EPA enforcement can be costly for organizations that do not track refrigerant gases

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Courtesy of Verisae

The EPA penalty aspect of the U.S. Clean Air Act is managed by the Office of Enforcement and Compliance Assurance. The agency is diligently enforcing requirements to reduce harmful gas emissions. The law allows auditors and inspectors to conduct on-site inspections and request a facility's records regarding their regulation of gases. Without providing proper documentation, or supplying incomplete or missing information, the risk of significant fines is high.

The phase-out program of refrigerant gas is now in full swing and facilities that use equipment requiring the use of ozone-depleting substances (ODS) are at risk for a substantial EPA penalty if they fail to follow the requirements outlined in the U.S. The US Clean Air Act include the reporting requirements and refrigerant data management rules that organizations must follow to report annual refrigerant usage. HVAC-R systems and related refrigeration equipment must be monitored, in some cases real-time with leak checkers, service records tracked, and reports submitted on an annual bases. Other systems such as with halon as in fire safety systems are also tracked.

To mitigate the EPA environmental mandates, organizations and government agencies of all sizes must manage and control refrigerant gases more accurately. Processes and often web-based tools should be implemented to manage, track, report, and submit service related documents in support of refrigerant management programs. Organizations operating or owning systems containing refrigerant gas, which are also ozone depleting substances, are subject to large fines for non-compliance. To cope with EPA and international regulations, progressive organizations turn to web-based applications to help manage and track their refrigerant gases. These refrigerant management programs centralize the data, monitor HVAC-R service related leaks, and empower one-click reporting of refrigerant usage. This allows them to keep current with government policies, compliance requirements, and penalties for non-compliance.

Overseeing the EPA penalty aspect of the U.S. Clean Air Act is the Office of Enforcement and Compliance Assurance. They are aggressively pursuing enforcement of the requirements to curb harmful gas emissions. Auditors and inspectors are permitted to make spot inspections to review a facility's records pertaining to regulated gases. Those unable to produce proper documentation, or have incomplete or missing data are subject to heavy fines.

The EPA penalty applies to facilities that improperly emit, vent, or dispose of refrigerant gas. The law requires proper servicing and safe removal of any equipment using restricted substances. Noncompliance could result in fines of up to $25,000 a day, per violation. Additional fines are added if the refrigerant gas is not properly recovered. Because of the substantial penalties involved, the government has developed a technician certification program for anyone who provides service, repair, maintenance, or disposal of equipment containing refrigerant gases.

Under the EPA penalty guidelines, refrigerant leaks not fixed within 30 days are subject to a $32,500 fine per day, per unit. Furthermore, purchasing used or imported refrigerant gas calls for fines of $300,000 per 30 pound cylinder of refrigerant gas. With so much money at stake, it is crucial for business entities, organizations, and municipalities to track every pound of gas and manage its inventory, especially those with more than one location where records management and ease of reporting becomes difficult.

Any amendments to the environmental laws usually allow for a period when comments are accepted and updates to the regulations are proposed and implemented. Since the inception of The Montreal Protocol, the Environmental Protection Agency (EPA) and other state government regulators have enforced the scheduled phase out of ODS with violators subject to large penalties. The total of fines collected is in the billions of dollars each year. With the added incentives related to carbon emissions management and the World's heightened awareness of climate change it is fully anticipated that more stringent and more restrictive measure will be placed on all substances that harm the environment.

Because refrigerant gas contains chlorofluorocarbons and hydrochlorofluorocarbons, identified as the major causes of ozone depletion, its use is being reduced, and eventually eliminated, worldwide. The plan reduces the use of R-22 refrigerant gas by 75% by 2010 and eliminates it by 2015. The EPA penalty increases as the complete phase-out comes to a close.

EPA penalty policies are based on the guidelines established by the U.S. Section 608 of the US Clean Air Act, along with the global treaties; The Montreal and The Kyoto Protocols work in concert to enhance the management and control of refrigerant gases across all HVAC-R systems of 50 lbs or greater. Taken in combination, these regulations and protocols cover ozone depleting substances and refrigerant gases which have a high global warming potential (GWP). Penalties are being issues to protect the environment and to encourage facilities to improve their carbon foot print.

Additional Resources:

Daniel Stouffer, a Product Manager at Verisae, has much more detail on the importance of effective refrigerant gas management and its place as it relates to the EPA Compliance and Enforcement regulations. Refrigerant Tracker makes it easy to monitor, manage, and report refrigerant gas usage. Learn more at http://www.Refrigerant-Tracker.com

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