating their
           requirements and making compliance even more easily
           understood);

     •     Explain the purpose of your inspection;

     •     Note the facility name, address, name of owner or operator, and
          name and title of person in charge;

     •    Ask how they found out about the regulations;

     •    Note the facility setting (i.e. urban, rural, etc.);

     •    Note the facility description, which will qualitatively differentiate
          the relative size of the facility;
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 Note the vehicle types serviced, and the number of MVAC
 service jobs per year - at present;

 Note if the facility is A Small Entity, and has documented that
 they performed less than 100 MVAC service jobs in 1990;

 Note if recovery only or recover/recycle equipment is present;

 Note if the MVAC recover/recycle or recover only equipment is
 on the list approved by UL under EPA requirements:

 Note the type of equipment (i.e. 3 recover only and 1
 recover/recycle);

 Note the specific equipment brand, model, year manufactured,
 serial number, and type of equipment (either recovery only or
 recovery/recycling^:

 If equipment is recover only, the inspector should ask what they
 do with the recovered refrigerant.  Refrigerant must either be
 sent off-site to be reclaimed (cleaned to a higher standard of
 purity than recycling) or if the business has several facilities in
 the area owned by one person (the equipment must also be
 owned by the shop owner) than the refrigerant may be recycled
at one of the business's other locations. This exception does
not apply to  nationwide or regional corporations, chains or
franchises.  An inspector may determine the need to go to Level
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 2, evaluating recordkeeping requirements to ensure proper off-
 site recycling or reclamation is occurring;

 Note if the technicians are certified by an accredited training
 program number;

 If technician certification has been noted, but the accreditation
 is uncertain, photocopy the training certificate for later
 evaluation - should the program indeed be accredited, update
 this manual to reflect that;

 Note  the total number of technicians trained to service MVACs
 at the facility, which training courses they attended, and the
 dates on which they attended (If there are a large number of
 technicians, you may make notations, such as "most
 technicians trained by MACS in August 1990. Total of 18
 certified technicians.");

 The facility must have file copies of training certifications,  and
 an inspector should determine if the staff who have been
 trained are still employed;

The inspector must print their name, the date of the inspection,
time of the inspection, and  sign the completed checklist at the
conclusion of the Level 1 inspection. Compliance status must
also be checked. Should the inspector have reason (see
following section) to expand the inspection to a Level  2, they
should so note at the bottom of the Level 1 checklist;
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      After collecting the above Level 1 inspection information, the
inspector may want to observe the MVAC service area, cross reference
equipment serial numbers to equipment in use, and possibly have a
certified technician demonstrate the procedures. If the inspector
determines that the requirements of Section 609 covering trained
technicians, approved recovery/recycling equipment, small entity status, or
facility documentation are not in order, the inspector may want to conduct a
Level 2 inspection.

      An inspector can provide the responsible party with the EPA Fact
Sheet (see Figure 2) and any other MVAC handouts  at the time of
inspection and explain the requirements.  A goal of the inspection program
is to help the regulated community to understand the program and its
compliance requirements and deadlines.
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[ Motor Vehicle Air Conditioning Service J^i gp^ j
STRATOSPHERIC OZOMX PROTECSZOW
Ground level ozone is * pollutant often called smog. However, in tha
upper atmosphere, known as the stratosphere, ozone shields the earth from
harmful ultraviolet radiation. Certain man-made chemicals including
chlorofluorocarbons (CFCs) are destroying the stratospheric ozone. The use of
CFC-12, the common refrigerant used in automobile air conditioners, accounts
for over 20% of the United States CFC use. The loss of ozone in the upper
atmosphere is associated with an increase in skin cancer, cataracts, and
damage to the human immune system. It is also associated with reduced crop
yields, harm to plant and animal life, and the deterioration of materials.

On November IS, 1990 the President signed the Clean Air Act Amendments
which phase out the production of CFCs by the year 2000 and require the
recycling of CFCs used in motor vehicle air conditioners. EPA proposed
regulations on September 4, 1991 for servicing motor vehicle air conditioners.
The proposed regulation* are subject to change upon promulgation in the fall
of 1991.
Amcxxvo TH» SERVICE or KOTO* VESICIB AIR
CONDITIONERS ' (Check with your state and local government, some have
additional requirements.)

Effective January 1, 1992
• Shops servicing motor vehicle air conditioners must recycle CFC
refrigerant beginning January 1, 1992. Technicians must be properly
trained and certified, and use approved refrigerant recycling equipment
Technicians must complete an EPA approved refrigerant recycling course to
be certified.

• Shop* that performed service on lea* than 100 motor vehicle air
conditioners in 1990 are considered small entities and have until January
1, 1993 'to purchase equipment and train technician*. To qualify for this
extension a shop must certify to EPA by January 1, 1992 that it is a small
entity.

• Recycling equipment must be certified by an EPA approved lab. At the
present time, only equipment with the Underwriters Laboratory
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WHEN TO CONDUCT A LEVEL 2 INSPECTION

At all times, the inspector has the option to conduct the Level 2 MVAC
service facility inspection. A Level 2 inspection should be considered if:

• The facility uses recover only equipment;

• The facility does not have clear documentation of compliance
pertaining to technician training or approved equipment use.

An inspector may have reason to conduct the inspection, other than those
cited above. If so, the inspector should document the reasons clearly.
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LEVEL 2 MVAC SERVICE FACILITY INSPECTIONS

The fundamental difference between Level 1 and Level 2 Inspections
is that under Level 2 the inspector will seek further detail of facility
procedures and refrigerant handling in the way of documentation. Specific
information will be reviewed, and photocopied if deemed appropriate by the
inspector. This may include customer service invoices, reclaimer billings for
off-site recycling, refrigerant reclaimer information, and any other records
the inspector finds necessary. It is important to note that due to revisions of
the final rule many areas of recordkeeping have been eliminated. These
include customer invoices and the date and quantity of refrigerant sent for
reclamation. The name and address of the reclaimer must still be kept on
file.

This level 2 checklist asks questions about some of the records that
businesses are no longer required to maintain. The reason for this is
approximately 80% of businesses do retain these records and as an
inspector you may request and use these records if available. It is not a
violation for failing to maintain customer invoices or reclaimer invoices.

Level 2 inspections essentially expand the review of recordkeeping,
and will require completion of the Level 2 Inspection Checklist included in
Chapter 4.0 (and assumes that the Level 1 Checklist has been completed).
Additional detail as to any observed or noted compliance shortcomings or
issues will be required on the checklist. These notations will serve as
documentation for the inspector's compliance determination, and provide
necessary support for any possible enforcement action.
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IF RECOVER ONLY EQUIPMENT IS USED

Should recover only equipment be used for MVAC servicing at a
facility, three possible options exist for recycling the recovered refrigerant:

• The first option would require that a facility also have
recovery/recycling equipment on-site: in which case the facility
may recycle on site. The recovery only equipment is less
expensive and therefore, this option would be most useful to a
large facility with many bays.

• The second option is available for a group of service facilities
owned by the same person (no chains or franchises) who owns
the recovery and recycle/recover equipment as well. This
option allows refrigerant to be recovered at each shop and
recycled at one location.

• The third option requires that the facility send the recovered
refrigerant off-site to a reclaimer who must reclaim to a higher
standard of purity, according to standard ARI 700. The more
stringent off-site reclamation standards reflect the concern that
refrigerant contamination is possible when refrigerant is sent off-
site. On-site recycling can be done to the SAE J1991 standard
. of purity, whereas recovered refrigerant that leaves the service
facility (and is not covered under option 2} must be reclaimed to
a higher standard of purity (the ARI 700-88 standard).
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Although some redundancy exists with regard to Level 1 checklist
items, the Level 2 checklist allows for further confirmation of whether the
facility is or is not complying with Section 609. Level 2 checklist items
include:

• Rechecking the reason for performing the Level 2 inspection,
including certification shortcomings and recover only
equipment;

Off-site reclaimer or recycler (if same owner) information,
name, address, and phone;

• Availability of invoices to document proper off-site fate of
recovered refrigerant;

• Notation of any other records at the facility to demonstrate
compliance;

• Photocopies of documentation obtained; and,

• Clear statement of any further action required.
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LEVEL 1 SMALL CAN RETAILER INSPECTIONS

A small can retailer inspection will require the inspector to attempt to
purchase a small can of refrigerant without any proof of technician
certification. The information on this checklist will be different from the
service facility inspections because the inspector must first try to purchase
the small can. The inspection will proceed as follows:

• Note the facility name, and address before entering;

• Attempt to purchase a container, weighing less than twenty
pounds, of CFC-12 or other refrigerant used in a motor vehicle
air conditioner; If it is not available on the shelves ask if they sell
th.e small containers.

• If you are able to purchase the small can make sure you get and
keep your receipt. You may want to take the can and receipt out
to your car then answer the questions on how they display the
merchandise and if the sign was visible.

• Return and identify yourself and ask for the appropriate facility
representative, owner, or responsible person;

• Explain the purpose of your inspection;

• Note how the facility owner became informed about the sales
restriction;
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Ask if they sell wholesale as well as retail;

If they do check for certifications that their customers are
purchasing for resale only to certified technicians.

Note if photocopies were made;

The inspector must print their name, the date of the inspection,
time of the inspection, and sign the completed checklist at the
conclusion of the inspection. Compliance status must also be
checked.
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POTENTIAL "GRAY AREAS" FOR SECTION 609 COMPLIANT

Inspectors will undoubtedly encounter "gray areas" or issues that are
not completely clear. Inspectors should consult EPA's Stationary Source
Compliance Division for clarity as new questions arise that are not explicitly
addressed in the Final Rule. EPA has identified the following examples of
questions which have required clarification. Many of these questions are
clarified in the Final Rule. Specifically, inspectors needing further
clarification of "gray areas" may contact Belinda Breidenbach at:

U.S. Environmental Protection Agency
Stationary Source Compliance Division
Mail code EN-341W
401 M Street, S.W.
Washington, D.C. 20460
Telephone (703) 308-8710
Fax (703) 308-8581
The regulated community can have questions answered by the toll free
stratospheric ozone hotline.
1-800-296-1996
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Question 1: What types of units fall within the definition of motor
vehicle air conditioners, as they are covered by Section 609?

Answer: Refrigeration equipment used to cool motor vehicle driver or
passenger compartments are included. For example in a transport or
commercial truck the driver/passenger cooling system is covered under
Section 609. In the same vehicle there may be a hermetically sealed
refrigeration unit for cooling stored materials; this unit is covered under
Section 608. It is anticipated that all systems not covered under Section
609 will be included in. Section 608. Note that Section 608 prohibits venting
of refrigerant after July 1,1992.

Question 2: What types of vehicles are covered under Section
609?

Answer: Vehicles that are covered include those that transport people or
property, including passenger cars, trucks, light and heavy duty vehicles on
a street or highway. Section 609 uses the title II definition of motor vehicle.

Question 3: What types of vehicles are not covered under
Section 609?

Answer: Vehicles that are not included as motor vehicles covered under
Section 609 include trains, airplanes, marine vessels or motor boats, farm
equipment, construction equipment, and buses that use a HCFC-22
system. EPA anticipates that these vehicles will be covered by the
prohibition of venting, Section 608, although EPA has reserved the right to
reconsider and include these vehicles under Section 609. Buses commonly
use HCFC-22 as a refrigerant, like a stationary air conditioning unit, and
Section 609 cites only standards for CFC-12. Hence, HCFC-22 bus air

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conditioner servicing will be covered under Section 608. Busses that use
CFC-12 are covered under Section 609.

Question 4: Is CFC-12 the only refrigerant covered under
Section 609?

Answer: No. The standards are currently only written for CFC-12.
However, substitute substances containing CFCs or HCFCs are covered,
including R-176 (a CFC-12, HCFC-142b and HCFC-22 blend). All MVAC
refrigerants, including HFC-134a, no matter what the substance will be
covered by 1995.

Question 5: What constitutes "servicing" of a MVAC?

Answer: Service involving the refrigerant means any service during which
discharge or release of refrigerant from the motor vehicle air conditioner to
the atmosphere can reasonably be expected to occur. Examples of
servicing include dismantling MVACs, any repairs to a system that requires
removal of the MVAC or disconnection of hoses, leak testing, or adding
refrigerant to "top off" a system.

Question 6: Are any services on MVACs not covered by Section
609?

Answer: Yes, services performed for free are not covered under Section
609; i.e. where the person performing the servicing is not being paid.
However, service for consideration does include fleets and vocational
schools. These groups, although not billing for the MVAC servicing directly
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or being paid a set fee explicitly for the service work, are paid employees
whose jobs include MVAC service.

Question 7: If a single company owns several MVAC service
establishments, can they use recover only equipment at multiple
facilities and then send the recovered refrigerant to a single,
central location for recycling to the SAE J1991 standard?

Answer: Yes. If all of the shops are owned by the same person and all of
the equipment .(recover units and the recover/recycle unit) are owned by
the shop owner. This option is not available to chains or franchises, shops
with the same name and different owners.

Question 8: Are there any other ways to recycle off-site?

Answer: No. Once refrigerant leaves a site it must be reclaimed to the
more stringent standard of purity defined by the Air-conditioning and
Refrigeration Institute (ARI Standard 700-88).

Question 9: How can an inspector most simply describe the
difference between on-site recycling and off-site reclamation?

Answer: On-site recycling involves equipment specifically designed and
approved for cleaning the refrigerant from a motor vehicle air conditioner.
Off-site reclamation distills the recovered refrigerant to a higher standard of
purity. This is necessary if refrigerant leaves the owners possession
because other types of equipment use CFC-12 and those systems can
introduce contaminants to the refrigerant that can not be removed by
27
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recycling. Reclamation is necessary to maintain the purity of the refrigerant
and prevent motor vehicle air conditioners from being damaged by
contaminated refrigerant.

Question 10: What is the simplest definition of "approved
recover/recycle equipment?"

Answer: Equipment that "has been design certified to meet the SAE
standards" by Underwriters Laboratory (UL) is considered approved
equipment. ETL may also test and approve equipment.

Question 11: How does an inspector ensure that equipment has
been certified by UL?

Answer: The equipment should have a label affixed to it with UL's "design
certified to meet SAE standards" label (see Chapter 6.0 for an illustration of
the label). An inspector may also compare the equipment manufacturer,
make and model with the Table listing UL certified equipment provided in
Chapter 4.0.

Question 12: Is any equipment approved or certified that is not
on the list shown in Chapter 4.0?

Answer: Probably. UL or ETL may have certified additional equipment
since this manual was developed, and inspectors should expect to update
the list as additional equipment is approved. Also, EPA acknowledges that
equipment purchased before regulations were proposed will be considered
certified if it is "substantially identical" to approved equipment.
28
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Question 13: What if my equipment is not UL (or ETL) approved?

Answer. If the equipment was purchased before September 4,1992 it can
apply to be determined substantially identical to equipment that was
certified. It still must meet the SAE J standards. Not many pieces of
equipment are expected to be determined substantially identical. The
reason for this is most approved equipment did not initially meet the SAE J
standards and had to be modified to pass the tests. Owners of uncertified
equipment should first contact the manufacturer. EPA will have a list of
substantially identical equipment that you can add to this manual.

Question 14: Are technician certification programs intended to
test MVAC technician "problem diagnosis and repair" skills?

Answer: No. Certification programs are only required to teach technicians
how to recover and recycle refrigerant, why refrigerant recovery and
recycling must be done to protect the stratospheric ozone, and what the
regulatory requirements are.

Question 15: What is the simplest definition of how a technician
"properly uses" approved equipment?

Answer: Proper use of equipment simply means following SAE standard
J1989, which each properly trained technician should be understand.
Properly using recover/recycle equipment includes recycling the refrigerant
before reuse. Properly using recover only equipment includes sending
recovered refrigerant to an off-site reclaimer or owner, or recycling the
recovered refrigerant on-site with a separate recover/recycling unit.
29
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Question 16: What should an inspector do if they find technician
certification forms from what is believed to be an unaccredited
training program?

Answer: Photocopy the form, make sure the program name and address
are clear. Contact Headquarters to determine the status of the training
program.

Question 17: How might a facility that only serviced 50 cars in
1990 nol be considered a Small Entity?

Answer: The total number of service events during 1990 is the basis for
Small Entity consideration. Hence; if a fleet serviced only 50 cars in 1990,
but averaged 3 service events for each car, they would not qualify as a
Small Entity due to a total of 150 service events.
30
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CHAPTER 4
Inspection Checklists
....
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Chapter 4.0 Inspection Checklists
Chapter Summary

Inspection checklists are provided for the inspector's use when
performing:

• Level 1 MVAC service facility inspections;

• Level 2 MVAC service facility inspection's; and

• Level 1 small can retail sales establishment inspections.

A list of UL-approved equipment is also provided for cross referencing
during inspections (Tables 1, 2, and 3).
31
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LEVEL 2 INSPECTION CHECKLIST
MOTOR VEHICLE CONDITIONING RECOVERY/RECYCLING
COMPLIANCE PROGRAM
NOTE; Complete the LEVEL 1 inspection checklist first.
29. Reason for performing LEVEL 2 inspection?

Recover only equipment
Other
30. Is equipment owner certification paperwork in order? (i.e. forms...)
Yes
No
If not, please explain:
31. Are customer invoices available?

Yes
No
32. Did the customer invoice record:

Note that service involving refrigerant was performed.

33. Are the customer invoices:

Well kept records with all invormation available?
Good records with only a few missing required information?
Poor records with most lacking required information:
(Level 2 MVAC Inspection Checklist!
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34. Name of Refrigerant Reclaimer

35. Reclaimer Phone

36. Reclaimer Address
37 For any or all invoices or records reviewed, were photocopies made?
Yes
No
If "yes", please attach photocopies.
38. Compliance Status

In compliance
Not in compliance
39. Inspector Name

40. Inspection Date

41. Time of Inspection

42. Inspector Signature
(Level 2 MVAC Inspection Checklist)
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MOTOR VEHICLE AIR CONDITIONING
SMALL CAN RETAILER INSPECTION CHECKLIST
1. Facility Name.
2. Facility Address
3. Name of Owner/Operator

4. Name of Person in Charge

5. Title of Person in Charge_
6. How did you find out about requirements?

Fact Sheet Did not know about requirements
Trade Association Word of Mouth
Articles Other
7. Are small cans of refrigerant available on the shelves?

Yes
No

Are they kept behind the counter?

Yes
No
Other locations
. Do not sell small cans of refrigerant
8. If small cans are sold, is there a sign prominently displayed stating that small cans of refrigerant
can only be sold to certified technicians?

Yes
No
N/A
9. Were you able to purchase a small can of refrigerant?

Yes
No
(Small Can Level 1 MVAC Inspection Checklist)
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10. Does the business sell wholesale as well as retail?

Yes
No

11. If yes: Do they have certifications from retailers that the refrigerant is for resale only?

Yes
No
12. For any or all invoices or records reviewed, were photocopies made?

Yes
No

If "yes", please attach photocopies.
13. Is the business in compliance?

Yes
No
14. inspector Name

15. Inspection Date
16. Time of inspection.
17. Inspector Signature.
(Small Can Level 1 MVAC Inspection Checklist)
-------
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Approved Technician Certification Programs

Mobile Air Conditioning Society

National Institute of Automotive Service Excellence

International Mobile Air Conditioning Association

The Greater Cleveland Automobile Dealers Association

Rancho Santiago College

New York State Association of Service Stations

The programs listed below are intended specifically
for the employees of these companies.

Ryder Truck Rental Incorporated

Potomac Electric Power Company

Kmart Corporation

Yellow Freight System, Incorporated

U.S. Army Ordnance School, Tactical Support Equipment Department, Fort
Belvoir, Va
-------
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CHAPTER 5
Recordkeeping Requirements
Mill
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Chapter 5.0 Recordkeepina Requirements

Chapter Summary

A discussion of recordkeeping requirements, as anticipated from the
Proposed Final Rule, follows and briefly covers:

• Small entity and equipment owner certification;

• Certification forms for trained technicians and facility operators;

• Invoices and records for documenting recovered refrigerant
that requires off-site reclamation; and

Documentation related to sales or purchasers of small cans of
refrigerant.
43
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Equipment owner certification forms, which also include space for
certifying a facility as a Small Entity, should not only be sent to EPA, but a
copy of the form should be kept on-site. A standard form for this purpose,
is included in Chapter 6.0. The form notes that approved equipment must
have been purchased by January 1,1992 if the business was servicing
MVACs, unless a facility was a Small Entity, in which case the approved
equipment has to be purchased by January 1,1993. In the case of Small
Entities, those establishments must retain records to verify that they
performed less than 100 MVAC service jobs in 1990.

Certification forms for trained technicians or copies of all training
certificates, of the technicians who are authorized to use the equipment,
must be maintained by the service establishment.

Records documenting where the refrigerant is sent off-site for
reclamation or recycling must be kept by the service facility, so that they can
prove that they have not released or reused the substance without
purification.

For small can sales/purchases, wholesalers and distributors may
attest in writing that the refrigerant is for resale only (as opposed to
technicians showing proof of certification). The seller must maintain these
records for three years.
44
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Will
T^li I
CHAPTER 6
Example Forms.
Kill
-------
-------
Chapter 6.0 Examples of Forms
Chapter Summary

The following text offers specific examples of forms that inspectors
are required to review. These include:

• Equipment owner certification forms;

• Examples of technician training certification forms;

UL label for approved equipment; and a

• Schematic illustration of standard equipment.
45
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MVAC RECOVER/RECYCLE OR RECOVER EQUIPMENT
CERTIFICATION FORM
StTMt
Ctty, Stat». Zip Cod*
(Ana Codt) T»l«ph xw Numbw
N«n» of Equipment Manufacturer and Model Number
S*rtaJ Numbtrfo)
Small Entity Certification.
I certify that fewer thin 100 jobs Involving, refrl-
gerant war* performed at the establishment
named In Part 1 of this form during 1 WO. I will
purchase approved equipment and certify this to
EPA by January 1,1093.
Signature
Date
Nam* (PIMM Print)
TWe
Year
3 t certify tin it I have acquired approved recover/recycle or
' recover equipment under Section 609 of the Clean Air
Act I certify that only property trained and certified tech-
nicians operate the equipment and that the Information
given above Is true and correct
SJgnttur* of Owner/Operator
Date
Nam* (PIMM Print)
Ttte
Send this form to:
MVACs Recycling Program Manager
Stratospheric Ozone
Protection Branch
(6202-J)
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
MVAC RECOVER/RECYCLE OR RECOVER EQUIPMENT
CERTIFICATION FORM INSTRUCTIONS

Motor vehicle reaver/recycle or recover equipment must be acquired by January 1 ,1 092 and certified to EPA
on or before w^trary 1 , 1 993 under Section 609 of the Clean Air Act To certify your equipment, pleaae com-
plete the above form according to the following Instructions and mall to EPA at the following address: MVACs
Recycling Program Manager, Stratospheric Ozone Protection Branch, (6202-J), U.S. EPA, 401 M Street,
S.W., Washington , D.C. 20460.

•I Please provide the name, address and telephone number of the establishment where the recover/recycle or
" recover equipment Is located.
Please provide the name brand, model number, year, and serial numberfs) of the recover/recycle or recover
equipment acquired for use at the above establishment
TTre certification statement must be signed by the person who has acquired the recover/recycle or recover
equipment (the person may be the owner of the establishment or another responsible officer). Thepersonwho
signs Is certifying that they have acquired the equipment, that each Individual authorized to use the equipment
Is property trained and certified, and that the Information provided Is true and correct

A SmaH Entity Certification. Service establishments that serviced fewer than 100 Jobs Involving refrigerant dur-
^ Ing 1990 are not requlredto purchase equipment urttilJanuaryl, 1993. ToquaUtyforthlsoneyearextenslon, the
owner must fill out Parti, sign the statement In Part 4 above, and send this form to EPA. Upon Inspection, the
owner must be able to prove It serviced fewer than lOOIobsIn 1990. SmaH entities must buy approved equip-
ment and certify to EPA by January 1, 1993.
-------
ames Qezftif-i
has successfully completed training in CFC-12
refrigerant recycling and service procedures
offered by the Mobile Air Conditioning Society.
FIGURE 4. SAMPLE TRAINING CERTIFICATE
INTERNATIONAL MOMLE AM CONOrnONINO ASSOCIATION
has successfully completed training and
is KK&a certified in the proper use of R-12
refrigerant recovery and recycling equipment.
FIGURE 5. SAMPLE TRAINING CERTIFICATE
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Underwriters Laboratories be.*
LZflTZD
RBFRXOIRAVT RICOVIRY EQOIPM1MT
OR
COMMERCIAL RICOV1R*/ RECYCLING EQUIPMENT
C«rti£i«d by Underwriter. Laboratoriu mo.
in aoeordane* vith ARI 740-ltti for th« followiag
oharaet«ri«tie»"
FIGURE 6. DL SEAL FOR APPROVED EQUIPMENT
FIGURE 7. GENERIC EQUIPMENT SCHEMATIC
-------
H4=^i
CHAPTER 7
Section 609 of the CAAA

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Chapter 7.0 A Copy of Section 609 of the CAAA
Chapter Summary
EPA regulations spell out exactly how to comply with Section 609 of
the CAAA. Due to the length of the anticipated Final Rule and the fact that
promulgation has not occurred at this writing, inspectors will be provided
with the Final Rule as a separate reference.
49
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"SEC. 609. SERVICING OF MOTOR VEHICLE AIR CONDITIONERS.

"(a) REGULATIONS.-within one year after the enactment of the
Clean Air Act Amendments of-1990, the Administrator shall
promulgate regulations in accordance with this section
establishing standards and requirements regarding the servicing of
motor vehicle air conditioners.
"(b) DEFINITIONS.-As used in this section-
"(1) The term 'refrigerant1 means any class I or class
II substance used in a motor vehicle air conditioner.
Effective five years after the enactment of the Clean Air Act
Amendments of 1990, the term 'refrigerant' shall also include
any substitute substance.
"(2)(A) The term 'approved refrigerant recycling
equipment1 means equipment certified by the Administrator (or
an independent standards testing organization approved by the
Administrator) to meet the standards established by the
Administrator and applicable to equipment for the extraction
and reclamation of refrigerant from motor vehicle air
conditioners. Such standards shall, at a minimum, be at least
as stringent as the standards of the Society of Automotive
Engineers in effect as of the date of the enactment of the
Clean Air Act Amendments of 1990 and applicable to such
equipment (SAE standard J-1990).
"(B) Equipment purchased before the proposal of
regulations under this section shall be considered certified
if it is substantially identical to equipment certified as
provided in subparagraph (A).
"(3) The term 'properly using' means, with respect to
approved refrigerant recycling equipment, using such
equipment in conformity with standards established by the
Administrator and applicable to the use of such equipment.
Such standards shall, at a minimum, be at least as stringent
as the standards of the Society of Automotive Engineers in
effect as of the date of the. enactment of the Clean Air Act
Amendments of 1990 and applicable to the use of such
equipment (SAE standard J-1989).
"(4) The term 'properly trained and certified' means
training and certification in the proper use of approved
refrigerant recycling equipment for motor vehicle air
conditioners in conformity with standards established by the
Administrator and applicable to the performance of service on
motor vehicle air conditioners. Such standards shall, at a
minimum, be at least as stringent as specified, as of the
date .of the enactment of the Clean Air Act Amendments of
1990, in SAE standard J-1989 under the certification program
of the National Institute for Automotive Service Excellence
(ASE) or under a similar program such as the training and
certification program of the Mobile Air Conditioning Society
(MACS) .
-------
"(C) SERVICING MOTOR VEHICLE AIR CONDITIONERS.-Effective
January 1, 1992, no person repairing or servicing motor vehicles
for consideration may perform any service on a motor vehicle air
conditioner involving the refrigerant for such air conditioner
without properly using approved refrigerant recycling equipment
and no such person may perform such service unless such person has
been properly trained and certified. The requirements of the
previous sentence shall not apply until January 1, 1993 in the
case of a person repairing or servicing motor vehicles for
consideration at an entity which performed service on fewer than
100 motor vehicle air conditioners during calendar year 1990 and
if such person so certifies, pursuant to subsection (d)(2), to the
Administrator by January 1, 1992.
"(d) CERTIFICATION.-(1) Effective two years after the
enactment of the Clean Air Act Amendments of 1990, each person
performing service on motor vehicle air conditioners for
consideration shall certify to the Administrator either-
"(A) that such person has acquired, and is properly
using, approved refrigerant recycling equipment in service on
motor vehicle air conditioners involving refrigerant and that
each individual authorized by such person to perform such
service is properly trained and certified; or
"(B) that such person is performing such service at an
entity which serviced fewer than 100 motor vehicle air
conditioners in 1991.
"(2) Effective January 1, 1993, each person who certified
under paragraph (1)(B) shall submit a certification under
paragraph (1)(A).
"(3) Each certification under this subsection shall contain
the name and address of the person certifying under this
subsection and the serial number of each unit of approved
recycling equipment acquired by such person and shall be signed
and attested by the owner or another responsible officer
Certifications under paragraph (1)(A) may be made by submitting
the required information to the Administrator on a standard form
provided by the manufacturer of certified refrigerant recycling
equipment.
"(e) SMALL CONTAINERS OF CLASS I OR CLASS II
SUBSTANCES.-Effective two years after the date of the enactment of
the Clean Air Act Amendments of 1990, it shall be unlawful for any
person to sell or distribute, or offer for sale or distribution,
in interstate commerce to any person (other than a person
performing service for consideration on motor vehicle
air-conditioning systems in compliance with this section) any
class I or class II substance that is suitable for use as a
refrigerant in a motor vehicle air-conditioning system and that is
in a container which contains less than 20 pounds of such
refrigerant.
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r
CHAPTER 8
A Certificate of Completion
.1

ttSU
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Chapter 8.0 A Certificate of Completion

Chapter Summary

The certification included in this final section of the manual is for
inspectors who complete the self-examination that follows.

Inspector Training Self-Examination

Please answer the following questions.

1. What document contains the authority to regulate the servicing of
motor vehicle air conditioners?
2. After November 15, 1992 who can purchase containers of refrigerant
weighing less than twenty pounds?
3. Who can purchase containers of refrigerant weighing more than
twenty pounds?
4. Who approves equipment?
52
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5. What are the three topics technicians need to learn in an approved
training program?
6. Are technicians required to prove they can properly repair air
conditioners?
7. What else do technicians need their certification for?
8. How can an inspector check if equipment is approved?

9. If an inspector finds a model of recover/recycle equipment that they
are not sure of whether it is approved or not, or if they find a technician
training certificate that identifies a training program that they are unaware
of, what should they do?
Once EPA trainers are satisfied that an inspector can adequately
answer the above questions, and that they have completed the required
inspector training, the following certificate should be signed and provided to
the inspector.
53
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