Refrigerants are regulated as hazardous materials by the US EPA and CARB, due to their ozone depleting ability and powerful greenhouse gas potential. Applicable regulations include:
- The Clean Air Act (Section 608) – US EPA
- The Regulation for the Management of High Global Warming Potential Refrigerants for Stationary Sources – CARB
Refrigerants are often persistent in the environment, making their impact longer lasting than those compounds that degrade quickly.
Use of refrigerants and maintenance and repair of refrigerant containing equipment has specific program requirements.
EPA-approved certification testing is required for any person who may perform service, maintenance, repair, or recovery work on refrigerant containing equipment. UCSF engineers and contractors may service only that equipment for which they are certified. Copies of certifications must be submitted to the chief engineer or UCSF Environmental Programs prior to the start of work.
Each UCSF department working with refrigerants and refrigerant containing equipment is required to keep the following documentation:
- List of current employees performing service or purchasing refrigerants
- List of employees actually performing the work on covered equipment
- List of equipment with a charge > 50 lbs
- Location
- Function
- Manufacturer
- Model Number
- Refrigerant Used in the unit
- Full charge of the unit
- All records concerning any maintenance or service (including date, name of the service tech, amount of refrigerant added / removed)
- Maintenance / inspection records
- A certification statement signed and sent to EPA
- A list of outside contractors performing work on any covered equipment
- Leak rate calculations
- Purchasing logs / invoices
- Inventory of current refrigerant supplies
- Reclamation records
In addition to the above requirements, CARB also requires the registration and routine leak detection requirements for all refrigerant containing equipment on the following schedule:
Refrigerant Charge
>2000 lbs
Registration Deadline
Jan 1, 2012
Leak Detection Requirements
- inspect monthly starting Jan 1, 2011
- install automatic leak detection Jan 1, 2012 if enclosed in a building
- Inspect every 3 months if not enclosed in a building
- Inspect each time additional refrigerant is added to the system starting Jan 1, 2011
>200 lbs
March 1, 2014
- Inspect every 3 months starting Jan 1, 2011
- Inspect each time additional refrigerant is added
>50 lbs
March 1, 2016
- Inspect every year starting Jan 1, 2011
- Inspect each time additional refrigerant is added
For federally regulated ozone depleting refrigerants follow this flow chart.
For state regulated ozone depleting refrigerants follow this flow chart.
Beginning in 2012, CARB will also require annual reports for specific pieces of equipment. The annual reports are to be submitted on the following schedule:
Refrigerant Charge
Leak Detection Requirements
>2000 lbs - Large
Starting March 1, 2012, and every year afterwards for all equipment >50lbs
>200 lbs - Medium
Starting March 1, 2014, and every year afterwards for all equipment >50lbs
>50 lbs - Small
Annual reports only required if your group is a Large or Medium. Documentation is required to be kept on site and presented at the request of an inspector even if annual reports are not required.
Contact UCSF Environmental Programs if you require further information or have questions regarding the Refrigerant Program.