29 Questions to Ask About Your Compliance Plan

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Courtesy of IHS

Most processors want to comply with environmental regulations, but may not be aware of all concerns. The bestpractices checklist was developed by gathering information from organizations creating and implementing Environmental Protection Agency (EPA) refrigerant regulations compliance programs. It contains both EPA 'must do' requirements as well as industry 'should do' recommendations. Best practices recommendations help companies implement a framework of procedures, systems and information to ensure that 'must do' requirements are met.

Perform a self-check by answering the following refrigerant compliance management questions.

1. Do you have copies and a complete understanding of EPA regulations and requirements applying to refrigerants and their usage?
2. Do you have copies and a complete understanding of the penalties and enforcement actions EPA can impose for noncompliance?
3. Does your organization have a written mission statement for refrigerant regulations compliance that specifically documents your intent to comply with EPA regulations?
4. Does your organization have a written job description for a facility refrigerant manager, responsible for management and compliance?
5. Has someone in your organization been officially designated as the refrigerant compliance manager? EPA will want to speak to this person during a refrigerant compliance inspection.
6. Has the designated refrigerant compliance manager been formally trained in EPA refrigerant regulations compliance management to ensure effective program implementation?
7.Has the refrigerant compliance manager been given the financial resources and authority to implement a refrigerant compliance program?
8. Does your organization have a written policy for EPA-required refrigerant usage record-keeping, including a defined and uniform method of collecting, maintaining and making records available to EPA inspectors?
9. Does your organization have copies of EPA certifications for all in-house and contractor technicians working at your facility to ensure they are properly certified? These must be presented to EPA upon request.
10. Do you have a written unintentional refrigerant venting, leaking and reporting policy for your refrigerant appliances, equipment and refrigerant inventory?
11. Do you have a written refrigerant policy and designated certified technician or contractor responsible for all purchases?
12. Do you have a written appliance servicing policy, including EPA compliance requirements and specific refrigerant-handling pro-cedures?
13. Do you have a written labeling policy for refrigerant cylinders and refrigerant appliances?
14. Do you have a written refrigerant inventory and storage policy incorporating national and state regulations and building codes?
15. Does your organization have a written leak-testing process and defined service procedures for positive-pressure equipment?
16. Does your organization have a written leak-testing process for low pressure equipment and defined service procedures for positive-pressure equipment?
17. Does your organization have a written policy for disposal of refrigerant equipment and parts?
18. Does your organization have a written policy for disposal of used refrigerant lubricants?
19. Does your organization have a written policy for shipping and transportation of refrigerants, both into and out of your facility?
20. Does your organization have a written refrigerant inventory management policy that ad-dresses disbursement, cradle-to-grave record-keeping and audit tracking of all refrigerants?
21. Does your organization have a written refrigerant safety policy, including required safety equipment and procedures for handling refrigerants?
22. Does your organization have a written refrigerant emergency response plan, including major venting incidents, maximum exposure levels and evacuation procedures?
23. Does your organization have contractor EPA refrigerant compliance requirements language included in your service maintenance agreements to ensure contractors are not exposing your organization to any liability?
24. Does your organization provide maintenance personnel with written EPA refrigerant compliance policies and procedures manuals?
25. Have your organization's EPA refrigerant compliance policies and procedures been effectively communicated to all affected personnel through documented compliance training sessions?
26. Do you have copies and a complete understanding of the various updates, amendments and changes EPA has issued on the original refrigerant regulations since 1993?
27. Have you established an ongoing process and infrastructure to collect, distribute and communicate the various updates and amendments issued by EPA?
28. Do you conduct ongoing training for technicians and other affected personnel that includes updates, amendments and changes issued by EPA?
29. Do you have a written policy for conducting annual internal refrigerant compliance GAP analysis surveys to ensure your organization is in compliance with all EPA requirements?

Answering these questions will help you understand where your organization might need work to ensure compliance. If your organization does not already have a refrigerant regulations compliance program in place, this checklist can be used to build a framework.

Robert Johnson is president of Environmental Support Solutions, Mesa, Ariz., an organization that provides compliance software, training and consulting to organizations affected by EPA refrigerant regulations. Visit www.ess-home.com.

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