5.4 Refrigerant Sales Restrictions and Recordkeeping
Key Takeaways
- Refrigerant can only be sold to certified technicians, their employers, or certified reclaimers
- Sellers must verify buyer certification and keep records for 3 years
- Technicians must keep certification records until 3 years after leaving the trade
- A chronically leaking appliance has lost 125%+ of its charge in 12 months
- Leak repairs must be completed within 30 days of discovery
5.4 Refrigerant Sales Restrictions and Recordkeeping
EPA Section 608 imposes specific restrictions on who can buy regulated refrigerants and requires detailed recordkeeping from both buyers and sellers.
Refrigerant Sales Restrictions
As of January 1, 2018, the purchase of regulated refrigerants (CFCs, HCFCs, HFCs, and HFC blends) in any quantity — including containers of any size — is restricted:
Who can purchase refrigerant:
- Section 608 certified technicians (Type I, II, III, or Universal)
- Companies that employ at least one certified technician
- EPA-certified reclaimers
Seller responsibilities:
- Verify that the buyer is either a certified technician or employs one
- Keep records of: purchaser name, date of sale, quantity of refrigerant purchased
- Maintain these records for 3 years from the date of sale
- Certification can be verified by requesting a copy of the technician's certification card or certificate
Technician Certification Records
Certified technicians must:
- Keep a copy of their certification at their place of business
- Maintain this record until 3 years after they are no longer working as a technician
- Make their certification available for inspection by EPA upon request
Disposal and End-of-Life Records
For appliances containing 5-50 lbs of refrigerant being disposed of:
- The technician must keep records of the disposal
- Records include: date, type and quantity of refrigerant recovered, and disposition of the refrigerant
- Records must be maintained for 3 years
For appliances containing 50+ lbs of refrigerant:
- Equipment owners must maintain records of all refrigerant additions (including date and quantity)
- Records of leak detection and repair activities
- Maintenance history for all servicing events that involve refrigerant
- Records must be maintained for 3 years
Leak Reporting for Large Systems
For appliances with a full charge of 50 or more pounds of ODS refrigerant:
- Owners must repair leaks within 30 days of discovery when the leak rate exceeds the applicable trigger rate
- Must conduct a follow-up verification test within 30 days of the repair
- If repair is not feasible within 30 days, must develop a retrofit/retirement plan within 30 days and complete it within 1 year (or 18 months in some cases)
Chronically Leaking Appliances
A chronically leaking appliance is one that has leaked 125% or more of its total charge in a 12-month period:
- These systems require special attention and may need to be retired or retrofitted
- The 30-day repair timeline is mandatory
- If not repaired, the owner must develop and execute a plan to retrofit or dispose of the equipment
For the Exam: Refrigerant can only be sold to certified technicians or their employers. Sellers must keep records for 3 years. The 3-year recordkeeping requirement applies to sales, certification, and disposal records. A chronically leaking appliance has leaked 125% or more of its charge in 12 months.
How long must refrigerant sales records be maintained?
Who can legally purchase regulated refrigerants?
What defines a "chronically leaking" appliance under EPA regulations?