How to decifer government laws for refrigerant gases (R-22 HCFCs)

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Refrigerant Gas Regulations for R-22 HCFCs: How the Government Mandates Monitoring and Tracking

The U.S. Clean Air Act is a regulation that spells out the EPA's role in air quality, especially in protecting the ozone layer and the tracking and reporting of Greenhouse Gases. The Act is maintained by the House of Representatives. The Clean Air Act has had changes made in the 1990s and again in 2008 that are more stringent than when it was first written over a decade ago.

Refrigerant gases are those used in climate control in commercial and business facilities such as warehouses, stores and office buildings. The refrigerants used in commercial heating, ventilating and air conditioning (HVAC) or regular air conditioning (AC) units include hydrofluorocarbons (HCFCs), chlorofluorocarbon (CFCs) and perfluorocarbon (PFCs).

Hydrofluorocarbons (HCFCs), perfluorocarbons (PFCs), and chlorofluorocarbons (CFCs) are destructive Greenhouse Gases (GHGs) as well as harmful to the upper ozone layer. HCFCs do not have any of the organic chemicals chlorine or bromine, but they still do have a possibility of causing ozone depletion. These refrigerant gases are not only considered Ozone Depleting Substances (ODS) but many of them also have very high Global Warming Potential ratios which results in their detailed tracking, monitoring, and reporting related to their Global Warming effects.

While perfluorocarbons do not contribute to the depletion of the ozone layer, scientists worry that PFCs can contribute to global warming since they have a very high global warming potential (GWP). GWP is a ratio developed to determine which chemical substances and refrigerant gases released into the atmosphere create more warming. The most common greenhouse gas (GHG) talked about the most often is carbon dioxide (CO2) or just carbon for short.

CFCs have been used since the early 1930s and were found to deplete ozone in the 1970s. A chemical reaction caused by ultraviolet (UV) radiation breaks off the chlorine atom in CFCs. This chlorine atom binds with oxygen already in the atmosphere. The depletion of the ozone is the result of chemical reactions where chlorine and oxygen are split apart.

Refrigerant management and knowing, down to the pound level where all refrigerant gases reside, is critical for the safety of the environment and to limit the release of Greenhouse Gases (GHG). The result of refrigerant emissions is either ozone destruction or increased Global Warming, both contributing to climate change. EPA Inspectors, governmental regulators, as well as many state officials are responsible for monitoring commercial AC and HVAC systems. They can do spot checks of the refrigerant service records, purchase orders, transit logs of gas transport for destruction, as well as many other pieces of data related to refrigerant gas management.

Existing and new legislation to be passed in 2009 requires companies keep accurate records that can be produced on demand by regulators to assure that AC and HVAC systems are not leaking and that all refrigerant gases are recovered correctly.

Due to the connection between refrigerant gases and their effect on climate change, many legislative bodies including various US states and the EPA have stepped up and increased the detailed refrigerant reporting requirements.

EPA Section 608 is a certification requirement for technicians before they can work on HVAC or AC systems. The EPA has detailed regulations on the purchase of refrigerant gas. For the most part, service technicians must be certified to even purchase gas in cylinders as small as 20 pounds. Nobody can buy any amount of refrigerant unless they are certified by the EPA.

The U.S. Environmental Protection Agency (EPA) has four certification classes. Type 1 is for small appliances. Type 2 is for high and very high pressure. Type 3 is a low pressure certification. Type 4 is a universal certification. Any technician with a particular certification type can only fix or recover equipment that is specified for the certification type.

Legislation due to become law in 2009 will require that all owners or operators of systems containing 50 pounds of refrigerant gas or more to monitor for leaks, maintain detailed service records, track all purchases of refrigerant, and submit annual reports of refrigerant usage and destruction annually.

Some of the larger AC or HVAC systems will require more frequent refrigerant reporting and more detailed system registrations. In all situations across not only service technicians, those who sell refrigerant gas, and those who own or operate AC or HVAC systems, the need for detailed, up-to-date refrigerant data, across an entire organization has never been more important.

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