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
Last updated: March 2026

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 TypeRetention PeriodWho Keeps It
Technician certificationUntil 3 years after leaving the tradeTechnician
Refrigerant purchase records3 years from date of saleSeller
Disposal recovery records3 yearsTechnician / disposal entity
Leak repair records3 yearsEquipment owner
Refrigerant addition records (50+ lbs)3 yearsEquipment owner
Reclamation recordsTransactional basisCertified reclaimer

2026 Regulatory Landscape Summary

As of 2026, the regulatory landscape includes overlapping requirements from multiple sources:

RegulationWhat It CoversKey Requirements
Clean Air Act Section 608All stationary refrigeration/ACVenting prohibition, certification, recovery, sales restrictions
AIM Act (2020)HFC managementPhasedown schedule, GWP limits, technology transitions
2026 HFC Leak RuleHFC systems ≥15 lbsLeak detection, repair triggers, recordkeeping
SNAP ProgramRefrigerant acceptabilityWhich substitutes are approved for each application
Montreal Protocol / KigaliInternational obligationsCFC/HCFC phaseout, HFC phasedown
DOT RegulationsRefrigerant transportCylinder requirements, shipping classification
OSHAWorker safetyExposure limits, PPE, confined space
State/Local codesAdditional requirementsMay be more stringent than federal

Common Exam Mistakes to Avoid

  1. Confusing "phaseout" with "phasedown" — CFCs/HCFCs are phased OUT (eliminated); HFCs are phased DOWN (reduced, not eliminated)
  2. Forgetting that certification never expires — EPA 608 certification is good for life
  3. Mixing up recovery percentages — 90% (compressor running) vs. 80% (not running) for small appliances
  4. Confusing recycled vs. reclaimed — recycled stays with same owner; reclaimed can be sold
  5. Getting pressure units wrong — know the difference between psig, psia, in. Hg vacuum, and mm Hg absolute
  6. Forgetting November 15, 1993 — the key date for equipment manufacturing and recovery standards
  7. 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.

Test Your Knowledge

EPA 608 technician certification is valid for:

A
B
C
D
Test Your Knowledge

What is the universal recordkeeping retention period for most EPA 608 compliance documents?

A
B
C
D
Test Your Knowledge

Which statement correctly describes the difference between CFC/HCFC regulations and HFC regulations?

A
B
C
D