Refrigerant Compliance Program

Technician Certification

EPA-approved certification testing is required for any person who may perform service, maintenance, repair, or recovery work on refrigerant-containing equipment. UC San Diego 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. UC San Diego uses the Refrigerant Compliance Management program (see below) to comply with recordkeeping requirements. Use the forms provided below to maintain records. 

• 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 UC San Diego 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 (see forms below) 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 (see forms below) to collect the information.
• Records of all UC San Diego technicians and outside contractors who perform any service, maintenance, repair, or disposal on refrigerant-containing equipment. Use the Contractor Input form (see forms below) to collect the information.
• Recovery and recycle unit information and maintenance history. Use the Recover/Recycling Unit Input form (see forms below) to collect the information.
• Complete service records for all refrigerant-related work by UC San Diego 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 (see forms below) 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 (see forms below) to collect the information

UC San Diego 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.

• 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.

"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 UC San Diego 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 (see forms below) 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, UC San Diego 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

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 UC San Diego or its subsidiaries. Contractors must verify their employees are properly certified and comply with these regulations.

Contractors must submit the following information to the UC San Diego 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

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

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

• UC San Diego technicians: See How to Request a Hazardous Waste Collection for more information.
• Contractors: Contact the Environmental Management Facility, (858) 534-2753, for assistance.

Ensure disposal information is properly documented:

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

• 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 (RCM) form (PDF) (Word)

• Federal Clean Air Act, Environmental Protection Agency (EPA)
• Stratospheric Ozone Protection, Title VI, EPA
• 40 CFR 82.166(j) & (k)), Electronic Code of Federal Regulations
• Addressing Ozone Layer Depletion, EPA
  • Ozone
• The Plain English Guide to the Clean Air Act, EPA