10.3 Compliance Checklist and Best Practices
Key Takeaways
- EPA 608 certification never expires — valid for the lifetime of the technician
- 3 years is the standard recordkeeping retention period for all Section 608 documents
- Phaseout (CFCs/HCFCs eliminated) vs. phasedown (HFCs reduced to 15%)
- The 2026 regulatory landscape includes Clean Air Act, AIM Act, SNAP, DOT, OSHA, and state/local codes
- Key numbers: 80%/90%, 4" vacuum, 25 mm Hg, 15 psig, \$44,539/day, 125%, 3 years
10.3 Compliance Checklist and Best Practices
This section summarizes the key compliance requirements every EPA 608 certified technician should follow in their daily work. Use this as a practical reference.
Technician Compliance Checklist
Before Starting Any Refrigerant Work:
- Verify your EPA 608 certification covers the equipment type
- Identify the refrigerant in the system (nameplate, identifier)
- Ensure recovery/recycling equipment is certified and in good working order
- Have proper PPE available (safety glasses, gloves, at minimum)
- Have appropriate recovery cylinders (DOT-approved, not expired, not overfilled)
During Service:
- Recover refrigerant before opening any system
- Never vent any regulated refrigerant intentionally
- Use nitrogen (with regulator) for pressure testing — never oxygen or compressed air
- Change oil only at 5 psig or below
- Charge zeotropic blends as liquid only
- Never mix different refrigerants
After Service:
- Verify recovery to required evacuation levels
- Properly seal any access points created during service
- Update the equipment label if refrigerant type was changed
- Document all refrigerant additions and removals
- Properly store and label all recovery cylinders
For Equipment Disposal:
- Recover all refrigerant before any disposal activity
- Document the recovery (date, type, amount)
- Retain records for at least 3 years
Recordkeeping Summary
| Record Type | Retention Period | Who Keeps It |
|---|---|---|
| Technician certification | Until 3 years after leaving the trade | Technician |
| Refrigerant purchase records | 3 years from date of sale | Seller |
| Disposal recovery records | 3 years | Technician / disposal entity |
| Leak repair records | 3 years | Equipment owner |
| Refrigerant addition records (50+ lbs) | 3 years | Equipment owner |
| Reclamation records | Transactional basis | Certified reclaimer |
2026 Regulatory Landscape Summary
As of 2026, the regulatory landscape includes overlapping requirements from multiple sources:
| Regulation | What It Covers | Key Requirements |
|---|---|---|
| Clean Air Act Section 608 | All stationary refrigeration/AC | Venting prohibition, certification, recovery, sales restrictions |
| AIM Act (2020) | HFC management | Phasedown schedule, GWP limits, technology transitions |
| 2026 HFC Leak Rule | HFC systems ≥15 lbs | Leak detection, repair triggers, recordkeeping |
| SNAP Program | Refrigerant acceptability | Which substitutes are approved for each application |
| Montreal Protocol / Kigali | International obligations | CFC/HCFC phaseout, HFC phasedown |
| DOT Regulations | Refrigerant transport | Cylinder requirements, shipping classification |
| OSHA | Worker safety | Exposure limits, PPE, confined space |
| State/Local codes | Additional requirements | May be more stringent than federal |
Common Exam Mistakes to Avoid
- Confusing "phaseout" with "phasedown" — CFCs/HCFCs are phased OUT (eliminated); HFCs are phased DOWN (reduced, not eliminated)
- Forgetting that certification never expires — EPA 608 certification is good for life
- Mixing up recovery percentages — 90% (compressor running) vs. 80% (not running) for small appliances
- Confusing recycled vs. reclaimed — recycled stays with same owner; reclaimed can be sold
- Getting pressure units wrong — know the difference between psig, psia, in. Hg vacuum, and mm Hg absolute
- Forgetting November 15, 1993 — the key date for equipment manufacturing and recovery standards
- Mixing up leak rate triggers — 10% comfort, 20% commercial, 30% industrial
For the Exam: Three years is the universal recordkeeping requirement. Certification never expires. Know the difference between phaseout (CFC/HCFC) and phasedown (HFC). Remember all the key numbers: 80%/90%, 4-inch vacuum, 25 mm Hg, 15 psig rupture disc, $44,539 penalty, 125% chronic leak rate.
EPA 608 technician certification is valid for:
What is the universal recordkeeping retention period for most EPA 608 compliance documents?
Which statement correctly describes the difference between CFC/HCFC regulations and HFC regulations?