ESS Addresses Pending Changes to EPA Leak Rate and Leak Repair Regulations


Source: IHS Markit

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Rules changes impact long-standing mandate involving “annualized” leak rate calculations

An upcoming amendment to the Clean Air Act includes a provision that would allow for more flexibility in the way leak rate calculation methods have been regulated for the last 13 years, a refrigerant compliance expert at ESS said today.

U.S. Environmental Protection Agency (EPA) amendments to Section 608 of the Clean Air Act are scheduled to become effective March 14, 2005. The amendments will impact virtually all sectors that use refrigerants for comfort cooling, commercial refrigeration, industrial process refrigeration or federally owned systems. Included are appliances that contain CFC or HCFC refrigerant charges in excess of 50 pounds, along with HFC blends that contain any kind of ozone-depleting component, said Mark Harbin, refrigerant software and compliance services manager for ESS.

Most of the rules changes deal with confirmation and clarification of already existing requirements. However, within the amendment, there is a section that addresses "annualized" and “rolling average” leak rate calculations.

"Historically, the leak rate calculation that has been used by equipment (appliance) owners and operators has been modeled after the annualized method used in the EPA and Chemical Manufacturers' Association (CMA) guide – Compliance Guidance for Industrial Process Refrigeration Leak Repair Regulations Under Section 608 of the Clean Air Act," Harbin said. "While the annualized method has been used for many years by most facilities, another method known as "rolling average" was discussed in the CMA guide, but never adopted. The rolling average amendment gives owners and operators a second option for calculating leak rates."

There are caveats, though. If owners or operators of refrigerant equipment choose to change their method of calculating leak rates, the method change must coincide with the date of the rule change. Also, once chosen, the calculation method must be used consistently for the lifetime of all applicable equipment at an operating facility. Regardless of the method chosen, EPA requires equipment owners or operators to promptly calculate the leak rate each time refrigerant is added to applicable equipment.

News of the rules change came with an announcement by Robert Johnson, CEO of ESS, that the company's award-winning refrigerant compliance management software will be modified so users can switch to the rolling average leak rate calculation if they choose.

"ESS was founded on the strength of a refrigerant management solution and we have served as the nation's expert in the industry since the inception of the Clean Air Act," Mr. Johnson said. "Our software, training and compliance consulting services will continue to be adapted to the ever-changing regulatory environment."

About ESS

ESS is the leading provider of integrated software and services for EH&S and Crisis Management. ESS' Essential SuiteTM and Compliance SuiteTM solutions have helped more than 35,000 businesses, government agencies and other organizations comply with international, federal, state and local regulations and industry standards. For more information, visit For Compliance Services, visit

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