The EPA's Updated Refrigerant Management
Requirements
What Supermarkets and Property and Facility
Managers Need to Know
What are the Section 608 regulations?
Section 608 of the Clean Air Act prohibits the knowing release of refrigerant during the maintenance, service,
repair, or disposal of air-conditioning and refrigeration equipment. The EPA requires proper refrigerant
management practices by owners and operators of refrigeration and air-conditioning systems, technicians, and
others.
What's changing in these regulations?
In the fall of 2016, the EPA updated the existing requirements related to ozon
depleting substances (ODS), such as CFCs and HCFCs, and extended them to
substitutes such as MFCs.1 The updates include:
•	More stringent requirements for repairing leaks in larger appliances;
•	New recordkeeping for the disposal of appliances containing five to 50
pounds of refrigerant;
•	New reporting requirement that kicks in when larger appliances leak
125% or more of their charge in a calendar year;
•	Restricting the sale of HFC refrigerant to technicians certified under
Sections 608 or 609 of the Clean Air Act; and
•	Changes to improve readability and simplify compliance.
How will the new requirements affect supermarkets and property and facility managers?
This fact sheet summarizes both the existing leak repair requirements and the revised requirements that will
take effect January 1, 2019.2
Affected Appliances
The leak repair regulations apply to industrial process refrigeration (IPR), commercial refrigeration, and
comfort cooling appliances containing 50 pounds or more of ODS or substitute refrigerant.
Leak Rate Calculations
Owners/operators must calculate the leak rate every time ODS or substitute refrigerant is added to an
appliance (unless the addition is made immediately following a retrofit, installation of a new appliance, or
qualifies as a seasonal variance).
Appliance Repairs
•	Owners/operators must identify and repair leaks that exceed 30% for IPR, 20% for commercial
refrigeration, and 10% for comfort cooling within 30 days of when the ODS or substitute refrigerant is
added. Leaks must be repaired such that the leak rate is brought below the applicable leak rate.
In addition to protecting
the ozone layer, the
EPA estimates that the
updated requirements
will decrease annual
greenhouse gas
emissions by
7.3 million MTCCtee—
that's equivalent to
taking 1.5 million cars
off the road per year.
1	These regulations do not extend to substitutes that have been exempted from the venting prohibition, such as ammonia.
2	This fact sheet highlights select changes that may be of most interest to this community. Please see the regulations for the full
changes/requirements.

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•	Owners/operators of all three appliance types must perform and document both an initial and follow-up
verification test of leak repairs, for appliances that exceed the applicable leak rate.
o An initial verification test must be performed before any additional refrigerant is added to
the appliance.
o A follow-up verification test must be performed only after the appliance has returned to
normal operating characteristics and conditions. There is no minimum timeframe.
•	The verification tests must demonstrate that leaks were successfully repaired. If either the initial or
follow-up verification test indicates that repairs were not successful, owners/operators may conduct as
many additional repairs and verification tests as needed within the 30 day repair period.
•	Owners/operators of IPR, commercial refrigeration, and comfort cooling equipment may request limited
extensions to the 30 day (120 days if an industrial process shutdown is required) repair deadline.
•	If owners/operators fail to bring the leak rate below the threshold leak rate, owners/operators must
create and implement a retrofit or retirement plan.
Leak Inspections
•	Owners/operators must conduct leak inspections for appliances that have exceeded the applicable leak
rate, according to the schedule in Table 1. Leak inspections must be conducted by a certified
technician. All visible and accessible components of an appliance must be inspected.
Table 1: Leak Inspection Requirements
Frequency of Leak Inspections
Once every three months until the owner/operator can demonstrate through leak
rate calculations that the leak rate has not exceeded 20% (commercial
refrigeration) or 30% (IPR) for four quarters in a row.
Once per calendar year until the owner/operator can demonstrate through the
leak rate calculations that the leak rate has not exceeded 20% (commercial
refrigeration) or 30% (IPR) for one year.
Once per calendar year until the owner/operator can demonstrate through the
leak rate calculations that the leak rate has not exceeded 10% for one year.
•	Quarterly or annual leak inspections are not required on appliances (or portions of appliances) that are
continuously monitored by an automatic leak detection system that is audited and calibrated annually.
Retrofit or Retirement Plans
•	Owners/operators must create a retrofit or retirement plan within 30 days3 of an appliance leaking ODS
or substitute refrigerant above the applicable leak rate if:
o The owner/operator intends to retrofit or retire rather than repair the leak; or
o The owner/operator fails to identify and repair the leak; or
o The appliance continues to leak above the applicable leak rate after required repairs and
verification tests.
•	Retrofit or retirement plans must contain: identification and location of the appliance; type and full
charge of the refrigerant in use; type and full charge of alternative refrigerant (if retrofitting); itemized
procedure for converting the appliance to a different refrigerant, including changes required for
compatibility with the new refrigerant (if retrofitting); plan for disposition of recovered refrigerant; plan
for disposition of the appliance (if retiring); and a schedule for completion within one year.
Equipment	Full Charge
Commercial	> 500
Refrigeration	pounds
and
Industrial
Process	50 to 500
Refrigeration	pounds
Comfort	50 or more
Cooling	pounds
3 Some extensions may be available, particularly for industrial process refrigeration.

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•	The retrofit or retirement must be completed within one year of the plan's date unless granted extra
time.
•	Owners/operators must repair all identified leaks as part of any retrofit.
•	Owners/operators may request relief from the obligation to retrofit or retire an appliance if they can
establish within 180 days of the plan's date that the appliance no longer exceeds the applicable leak
rate and agrees in writing to repair all identified leaks within one year of the plan's date.
Chronically Leaking Appliances
• Owners/operators must submit reports to the EPA if any appliance leaks 125% or more of its full
charge in one calendar year. This report must describe efforts to identify leaks and repair the
appliance.
Recordkeeping and Reporting Requirements
Owners/operators must maintain hard or electronic copies4 of:
•	Records documenting the full charge of appliances.
•	Records, such as invoices, showing when service or
maintenance is performed, when refrigerant is added to an
appliance (or removed, in the case of disposal), when a leak
inspection is performed, and when a verification test is
conducted.
•	If using an automatic leak detection system, documentation
that the system is installed and calibrated annually and
records of when the monitoring system identifies a leak and
the location of the leak.
•	Retrofit and/or retirement plans.
•	Requests submitted to the EPA to extend the repair or retrofit
deadlines.
•	If a system is mothballed to suspend a deadline, maintain records documenting when the system was
mothballed and when it was brought back on-line (i.e., when refrigerant was added back into the
appliance).
•	Records to demonstrate a seasonal variance.
•	Reports on appliances that leak 125% or more of the full charge in a calendar year.
Reporting to the EPA
All notifications must be submitted
electronically to 608reports@epa.gov.
If the notification contains confidential
business information, the information
should be submitted to:
Section 608 Program Manager
Stratospheric Protection Division
Mail Code: 620ST"
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Additional Resources
Update to the Refrigerant Management Requirements Final Rule:
www.epa.aov/section608/revised-section-608-refriaerant-manaaement-reaulations
The EPA's Section 608 Webpage: www.epa.aov/section608
The EPA Stratospheric Ozone Contact: spdcomment@epa.aov
Printed on 100% recycled/recyclable paper with a minimum	0ffice of Air and
1L3	a.	a. ¦	a. ui u j ¦ i	EPA-430-F-16-066
50% post-consumer waste using vegetable-based inks.	September 2016
4 The EPA encourages electronic recordkeeping.

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