United States
   Environmental Protection

Motor Vehicle Air Conditioning
Servicing among Tribal Technicians

To prevent refrigerant emissions during the servicing of motor vehicle air conditioning (MVAC)
systems, the U.S.  Environmental Protection Agency (EPA), under Section 609 of the Clean Air Act,
requires that motor vehicle technicians be trained and certified in the proper use of approved
MVAC servicing equipment.  In 2013, through funds from EPA's Tribal Program,  EPA partnered with
two tribes to conduct Section 609 certification sessions for about 60 technicians from tribal fleet
service centers across Arizona and California. The observations and conclusions of this case study
are only representative of a subset of technicians from the tribal fleet service centers for which
training was provided.

Currently, the  most common refrigerant used in MVAC systems is hydrofluorocarbon (HFC)-134a.
MFCs are intentionally made fluorinated greenhouse gases used in air-conditioning, refrigeration,
foam-blowing,  fire retardants, solvents, and aerosols. They are widely used as replacements for
ozone-depleting substances, whose use is being phased out globally under the Montreal Protocol
on Substances  that Deplete the Ozone Layer. Ozone-depleting substances destroy the
stratospheric ozone layer that shields the Earth from the  sun's harmful ultraviolet radiation. Use
of the ozone-depleting refrigerant, chlorofluorocarbon (CFC)-12, in new MVAC systems in the
United States ceased in the 1990s. Since 1994, the most common refrigerant has been HFC-134a, a
substance that does not deplete the ozone, but is a potent greenhouse gas. Today, many motor
vehicle  manufacturers are beginning to transition to new, climate-friendly alternatives.

Under Section  609 of the Clean Air Act, EPA-approved technician training and certification
programs provide  education on the proper use of MVAC servicing equipment, the regulatory
requirements of the Clean Air Act, the importance of refrigerant recovery, as well as the effects
of improper handling of refrigerants on the ozone layer and climate system. To be certified,
technicians must be trained by an EPA-approved program and pass a test demonstrating their
knowledge in these areas. Section  609 certification is required to service any motor vehicle air
conditioning system for consideration  (i.e., payment or bartering), regardless of the refrigerant
used in the system.
                                        Table 1. Environmental impacts of MVAC refrigerants1'"

                                                            Global warming      Ozone
EPA's Significant New Alternatives
Policy (SNAP) program ensures the
smooth transition to alternatives that
pose lower overall risk to human health
and the environment. The SNAP program
evaluates and finds acceptable
substitutes for ozone-depleting
substances. Under the SNAP program,
EPA recently found acceptable,  subject
to use conditions, three low global
warming  potential MVAC refrigerants:
HFC-152a, hydrofluoroolefin (HFO)-1234yf, and carbon dioxide (C02). None of these alternatives
deplete the ozone layer and all have significantly lower global warming potentials than CFC-12 or
HFC-134a. Table 1 shows the relative global warming potential of these MVAC refrigerants and
whether or not they are ozone depleting. Today, there are cars on the road that use CFC-12, HFC-
134a, and HFO-1234yf. It is important for motor vehicle technicians to know how to safely handle
these refrigerants and others approved under the SNAP program.

C02 (R-744)


                                          Page 1

Summary of Activities
Many tribes manage vehicle fleets that serve their communities in a variety of capacities and are
serviced locally by tribal technicians. EPA partnered with tribal fleet programs that hosted, and
recruited technicians to participate in, training sessions offered by an EPA-approved Section 609
technician training and certification program.1 In 2013, EPA supported two sessions with
technicians from eight tribes. The participating tribes were the Karuk Tribe, the Morongo Band of
Mission Indians, the Navajo Nation, the Picayune  Rancheria of Chukchansi Indians, the Soboba
Band of Luiseno Indians, the Tachi Yokut Tribe (Santa Rosa Indian Community), the Viejas Band of
Kumeyaay Indians, and the Yavapai-Apache Nation.

The two sessions trained approximately 60 tribal  fleet technicians. The session held in February
was hosted by the Morongo Band of Mission  Indians and trained technicians from  their tribal fleet
service center as  well as fleet technicians from other nearby tribes in California  and Arizona. The
second session held in April trained technicians from five service centers across the Navajo Nation.
Eight tribes with a total of 12 fleet service centers participated in the training sessions.

Figure 1 shows the locations of tribes that
participated in the training sessions. The
Navajo Nation, located in Arizona,  New
Mexico, and Utah is the largest participating
tribe, with  a population of approximately
274,000 tribal members and  46 tribal fleet
technicians.111 The other participating tribes
are considerably smaller with populations
between approximately 200 and
3,400 members.111'1" These tribes are located
in California, with the exception of the
Yavapai-Apache Nation, which is in Arizona.

Each training session included several  hours
of classroom instruction by an EPA-approved
technician training and certification
program. The EPA-approved  program
provided the instruction and administered
the exam using their training materials. All
Section 609 certification programs  must
cover a standard set of topics, including the
environmental benefits of reducing emissions
of refrigerants with high global warming
potential and proper use of refrigerant
recovery equipment. Supplemental
information on new alternative refrigerants
HFC-152a, HFO-1234yf, and C02, was also
included for these sessions. At the end of the
instruction  period, the technicians
Figure 1. Location of participating tribes.
1. Training was provided by the Mobile Air Conditioning Society (MACS) Worldwide.
                                           Page 2

        Figure 2. Navajo technicians taking the
        Section 609 certification exam in Window
        Rock, Arizona on April 29, 2013.
completed a closed-book, multiple-choice exam to
earn certification (Figure 2). All technicians that
took the exam passed and obtained certification.


Eight follow-up telephone interviews were
conducted with participants from five tribes to
better understand the experience of the
technicians, characteristics of the fleets they
service, current MVAC servicing practices, and
benefits gained from the training session. This
section summarizes that information. The
observations and conclusions of the case study are
only representative of technicians from a subset of the tribal fleet service centers for which
training was provided, based on information collected during the follow-up interviews.

Technician Characteristics

The technicians had automotive repair experience ranging from  18 months to more than 30 years.
The average experience of the technicians represented in this case study was just over 17 years.
Most of these individuals had formal automotive repair education,  training, or certification.
Several relied on experiential learning.  Most of the technicians had previously earned Section 609
certification. The newly certified technicians indicated several reasons for not obtaining their
certification earlier, including a lack of opportunity to attend training and misunderstanding of

The technicians reported that about one-half of their colleagues had previously earned
Section 609 certification before participating in the current training sessions supported by EPA.
Many technicians opted to retake the certification exam to earn a  new certification card
(e.g., some technicians had misplaced their cards and did not recall the issuing certification
program to request replacements), to demonstrate their understanding of the training material, or
because it was requested by their manager.

The technicians also reported that some of their colleagues did not have Section 609 certification
and did not attend the training session. Reasons for this include  scheduling conflicts, difficulty
learning in a classroom setting or completing an exam, an impression that training would not be
useful, or a sense that they already know the information and do not need additional training.

Fleet Program Characteristics

The technicians provided the number, types, and age of vehicles in their fleets and described
their service centers' resources.  Fleet characteristics are important to help determine the
environmental benefits of proper servicing practices for two reasons: (1) different types of
vehicles contain different amounts of refrigerant, with buses containing the most and cars the
least and  (2) model year 1994 and older vehicles  may contain CFC-12. Model year 1995 and newer
MVAC systems contain HFC-134a; in the future MVAC systems may contain other alternative
Page 3

Across the tribal fleets included in this case study, there are approximately 2,200 vehicles. About
64% were identified as light-duty vehicles, including cars, sport utility vehicles, and pick-up
trucks; about 21% were classified as heavy-duty vehicles, including large trucks and utility vehicles
such as those used for road work or trash collection; and about 15% were classified as buses
(Figure 3). Less than 1% of the fleet vehicles were model year 1994 or older.
                                               VEHICLE TYPE   COMPOSITION OF FLEETS"
                                              | LIGHT-DUTY




                                              Values rounded.
                Figure 3. Approximate composition of fleets.
The size and composition of the individual tribal fleets in this case study vary widely. The size of
the fleets ranges from 15 to about 800 vehicles. Table 2 demonstrates the variation in fleet
composition by vehicle type, listing the percentage of light-duty vehicles, heavy-duty vehicles,
and buses for each of the tribal service centers that are represented in the case study.

            Table 2. Fleet vehicle compositions reported
                                               Service center
Vehicle type
The fleet vehicles are used for a wide range of purposes. The technicians said that they worked on
emergency response vehicles (e.g., police cruisers, fire trucks, ambulances), school and Head
Start buses or vans, utility and maintenance vehicles, casino vehicles, and other social service
vehicles, such as those used to transport the elderly.

Available fleet maintenance resources vary by tribe.  Many of the tribes have refrigerant recovery
and recycling equipment.  Those without service equipment must send their vehicles offsite for
refrigerant recovery. Many tribes lack newer service  equipment  models. Figure 4 displays two of
the recovery and recycling machines being used by tribes in the  case study. Only some of the
fleets have access to leak detectors and refrigerant identifiers. Notably, the number of
technicians per vehicle served at  each fleet  service center varies considerably, with some
technicians individually responsible for up to several hundred vehicles.
                                           Page 4

                     Figure 4. Examples of older (left) and newer (right)
                     models of recovery and  recycling machines among
                     participating tribes.
MVAC Servicing Practices

The tribes' approaches to servicing their fleets vary. Most technicians inspect and repair systems
when there is a customer complaint. Others check systems on a regular schedule, but only
perform refrigerant recovery, recycling, and recharging if a system is damaged or not working
properly. A few technicians indicated a higher rate of servicing.

On average across the United States, MVAC systems in cars or light-duty vehicles are serviced once
every six years/ It appears the rate at which some  tribal fleet technicians service vehicles is
higher than average. However, there is reason to believe that tribal fleet vehicles require
servicing more frequently than other vehicles. Systems are frequently damaged due to wear from
driving on unpaved roads. Fleet vehicles may also experience more wear than non-fleet  vehicles
because of the greater number of miles they drive each year. Fleet vehicles, such as buses, may
need to be serviced more regularly to meet customer or management demands. Buses may also
require more frequent servicing than cars because buses have longer refrigerant lines that are
more prone to leaks.""There are additional factors that could increase the frequency with which
MVAC systems are serviced in tribal fleets. Based on the fleet composition and an assumed MVAC
servicing schedule of once every six years for light - duty and heavy-duty vehicles, and once every
three years for buses, EPA expects that across all fleets that participated in this case study, each
year these tribal fleet technicians will service about 230 light-duty vehicles, 80 heavy-duty
vehicles, and 110 buses.V>V1 It is  expected that about half of all servicing conducted by these fleet
technicians each year will be on light-duty vehicles.

Participants provided information about service practices in their service centers. None  of the
technicians identified serious lapses in servicing practices, such as the intentional releasing or
venting of refrigerant.
                                           Page 5

Environmental Benefits
The environmental benefits gained from properly servicing MVAC systems result from reductions in
emissions of greenhouse gases. HFC-134a, the most common MVAC refrigerant, does not deplete
the ozone layer, but is a potent greenhouse gas with a global warming potential of 1,430, as
indicated in Table 1.

The technicians in this case study cumulatively service hundreds of vehicles each year,  all using
HFC-134a. Using conservative estimates of MVAC system charge size and frequency of servicing,
these technicians will handle a minimum of 0.8 metric tons of HFC-134a annually, with  an
associated global warming potential of over 1,155 metric tons C02-equivalent. To put this in
perspective, proper servicing of these MVAC systems has the potential to avoid greenhouse gas
emissions equivalent in magnitude to those resulting from electricity used by 159 U.S. homes in
one year.

Properly handling refrigerants is vital to reducing harm to the environment. Section 609 training
provides information for MVAC technicians on how to handle refrigerant properly to avoid
intentional venting of refrigerant. Best  practices learned by technicians through Section 609
certification can improve refrigerant handling, MVAC system inspection, maintenance, and repair,
and ultimately minimize the unintentional venting of refrigerant.

Training Benefits Identified by Technicians

About one-half of the technicians who participated  in the training sessions were already Section
609 certified, and many of the uncertified technicians seemed to be familiar with proper  MVAC
servicing practices.  For example, none of technicians that participated in the case study indicated
that the venting of refrigerant occurs in their fleet  service centers. The technicians reported that
they and their colleagues use approved  refrigerant  recovery,  recycling, and recharge equipment,
or send their vehicles offsite to be serviced by a facility with  approved equipment.

Technicians stated that they gained new knowledge and an understanding of best practices  from
the EPA training sessions. More specifically, the technicians indicated that they learned the
following information during the  training sessions:

       Technicians must be certified to work on HFC-134a systems (some had been told that
       certification was only required for CFC-12 systems)
       It is important to check for cross-contamination in systems before servicing by using a
       refrigerant identifier
       How to properly maintain recovery equipment
       Best practices to use when servicing systems, including conducting a visual inspection of
       system hoses and components before servicing, and using a heat gun
       Personal safety practices to use when servicing systems (e.g., wearing safety glasses)
       How to verify if a refrigerant canister is empty
       Recovery machines must be registered with  EPA regional offices
       More sensitive leak detection equipment is now available
       New refrigerants are being introduced.
                                          Page 6

Conclusions and Next Steps
With funding provided from EPA's Tribal Program, EPA sponsored training for approximately
60 tribal fleet vehicle technicians on how to properly service MVAC systems and limit harmful
refrigerant emissions. Through two training sessions, all participating technicians received Section
609 certification, about half of which were new certifications. Some of these technicians may
have previously serviced MVAC systems without certification and others had sent vehicles offsite
for servicing due to a lack of certification. These technicians can now perform MVAC servicing in-
house, after obtaining approved MVAC refrigerant recovery equipment. The conclusions of this
case study are the following:

       More training is needed. These sessions reached a relatively small number of tribal fleet
       technicians and work is needed to identify technicians who require Section 609
       certification. Tribal technicians in rural areas or other regions may have limited access to
       Section 609 certification opportunities. Currently certified technicians can also benefit
       from access to updated training content. Figure 5 displays tribal lands across the
       Continental United States. With 566 recognized tribes and roughly 2 million tribal members
       in  the United States, there are many more outreach opportunities.111' Training will help
       ensure proper servicing of MVAC systems and minimize unintentional refrigerant release
       during MVAC servicing. Ongoing outreach could also dispel technicians' misconceptions
       about Section 609 requirements, such as the perception that certification is only required
       for CFC-12 systems.
                0 50100 200
            Figure 5. Tribal lands in the Continental United States.

       Technicians want to know about recently listed alternatives. A beneficial portion of the
       training was the supplemental information on newer alternative refrigerants HFC-152a,
       HFO-1234yf, and C02. Even though these newer refrigerants are not widely used today, the
       technicians found value in knowing what refrigerant technologies they may service in the
       near future.

       Servicing procedures addressed in Section 609 training are becoming an industry
       standard. Uncertified technicians appeared familiar with proper servicing practices. This
       might indicate the pervasiveness and success of the Section 609 training requirement since
       its introduction in the early 1990s. However, continued training ensures that new
       technicians learn the Section  609  requirements and best servicing practices, and become

       Fleet vehicle servicing frequencies might be higher than average. In some cases MVAC
       refrigerant recovery frequencies were higher than expected. The reason for this is not
       clear, and could be attributable to several factors, including general wear on fleet
       vehicles, system damage from vehicle miles on unpaved roads,  or greater demand for
       MVAC system functionality in  fleet vehicles.

Based on the findings of this case study, potential next steps could include outreach to additional
tribal communities to provide training opportunities,  information on the importance of
certification, information on new alternative refrigerants, and details on how to get trained by an
EPA-approved technician training and certification program. Hands-on training could be valuable
as an addition to Section 609 certification training programs.  Lastly, many tribal fleet programs
could benefit from access to newer recovery machines, leak detectors, and refrigerant identifiers.
To respond to the need for additional information on  the new alternative refrigerants, EPA
recently published the brochure New Climate-Friendly Motor Vehicle Air Conditioning

By partnering with the Morongo Band of Mission Indians and the Navajo Nation, EPA was able to
help facilitate training for approximately 60 MVAC technicians servicing tribal fleet vehicles. EPA
was also able to identify areas where additional efforts could help bridge gaps in information.
                                          Page 8

Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R. Belts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe,
G. Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz, and R. Van Dorland. 2007. Changes in Atmospheric
Constituents and in Radiative Forcing. Climate Change 2007: The Physical Science Basis.  Contribution of
Working Group I to the Fourth Assessment Report of the  Intergovernmental Panel on Climate Change, S.
Solomon, D. Qin, M.  Manning, Z. Chen, M. Marquis, K.B.  Averyt, M. Tignor and H.L. Miller (eds.). Cambridge
University Press, Cambridge, United Kingdom and New York, NY,  USA.
Nielsen, O.J., M.S. Javadi, M.P. Sulbaek Andersen, M.D.  Hurley, T.J. Wellington, and R. Singh. 2007.
Atmospheric chemistry of CF3CF = CH2: Kinetics and mechanisms of gas-phase reactions with Cl atoms, OH
radicals, and O3. Chemical Physics Letters 439:18-22. Available:
http://www.cogd'.dk/network/OJN_174_CF3CF=CH2.pdf. Accessed December 18, 2013.
Bureau of Indian Affairs. 2005. 2005 American Indian Population and Labor Force Report. United States
Department of the Interior Bureau of Indian Affairs, Office of Indian Services. Available:
http://www.bia.gov/cs/groups/public/documents/text/idc-001719.pdf. Accessed August 20, 2013.
Viejas Band of Kumeyaay Indians and Manzanita  Band of Kumeyaay Indians. 2007. Imperial County Board
Recognizes Viejas and Manzanita Tribes for Continuous Civic Support. November 6. Available:
http://www.vieiasbandofkumevaav.org/pdfs/11062007.pdf. Accessed August 20, 2013.
Jetter, J., R. Forte,  and F. Delafield. 2001. Refrigerant concentrations in motor vehicle passenger
compartments. American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE)
Schwartz, W. 2007. Establishment of Leakage Rates of Mobile Air Conditioners in Heavy Duty Vehicles:
Part 2 Buses and Coaches. European Commission. January.
Bureau of Indian Affairs. 2012. Indian entities recognized and eligible to receive services from the Bureau of
Indian Affairs. Federal Register 77(155):47868.
National Atlas of the United States.  2005. Map Layer Info. Indian  Lands of the United States. Available:
http://www.nationalatlas.gov/mld/indlanp.html. Accessed August 21, 2013.
                                                 Page 9

             Learn More about Clean Air Act Section 609
                 and How to Become 609 Certified


               EPA Ozone Layer Protection Website
                          January 2014
                            United States
                            Environmental Protection
Disclaimer: EPA does not endorse any particular company or its products.