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Refrigerant Compliance Program

Learn about employee and contractor responsibilities for implementing UCSD's Refrigerant Compliance Program.

Refrigerants are regulated as hazardous materials by the federal Environmental Protection Agency (EPA) because they have a powerful green house gas effect and deplete the ozone layer when released into the atmosphere.

UCSD Refrigerant Compliance Program

UC San Diego’s Refrigerant Compliance Program identifies management, monitoring, tracking, and reporting measures that must be implemented by campus employees and contractors to restrict release of refrigerants identified as ozone-depleting substances.

Ozone-depleting substances (ODS) include chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), halons, methyl bromide, carbon tetrachloride, hydrobromofluorocarbons, chlorobromomethane, and methyl chloroform.

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Requirements

Technician Certification

EPA-approved certification testing is required for any person who may perform service, maintenance, repair, or recovery work on refrigerant-containing equipment. UCSD technicians and contractor technicians may service only equipment for which they are certified.

Label Refrigerant Recovery Equipment

The following label or its equivalent must be present on all refrigerant recovery equipment:

This equipment has been certified by ARI/UL to meet EPA’s minimum requirements for recycling and/or recovery equipment intended for use with [appropriate appliance category].

Recordkeeping

Federal law requires specific information related to refrigerant use to be documented and retained for a minimum of 3 years. Purchase records of refrigerants used in units with over 50-pound charge must be retained for 5 years. UCSD uses the Refrigerant Compliance Management program (see below) to comply with recordkeeping requirements.

Refrigerant Compliance Management (RCM)

UCSD uses a central computerized database called the Refrigerant Compliance Management (RCM) program to track refrigerant information, including purchase, removal, and additions during maintenance and disposal.
  • For questions about the RCM database or to set up an account for a new employee to use the RCM program, contact Environment, Health & Safety.

Because UCSD uses refrigerants across all sizes of units, any refrigerant purchased and used on campus must be tracked. All refrigerant-containing equipment and cylinders must be identified with a unique identification (ID) number and the refrigerant type and charge quantity. The identification number must appear on all documentation related to the specific piece of equipment or cylinder and is used to track the refrigerant in the RCM.

Use the RCM to capture this required information:

  • A complete and current inventory of refrigerant-containing equipment categorized as under 50 pounds, over 50 pounds, comfort cooling, commercial refrigeration, industrial process refrigeration, or other. Use the Equipment Input form (PDF) (Word) to collect the information.
  • A complete and current inventory of all refrigerant-containing cylinders or other refrigerant containers that are on site. At a minimum, annual refrigerant inventory reconciliation must be completed and documented. Use the Cylinder Input form (PDF) (Word) to collect the information.
  • Records of all UCSD technicians and outside contractors who perform any service, maintenance, repair, or disposal on refrigerant-containing equipment. Use the Contractor Input form (PDF) (Word) to collect the information.
  • Recovery and recycle unit information and maintenance history. Use the Recover/Recycling Unit Input form (PDF) (Word) to collect the information.
  • Complete service records for all refrigerant-related work by UCSD technicians and contractors. At a minimum, service records must contain:
    • Date of service
    • Technician or contractor name
    • Quantity and type of refrigerant added, recycled, or removed
    • Description of services provided
    • Leak repair procedure
    • Leak testing method and results
    • Vacuum level achieved during recovery – Use the Refrigerant Service Order form (PDF) (Word) to collect the information
  • Reports of known or observed leaks.
  • Decommissioning information when refrigerant-containing equipment is removed from service and refrigerant and equipment oil is removed:
    • Date of refrigerant/oil recovery
    • Technician or contractor name
    • Equipment ID
    • Model and serial number
    • Refrigerant type
    • Quantity recovered
    • Recovery unit ID
    • Vacuum level
    • Quantity of oil recovered
    • Disposal records for empty equipment, refrigerant, and oil – Use the Refrigerant Service Order form (PDF) (Word) to collect the information

Refrigerant inventory

UCSD area supervisors of workplaces that purchase, use, or store refrigerants must conduct and document inventory in the RCM at these times:

  • 3 month intervals – Review refrigerant inventory every 3 months for accuracy and completeness.
  • Annually – Perform a thorough physical audit of refrigerants, and reconcile any discrepancies between the quantity purchased, disposed, and inventoried.

Leak testing

Refrigerant-containing equipment must be leak tested using EPA-approved methods and documented in the RCM at these times:
  • Perform leak testing on all new refrigeration equipment (factory charged, field charged, spilt system, packaged equipment, or field constructed system) prior to acceptance and operation.
  • After equipment repairs, conduct leak testing before recharging the repaired unit with refrigerant.
  • Perform leak testing annually for each system with greater than 50 pounds of refrigerant as part of scheduled preventative maintenance inspections.
  • After a known leak, conduct a 30-day leak test verification on repaired equipment with over 50 pounds of charge capacity.

Leaking systems

"Allowed" leak rate

The "allowed" leak rate is different based on the use of the equipment. Specifics can be found at 40 CFR 82.156. The RCM program automatically performs leak rate calculations and flags equipment that requires attention. This is only valid if complete and accurate data is present in the RCM program.

Failure to make the required leak calculation or promptly enter the service work order data into the RCM program is not acceptable.

Known leaks

A refrigerant system has a "known" leak when any of the following conditions apply:

  • Review of the available documentation determines the system has a leak
  • A UCSD technician or contractor has added refrigerant to the same system during a recent visit of less than 1 year
  • The service technician readily determines the system has a refrigerant leak

Leak response

If a refrigerant unit cannot be shut down for repairs and refrigerant must be charged into the leaking system, the technician must first obtain documented authorization from their supervisor.

  • Document authorization on the RCM Service Order form (PDF) (Word) and describe why repairs are delayed.
  • Promptly enter the information in the RCM program.

Eliminate known or suspected leaks as quickly as practicable. If a leak exceeds the regulatory leak rate as determined by the RCM program, UCSD is required to:

  1. Complete leak repairs in 30 days
  2. Develop a detailed and specific plan for equipment retrofit or replace the equipment within 1 year of the earliest leak identification

Contractor requirements

Contractors are responsible and accountable for compliance with EPA regulations at 40 CFR 82 et al, the Clean Air Act (CAA), Section 608, and any state and local codes when performing refrigerant-related work for UCSD or its subsidiaries. Contractors must verify their employees are properly certified and comply with these regulations.

Contractors must submit the following information to the UCSD project manager for inclusion in the RCM program:

  • Service technician names, EPA certification numbers, and copies of EPA Certification Cards
  • Recovery and recycling units to be used and a copy of the EPA Recovery Unit Acquisition Certification
  • Service, repair, or installation records for each piece of equipment listed below:
    • Manufacturer and model number
    • Serial number
    • Location of equipment
    • Refrigerant type and unit charge
    • Date of service or installation
    • Service, repair, or disposal description
    • Quantity and type of refrigerant added
    • Quantity of refrigerant removed, recovered, recycled, reclaimed, or disposed
    • Quantity and method of lubricant (oil) disposed
    • Leak discovery and repair information
    • Name of EPA certified technician who performed the work
    • EPA-certified equipment used on the equipment

UCSD will stop work under any contract at any time if the work fails to meet federal, state, local or UCSD requirements.

Disposal of refrigerants, lubricants, and equipment

Disposal of refrigerants, oils, and associated equipment is regulated as hazardous waste. Removal of refrigerant liquids or equipment from UCSD property must be performed by either the UCSD Environmental Management Facility or a certified, approved refrigerant contractor.

Ensure disposal information is properly documented:

  • Enter disposal information in the RCM database.
  • Provide printed copies of manifest documents to the UCSD Environmental Management Facility, Mail Code 0958.

Forms

  • Equipment Input form (PDF) (Word)
  • Cylinder Input form (PDF) (Word)
  • Contractor Input form (PDF) (Word)
  • Recover/Recycling Unit Input form (PDF) (Word)
  • Refrigerant Service Order form (PDF) (Word)

Regulations and policies

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