Just the Facts for MVACs: EPA Regulatory Requirements for Servicing of Motor Vehicle Air Conditioners
Section 609 of the Clean Air Act (CAA) directs the U.S. Environmental Protection Agency (EPA) to establish requirements to prevent the release of refrigerants during the servicing of motor vehicle air conditioners (MVACs) and MVAC-like appliances. MVACs are defined as mechanical vapor compression refrigeration equipment used to cool the driver's or passenger's compartment of any motor vehicle. MVAC-like appliances are used to cool the driver’s or passenger’s compartment of off-road vehicles, including agricultural and construction vehicles. Regulations developed under Section 609 of the Clean Air Act are promulgated in 40 CFR 82 Subpart B.
Under Section 609 of the CAA, EPA requires the following regarding the servicing of MVAC:
- Certification: MVAC systems may only be serviced for consideration (payment or bartering) by technicians trained and certified by an EPA-approved technician training and certification program. Technicians servicing MVAC-like appliances must always be certified. Certification is required regardless of the refrigerant.
- Equipment: Technicians must use approved refrigerant handling equipment designed for recovery only or recovery and recycling of MVAC refrigerant.
- Recharging: Refrigerant must be properly recycled or reclaimed before recharging it into an MVAC system.
The following sections describe the EPA regulatory requirements for the servicing of motor vehicle air conditioners and the potential impacts on the service industry.
- Approved Refrigerants
- Venting Prohibition
- Approved Refrigerant Handling Equipment
- Technician Training and Certification
- Recordkeeping Requirements
- Refrigerant Sales Restrictions
EPA’s Significant New Alternatives Policy (SNAP) program evaluates alternatives to ozone-depleting substances (ODS) and lists them as acceptable, acceptable subject to use conditions, or unacceptable. Substitutes for use in MVACs must be approved under SNAP for use in new vehicles, retrofit systems, or both. If a refrigerant is listed as unacceptable for use in MVACs, it is illegal to use in both new systems and to retrofit existing systems. All flammable refrigerants, except HFC-152a and HFO-1234yf, have been listed as unacceptable under SNAP and therefore, are illegal to use in the United States. This means that the only flammable refrigerants currently acceptable for use in MVACs are HFC-152a and HFO-1234yf.
As part of SNAP approval, EPA establishes refrigerant-specific requirements for unique fittings. This includes fittings for MVAC systems, servicing equipment, and containers. An adapter should not be used to convert a fitting.
For additional information on MVAC refrigerants, see the webpage “Motor Vehicle Air Conditioning Refrigerant Transition & Environmental Impacts”.
Another section of the Clean Air Act, Section 608, prohibits the intentional release (venting) of refrigerants, ozone-depleting and their substitutes, while maintaining, servicing, repairing, or disposing of air conditioning or refrigeration equipment. Currently, only one refrigerant approved for use in MVAC, carbon dioxide (CO2), is exempt from the venting prohibition.
Technicians must use certified refrigerant handling equipment to repair or service MVACs and MVAC-like appliances. EPA requires that MVAC refrigerant handling equipment be certified by the Administrator or an independent standards testing organization approved by the Administrator to meet the standards in 40 CFR 82 subpart B. Intertek (formerly ETL Testing Laboratories, Inc.) and Underwriters Laboratory (UL) are approved independent standards testing organizations. A list of approved recover/recycle and recover-only equipment is available at http://www.epa.gov/ozone/title6/609/technicians/appequip.html.
Certified refrigerant handling equipment must be used to remove refrigerant prior to servicing or repairing an MVAC, or conducting any other service on a vehicle during which discharge of refrigerant can reasonably be expected. Recovered refrigerant must be either recycled or reclaimed before it can be recharged it into an MVAC or MVAC-like appliance, even if the refrigerant is being returned to the system from which it was removed. Recovered refrigerant can either be recycled on-site using approved equipment designed to both recover and recycle refrigerant, or sent off-site to a reclamation facility to be purified according to ARI Standard 700. Recycling removes impurities and oil, while reclamation returns the refrigerant to virgin specifications. Refrigerant sent off-sight must be sent to an EPA-certified refrigerant reclaimer.certification form (PDF) (2 pp., 16KB, About PDF) must be submitted to the appropriate EPA Regional Office.
Note that this certification is a one-time requirement. If a shop purchased a piece of CFC-12 or HFC-134a refrigerant handling equipment in the past, and sent the certification to EPA, the shop does not need to send a second certification to EPA when it purchases another piece of equipment, no matter what refrigerant that equipment is designed to handle.
Technicians who repair or service motor vehicle air conditioners for consideration must be trained and certified by an EPA-approved technician training and certification program. Technicians who repair or service MVAC-like appliances must always be certified by an EPA-approved 609 program.
Under Section 609 of the Clean Air Act, EPA-approved technician training and certification programs provide education on the proper use of MVAC servicing equipment, the regulatory requirements of the Clean Air Act, the importance of refrigerant recovery, as well as the effects of improper handling of refrigerants on the ozone layer and climate system. To be certified, technicians must be trained by an EPA-approved program and pass a test demonstrating their knowledge in these areas. Section 609 certification is required to service any motor vehicle air conditioning system for consideration (e.g., payment or bartering), regardless of the refrigerant used in the system.
A list of EPA-approved technician training and certification program is available at http://www.epa.gov/ozone/title6/609/technicians/609certs.html.
Service shops must maintain records of the name and address of any facility to which refrigerant they recover is sent. Service shops are also required to maintain records (on-site) showing that all service technicians are properly certified.
The sale or distribution of any class I or class II substance, such as CFC-12 or refrigerant blends that include HCFCs, is restricted to technicians certified under section 608 or section 609 of the CAA. The sale or distribution of any class I or class II substance suitable for use in an MVAC that is in a container of less than 20 pounds may only be sold to technicians certified under section 609. Any person who sells or distributes CFC-12 for use as a refrigerant in a motor vehicle air conditioner and that is in a container of less than 20 pounds must verify that the purchaser has obtained certification by an EPA-approved section 609 technician training and certification program.
The only exception to these requirements is if the purchaser is purchasing the small containers for resale only. In this case, the seller must obtain a written statement from the purchaser that the containers are for resale only and indicate the purchasers name and business address. Records must be maintained for 3 years.