THE CLEAN AIR ACT 1990-SECTION 609
Our Threatened Ozone Layer
Remember that ozone is "good up high, bad nearby": even though it protects us when it is in the stratosphere, ozone at ground level can be harmful to breathe and is a prime ingredient in smog. Many man-made sources such as tailpipe emissions from vehicles contribute to ground-level ozone.
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Global Action to Protect the Ozone Layer
The United States has joined over 160 countries as a party to the international treaty known as the Montreal Protocol. All developed countries agreed to phase out production of most ozone-depleting substances, including CFC's, by the end of 1995. The 1990 Clean Air Act Amendments (the Act) incorporated this production ban date and directed the EPA to develop regulations to maximize recycling, ban nonessential uses, develop labeling requirements and examine safe alternatives for ozone-depleting substances.
Impact of Motor Vehicle Air Conditioners
One of the largest uses of CFC-12 in the U.S. is as a refrigerant in Motor Vehicle Air Conditioners (MVACs). Section 609 of the Act gives the EPA the authority to establish requirements to prevent the release of refrigerants during the servicing of MVACs and to require recycling of refrigerants. Widespread refrigerant recycling reduces the demand for virgin CFC-12 and thus extends the time that it will be available. The following sections describe the requirements of the law and its potential impact on the service industry.
Handling CFC-12
VENTING
Another section of the Clean Air Act, section 608, prohibits releasing CFC-12 into the atmosphere. The prohibition on venting CFC-12 has been in effect since 1992.
SECTION 609 REGULATORY HISTORY
The original regulation promulgated under section 609 was published in July 1992. That regulation established standards for equipment that recovers and recycles CFC-12 refrigerant from motor vehicle air conditioners, rules for training and testing technicians to handle this equipment, and record-keeping requirements for service facilities and for refrigerant retailers. A supplemental final rule published in May 1995 established a standard for equipment that recovers but does not recycle CFC-12, as well as training and testing technicians to handle this equipment.
APPROVED EQUIPMENT
Technicians repairing or servicing CFC-12 MVACs must use either recover/recycle or recover-only equipment approved by the EPA. Recover/recycle equipment cleans the refrigerant so that oil, air and moisture contaminants reach acceptably low levels. A list of approved recover/recycle and recover-only equipment is available from the EPA.
TECHNICIAN TRAINING AND CERTIFICATION
Technicians who repair or service CFC-12 motor vehicle air conditioners must be trained and certified by an EPA-approved organization. Training programs must include information on the proper use of equipment, the regulatory requirements, the importance of refrigerant recovery, and the effects of ozone depletion. To be certified, technicians must pass a test demonstrating their knowledge in these areas. A list of approved testing programs is available from the EPA.
RECORDKEEPING REQUIREMENTS
Service shops must certify to the EPA that they own approved CFC-12 equipment. If refrigerant is recovered and sent to a reclamation facility, the name and address of that facility must be kept on file.
SALES RESTRICTIONS
Section 609 has long prohibited the sale of small cans of ozone-depleting refrigerants to anyone other than a certified technician. The sale of any size container of CFC-12 to anyone other than certified technicians was prohibited under section 608 of the Act beginning on November 14, 1994. This provision is intended to discourage "do-it-yourselfers" who recharge their own air conditioners. Such individuals often release refrigerant because they typically do not have access to recovery/recycling equipment. The EPA encourages "do-it-yourselfers" to bring their vehicles to certified technicians who can properly fix air conditioners using approved equipment. This avoids damage to A/C equipment by improper charging and helps to protect the environment.
| Fig. 2: Common recovery machine used on R-134a systems |
Handling HFC-134a Refrigerant
VENTING
Section 608 of the Clean Air Act prohibits releasing HFC-134a into the atmosphere. The prohibition on venting HFC-134a has been in effect since November 1995.
SECTION 609 REGULATORY HISTORY
In March 1996, the EPA proposed a rule to require recycling of HFC-134a. The rule proposed standards for recover-only and recover/recycle equipment and rules for training and testing technicians to handle this equipment.
APPROVED EQUIPMENT
Because of the venting prohibition described above, technicians who repair or service HFC-134a MVACs must recover the refrigerant. Any equipment may be used to recover the refrigerant, since equipment standards will not be in place until the effective date of the final rule. Technicians are not required to recycle HFC-134a refrigerant until the effective date of the final rule. At that time, technicians handling HFC-134a will have to either recycle the used HFC-134a refrigerant on-site, or send it to an off-site reclamation facility to be purified to ARI Standard 700, before it can be used to recharge A/C equipment.
After the effective date of the rule, the EPA will make available a list of approved recover/recycle and recover-only HFC-134a equipment.
CONVERTING CFC-12 EQUIPMENT FOR USE WITH HFC-134A
EPA regulations prohibit technicians from changing fittings on the same unit back and forth so that the unit is used for CFC-12 in the morning, HFC-134a in the afternoon, then back to CFC-12 again, etc.
EPA regulations specify that when equipment is converted for use with a new refrigerant, the converted unit must be able to meet the applicable equipment standard set forth in the regulations. CFC-12 equipment may be permanently converted for use with HFC-134a under certain conditions. The EPA intends to issue regulations placing certain restrictions on these retrofits in the future. Those restrictions may require that the manufacturer's service representative rather than the automotive service technician perform the retrofit, that a unit may only be retrofitted if retrofit procedures have been certified by an independent testing laboratory such as Underwriters Laboratories, and that an appropriate label is affixed to the unit. In addition, the retrofitted unit must meet the technical specifications of SAE standard J2210 and must have the capacity to purify used refrigerant to SAE standard J2099 for safe and direct return to the air conditioner following repairs.
In the absence of any EPA regulations, a service facility may perform such a retrofit, or may have the equipment manufacturer's service representative perform the retrofit, as long as the fittings are changed in accordance with the EPA's Significant New Alternative Policy (SNAP) program regulations. The Agency cautions technicians, however, that although recovering a given refrigerant using permanently converted equipment is legal, it may not be technically desirable. The equipment is designed to be compatible with specific refrigerants, and incompatible materials may cause short circuits, damage to seals, and compressor failure. Technicians should check with the recovery equipment manufacturer for recommendations about the recovery of refrigerants other than the refrigerant the equipment was originally intended to recover. Conversion of recovery equipment for use with other refrigerants may also invalidate any warranties offered by the equipment manufacturer.
TECHNICIAN TRAINING AND CERTIFICATION
Before the final rule is published and goes into effect, technicians repairing or servicing HFC-134a MVACs do not need to be trained and certified to handle HFC-134a. After the effective date of the rule, however, technicians who repair or service HFC-134a MVACs must be trained and certified by an EPA-approved organization. If a technician is already trained and certified to handle CFC-12, he will not need to be re certified to handle HFC-134a.
RECORDKEEPING REQUIREMENTS
Service shops must certify to the EPA that they own approved HFC-134a equipment.
NOTE: This certification is a one-time requirement, so that if a shop purchased a piece of CFC-12 recycling equipment in the past, and sent the certification to the EPA, the shop does not need to send a second certification to the EPA when it purchases a second piece of equipment, no matter what refrigerant that equipment is designed to handle. If refrigerant is recovered and sent to a reclamation facility, the shop must retain the name and address of that reclaimer.
SALES RESTRICTIONS
At the time of publishing, there is no restriction on the sale of HFC-134a, so anyone may purchase it. The EPA will issue a proposed rule under section 608 of the Act that will include a proposal to restrict the sale of HFC-134a so that only technicians certified under sections 608 and 609 may purchase it. After the proposed rule is published, the EPA will review comments from the public on the proposal and will then publish a final rule sometime in late 1998.
Handling Other Refrigerants that Substitute for CFC-12
VENTING SUBSTITUTE REFRIGERANTS
Other than HFC-134a, all EPA-accepted refrigerants that substitute for CFC-12 in motor vehicles, and that are currently on the market, are blends that contain ozone-depleting HCFC's such as R-22, R-142b and R-124. Section 608 of the Clean Air Act prohibits venting any of these new blend substitutes into the atmosphere. The prohibition on venting these ozone-depleting blends has been in effect since 1992.
SECTION 609 REGULATORY HISTORY
When the March 1996 proposed rule that requires recycling of HFC-134a was published in final form in the summer of 1997, it also established a standard for equipment that is designed to recover, but not recycle, any single, specific blend substitute refrigerant.
RECOVER ONLY EQUIPMENT
Technicians recovering these blend refrigerants must use EPA-approved equipment. As noted above, the final rule contains a standard for equipment designed to recover, but not recycle, a single, specific blend refrigerant. It may be possible to convert a piece of CFC-12 recover-only equipment so that it meets this standard-see the discussion on equipment conversions that follows this topic.
The EPA is currently working with independent testing laboratories and with equipment manufacturers to devise equipment that can recover, but not recycle, not only multiple blend refrigerants, but also contaminated CFC-12 and HFC-134a. Within the next year, the EPA will propose a standard for this type of equipment. The EPA expects that this equipment should be available by the 1998 A/C season.
CONVERTING CFC-12 RECOVER-ONLY EQUIPMENT FOR USE WITH BLEND SUBSTITUTES
The EPA regulations prohibit technicians from changing fittings on the same unit back and forth so that the unit is used for CFC-12 in the morning, a blend substitute in the afternoon, another blend substitute the next morning, HFC-134a the next afternoon, etc.
The EPA regulations specify that when equipment is converted for use with a refrigerant other than the refrigerant for which the equipment was originally intended, the converted unit must be able to meet the applicable equipment standard set forth in the regulations. CFC-12 recover-only equipment may be permanently converted for use with single, specific blend refrigerants under certain conditions. The EPA intends to issue regulations placing certain restrictions on these retrofits in the future. Those restrictions may require that the manufacturer's service representative rather than the automotive service technician perform the retrofit, that a unit may only be retrofitted if retrofit procedures have been certified by an independent testing laboratory such as Underwriters Laboratories, and that an appropriate label is affixed to the unit. In addition, the retrofitted unit has to meet the technical specifications of the EPA standard.
RECYCLING EQUIPMENT
The EPA regulations currently prohibit technicians from recycling blend substitute refrigerants, and the Agency is not aware of any equipment currently on the market designed to recycle any of these blends. After recovering the blend refrigerant from the MVAC system, it must, therefore, be sent off-site for reclamation.
The EPA is working with independent testing laboratories and with equipment manufacturers to determine whether recycling equipment can be developed to service these blends, without jeopardizing the health or safety of the technician and the integrity of the MVAC system. If it is possible to develop such equipment, the EPA will work with equipment and refrigerant manufacturers and with independent testing laboratories to develop an appropriate standard for the equipment.
CONVERTING CFC-12 RECOVER/RECYCLE EQUIPMENT FOR USE WITH BLEND SUBSTITUTES
At the time of publication, the EPA also currently prohibits the conversion of existing CFC-12 or HFC-134a recycling equipment for either temporary or permanent use with a blend refrigerant. In the future, the EPA may issue regulations allowing these conversions but placing certain restrictions on who performs the conversions, what models may be converted, etc.
TECHNICIAN TRAINING AND CERTIFICATION
Technicians who repair or service MVACs with these refrigerants must be trained and certified by an EPA-approved organization. If a technician is already trained and certified to handle CFC-12 or HFC-134a, he will not need to be re certified to handle the blend refrigerants.
RECORDKEEPING REQUIREMENTS
Service facilities that work on vehicles that use blend substitutes must certify to the EPA that they own approved equipment designed to service these refrigerants. Note that this certification is a one-time requirement, so that if a shop purchased a piece of CFC-12 or HFC-134a recycling equipment in the past, and sent the certification to the EPA, the shop does not need to send a second certification to the EPA when it purchases a second piece of equipment, no matter what refrigerant that equipment is designed to handle. If refrigerant is recovered and sent to a reclamation facility, the shop must retain the name and address of that reclaimer.
SALES RESTRICTIONS
Because these blends contain HCFC's, Section 608 regulations prohibit the sale of any size container of any of these blend refrigerants to anyone other than certified technicians. This prohibition began in November, 1994.
Retrofitting Vehicles to Alternative Refrigerants
Although section 609 of the Act does not govern retrofitting, section 612 of the Act, which describes the EPS's Significant New Alternatives Policy (SNAP) program, does require that when retrofitting a CFC-12 vehicle for use with another refrigerant, the technician must first extract the CFC-12, must cover the CFC-12 label with a label that indicates the new refrigerant in the system and other information, and must affix new fittings unique to that refrigerant.
In addition, if a technician is retrofitting a vehicle to a refrigerant that contains R-22, the technician must ensure that only barrier hoses are used in the A/C system. Finally, if the system includes a pressure relief device, the technician must install a high-pressure compressor shutoff switch to prevent the compressor from increasing pressure until the refrigerant is vented.