3.3 Recordkeeping & Leak Repair Requirements

Section 608 recordkeeping exists so that the Environmental Protection Agency (EPA) and state inspectors can verify that refrigerant recovery, recycling, reclamation, and disposal actually happened the way a technician says it did. This section covers those recordkeeping duties, plus the related leak-repair rules that trigger some of the most frequently tested numbers on the Core exam.

Recordkeeping Requirements

The baseline rule is retention: records must be kept for three years. Records may be kept in whatever format is most convenient — paper logs and electronic records are equally acceptable, as long as they remain retrievable if requested by an inspector.

Disposal Recordkeeping for Appliances Holding 5-50 Pounds

A specific recordkeeping duty applies when an appliance with a full charge between 5 and 50 pounds is disposed of. For each disposed appliance, the technician or disposer must record:

• The location where the appliance was disposed of
• The date refrigerant was recovered
• The type of refrigerant recovered

In addition to this per-appliance record, the technician or disposer must keep a monthly total of refrigerant recovered, broken out by refrigerant type, across all appliances disposed of that month. If the recovered refrigerant is transferred elsewhere for reclamation or destruction, the technician must also record details of that transfer — specifically the name of the recipient and the date of the transfer.

Why the Disposal Record Has Two Layers

Notice that the disposal recordkeeping duty actually has two layers, and the exam tests both. The first layer is the per-appliance record — location, date, and refrigerant type for each individual disposed appliance. The second layer is the monthly summary — a running total of refrigerant recovered by type across every appliance disposed of that month. A technician who only logs individual appliances but never rolls those entries up into a monthly total by refrigerant type has not fully satisfied the recordkeeping duty, and the same is true in reverse: a monthly total alone, without the underlying per-appliance detail, would not let an inspector verify any single disposal event.

Leak Repair Requirements

Separate from disposal recordkeeping, Section 608's service-practice rules (40 CFR Part 82, Subpart F) impose leak-rate repair thresholds on appliances holding 50 pounds or more of an ozone-depleting refrigerant — a chlorofluorocarbon (CFC) such as R-12, or a hydrochlorofluorocarbon (HCFC) such as R-22. If such an appliance's annual leak rate exceeds the applicable threshold, the owner or operator must repair the leak:

Owners and operators of appliances holding 50 pounds or more of refrigerant that leak 125% or more of their full charge in a calendar year are considered chronically leaking and must report the appliance to EPA.

Worked Example: The 125% Chronic-Leaker Threshold

The 125% figure is easy to misread as "leaking all of the refrigerant plus a little more," but it is better understood as a cumulative annual total that can exceed the appliance's full charge because refrigerant is repeatedly added back in over the course of the year. Consider an industrial process refrigeration system with a 100-pound full charge. If, over the course of a calendar year, the owner has to add a cumulative total of 130 pounds of refrigerant to keep the system running — because it keeps leaking and getting topped off — that 130 pounds represents 130% of the appliance's full charge. Since 130% exceeds the 125% chronic-leaker trigger, the owner must report that appliance to EPA as chronically leaking, in addition to whatever repair obligation is triggered by the 30% industrial-process leak-rate threshold discussed above.

The 2020 Rule: Substitutes Were Rescinded From These Duties

An EPA rule effective April 10, 2020 rescinded the leak-repair, periodic-inspection, and EPA-reporting duties described above specifically for substitute (non-ozone-depleting) refrigerants — refrigerants such as hydrofluorocarbons (HFCs) that do not deplete the ozone layer. As a result, today the classic 10%/20%/30% leak-repair triggers, the periodic-inspection duty, and the chronic-leaker reporting duty apply squarely to ODS refrigerants (CFCs and HCFCs) at the 50-pound threshold. This is a frequently tested distinction: not every refrigerant leak triggers a Subpart F repair duty — it depends on whether the refrigerant in the appliance is ozone-depleting. Two rules that continue to apply broadly, regardless of refrigerant type, are the evacuation (vacuum) standards for servicing equipment and the prohibition on venting refrigerant to the atmosphere.

A Newer, Separate Program: The 2024 AIM Act HFC Rule

Technicians should also be aware of a distinct, newer regulatory program layered on top of classic Section 608: an EPA rule issued under the American Innovation and Manufacturing (AIM) Act, signed September 20, 2024. This rule creates an Emissions Reduction and Reclamation (ER&R) program under 40 CFR Part 84 — a different part of the federal regulations from Section 608's Part 82 — that re-imposes leak-rate, repair, and recordkeeping duties similar to the classic Subpart F rules, but targeted specifically at HFC refrigerants and their substitutes. The AIM Act program uses a lower 15-pound charge threshold (rather than 50 pounds) and applies to refrigerants with a global warming potential (GWP) greater than 53, with compliance phased in through January 1, 2026.

It is important to keep the two programs straight for exam purposes: the classic Section 608 numbers — 50 pounds, 10%/20%/30%, 125%, and an ODS focus — remain the primary tested content on the Core exam. The AIM Act's ER&R program is a separate, newer layer of the regulatory landscape that a working technician should know exists alongside Section 608, not a replacement for the numbers above.