Just the Facts for MVACs: EPA Regulatory Requirements for Servicing of Motor Vehicle Air Conditioners
Our Threatened Ozone Layer
The ozone layer acts as a blanket in the stratosphere that protects us from harmful ultraviolet (UV) radiation. Scientists worldwide believe that man-made chemicals such as CFC-12 (also known by the trade name Freon) are rapidly destroying this layer of gas 10 to 30 miles above the earth's surface. Strong UV radiation breaks the CFC-12 molecules apart, releasing chlorine. A single chlorine atom can destroy over one hundred thousand ozone molecules. Ozone loss in the atmosphere is likely to lead to an increase in cataracts and skin cancer, which is now one of the fastest growing forms of cancer, and could weaken the human immune system. In the U.S., one person dies of skin cancer every hour. Agriculture, as well as plant and animal life, may also be dramatically affected.
Remember that ozone is "good up high, bad nearby": even though it protects us when it is in the stratosphere, ozone at ground level can be harmful to breathe and is a prime ingredient in smog. Many man-made sources such as tailpipe emissions from cars contribute to ground-level ozone.
Global Action to Protect the Ozone Layer
The United States has joined over 190 countries as a Party to the international treaty known as the Montreal Protocol. All developed countries agreed to phase out production of most ozone-depleting substances, including CFCs, by the end of 1995. The 1990 Clean Air Act Amendments (the Act) incorporated this production ban date and directed EPA to develop regulations to maximize recycling, ban nonessential uses, develop labeling requirements and examine safe alternatives for ozone-depleting substances.
Impact of Motor Vehicle Air Conditioners
One of the largest uses of CFC-12 in the U.S. is as a refrigerant in motor vehicle air conditioners (MVACs). Section 609 of the Act gives EPA the authority to establish requirements to prevent the release of refrigerants during the servicing of MVACs and to require recycling of refrigerants. Widespread refrigerant recycling reduces the demand for virgin CFC-12 and thus extends the time that it will be available. The following sections describe the requirements of the law and its potential impact on the service industry.
Recycling vs. Reclamation
In the discussion below, recycling means the use of a machine to remove impurities and oil and then recharge the refrigerant into either the same car or a different car. Recycled refrigerant is not as pure as reclaimed refrigerant. Recycling occurs in the service shop.
Reclamation means the removal of all oil and impurities beyond that provided by on-site recycling equipment, and reclaimed refrigerant is essentially identical to new, unused refrigerant. Reclamation cannot be performed in the service shop. Rather, the shop generally sends refrigerant either back to the manufacturer or directly to a reclamation facility.
Venting CFC-12Another section of the Clean Air Act, Section 608, prohibits releasing CFC-12 into the atmosphere. The prohibition on venting CFC-12 has been in effect since 1992.
Section 609 Regulatory History
The original regulation promulgated under section 609 was published in July 1992. That regulation established standards for equipment that recovers and recycles CFC-12 refrigerant from motor vehicle air conditioners, rules for training and testing technicians to handle this equipment, and record-keeping requirements for service facilities and for refrigerant retailers. A supplemental final rule published in May 1995 established a standard for equipment that recovers but does not recycle CFC-12, and training and testing technicians to handle this equipment.
Technicians repairing or servicing CFC-12 MVACs must use either recover/recycle or recover-only equipment approved by EPA. Recover/recycle equipment cleans the refrigerant so that oil, air and moisture contaminants reach acceptably low levels.
Technicians who repair or service CFC-12 and HFC-134a motor vehicle air conditioners must be trained and certified by an EPA-approved organization. Training programs must include information on the proper use of equipment, the regulatory requirements, the importance of refrigerant recovery, and the effects of ozone depletion. To be certified, technicians must pass a test demonstrating their knowledge in these areas.
Service shops must maintain records of the name and address of any facility to which refrigerant is sent. If refrigerant is recovered and sent to a reclamation facility, the name and address of that facility must be kept on file. Service shops are also required to maintain records (on-site) showing that all service technicians are properly certified.
Service shops must certify to EPA that they have
acquired and are properly using approved refrigerant
recovery equipment, and that each person using the
equipment has been properly trained and certified. The
certification statement shall include the name and
address of the service establishment, the name of the
equipment manufacturer, equipment model and serial
number, and equipment date of manufacture. A sample
certification form (PDF) (2 pp.,
16KB, About PDF) shows the information that should be included in
the signed statement.
Section 609 has long prohibited the sale of small cans of ozone-depleting refrigerants to anyone other than a certified technician. The sale of any size container of CFC-12 to anyone other than certified technicians was prohibited under section 608 of the Act beginning on November 14, 1994. This provision is intended to discourage "do-it-yourselfers" who recharge their own air conditioners. Such individuals often release refrigerant because they typically do not have access to recovery/recycling equipment. The Agency encourages "do-it-yourselfers" to bring their cars to certified technicians who can properly fix air conditioners using approved equipment. This avoids damage to A/C equipment by improper charging and helps to protect the environment.
Venting HFC-134a Refrigerant
Section 609 Regulatory History
EPA proposed a rule to require recycling of HFC-134a on March 6, 1996 (61 FR 9014) (20 pp, 327 KB). The rule proposed standards for recover-only and recover/recycle equipment and rules for training and testing technicians to handle this equipment. EPA requested comments from the public about this proposed rule, and, after reviewing the comments, published a final rule on December 30, 1997 (62 FR 68026) (32 pp, 351 KB). For more information about this rule, see the fact sheet "Summary of Final Rule Governing Substitutes for CFC-12 Refrigerant in Motor Vehicle Air Conditioners."
Technicians who repair or service HFC-134a MVACs must recover the refrigerant and either recycle it on-site, or send it off-site to a reclamation facility so that it may be purified according to ARI Standard 700. Technicians must use EPA-approved equipment to perform the refrigerant recovery and recycling. Recover/ recycle equipment cleans the refrigerant so that oil, air and moisture contaminants reach acceptably low levels. A list of approved recover/recycle and recover-only equipment is available from the Hotline and the web site listed above. Note that certain EPA-approved models can recycle both CFC-12 and HFC-134a refrigerants.
Converting CFC-12 Equipment for Use with HFC-134a
EPA regulations prohibit technicians from changing fittings on the same unit back and forth so that the unit is used for CFC-12 in the morning, HFC-134a in the afternoon, then back to CFC-12 again, etc.
EPA regulations specify that when equipment is converted for use with a new refrigerant, the converted unit must be able to meet the applicable equipment standard set forth in the regulations. CFC-12 equipment may be permanently converted for use with HFC-134a under certain conditions. EPA intends to issue regulations placing certain restrictions on these retrofits in the future. Those restrictions may require that the manufacturer's service representative rather than the automotive service technician perform the retrofit, that a unit may only be retrofitted if retrofit procedures have been certified by an independent testing laboratory such as Underwriters Laboratories, and that an appropriate label is affixed to the unit. In addition, the retrofitted unit must meet the technical specifications of SAE standard J2210 and must have the capacity to purify used refrigerant to SAE standard J2099 for safe and direct return to the air conditioner following repairs.
Currently, however, in the absence of any EPA regulations, a service facility may perform such a retrofit, or may have the equipment manufacturer's service representative perform the retrofit, as long as the fittings are changed in accordance with EPA's Significant New Alternative Policy (SNAP) program regulations. The Agency cautions technicians, however, that even though recovering a given refrigerant using permanently converted equipment is legal, it may not be technically desirable. The equipment is designed to be compatible with specific refrigerants, and incompatible materials may cause short circuits, damage to seals, and compressor failure. Technicians should check with the recovery equipment manufacturer for recommendations about the recovery of refrigerants other than the refrigerant the equipment was originally intended to recover. Conversion of recovery equipment for use with other refrigerants may also invalidate any warranties offered by the equipment manufacturer.
Technician Training and Certification
Technicians who repair or service HFC-134a MVACs must be trained and certified by an EPA-approved organization. If a technician is already trained and certified to handle CFC-12, he does not need to be recertified to handle HFC-134a.
Service shops must certify to EPA that they own approved HFC-134a equipment. Note that this certification is a one-time requirement, so that if a shop purchased a piece of CFC-12 recycling 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 a second piece of equipment, no matter what refrigerant that equipment is designed to handle. If refrigerant is recovered and sent to a reclamation facility, the shop must retain the name and address of that reclaimer.
Right now, there is no restriction on the sale of HFC-134a, so anyone may purchase it. This year, EPA will issue a proposed rule under section 608 of the Act that will include a proposal to restrict the sale of HFC-134a so that only technicians certified under sections 608 and 609 may purchase it. After the proposed rule is published, EPA will review comments from the public on the proposal and will then publish a final rule sometime in 1998 or 1999.
Handling Other Refrigerants that Substitute for CFC-12
Venting Substitute Refrigerants
Other than HFC-134a, all EPA-accepted refrigerants that substitute for CFC-12 in motor vehicles, and that are currently on the market, are blends that contain ozone-depleting HCFCs such as R-22, R-142b and R-124. Section 608 of the Clean Air Act prohibits venting any of these new blend substitutes into the atmosphere. The prohibition on venting these ozone-depleting blends has been in effect since 1992.
Section 609 Regulatory History
The December 1997 final rule established a standard for equipment that is designed to recover, but not recycle, any single, specific blend substitute refrigerant.
Using Older Equipment to Recover Blends
Technicians have a number of choices in recovering blend refrigerants. One option is that a technician may permanently dedicate an older piece of equipment he owns to recovering one or more blend refrigerants. The technician may also use this equipment to recover contaminated CFC-12 and HFC-134a and other "mystery mixtures." This equipment, however, may no longer be used to recover uncontaminated CFC-12 or HFC-134a. Refrigerant recovered using this kind of "junk" tank must then be shipped off-site for reclamation or destruction.
Using New Equipment to Recover Blends
Another option for recovering a blend refrigerant is to use a new piece of EPA-approved equipment designed to recover, but not recycle, any single, specific blend refrigerant. The EPA regulation published in December 1997 includes an appendix that describes the standards that this new equipment must meet.
In addition, EPA is currently working with independent testing laboratories and equipment manufacturers to devise a standard for new equipment that can recover, but not recycle, both multiple blend refrigerants and contaminated CFC-12 and HFC-134a. EPA will finalize a standard for this type of equipment by the end of 1998. This equipment may be commercially available by the 1998 A/C season. EPA expects to grandfather any equipment purchased in 1998 before the EPA standard becomes finalized.
As of June 1, 1998, EPA allows recycling of refrigerant blends used in motor vehicle air conditioning systems (MVACs), provided that a) recycling equipment meets a new Underwriters Laboratories (UL) standard (Standard 2964) and b) refrigerant is returned to the vehicle from which it was removed. The only exception to item b) is for fleets of vehicles with a common owner; recycled blend refrigerant may be moved among vehicles within such a fleet. EPA detailed this policy in a June 1, 1998, open letter to the industry. Certified recycling equipment may be commercially available during the 1998 A/C season. EPA plans to adopt this new UL standard into EPA's regulations and to grandfather any equipment that (1) meets the UL standard and (2) is purchased before the date on which EPA publishes a proposed rule to adopt the UL standard.
Converting CFC-12 or HFC-134a Recover/Recycle Equipment for Use with Blend Substitutes
EPA currently prohibits the conversion of existing CFC-12 or HFC-134a recycling equipment for either temporary or permanent use with a blend refrigerant, unless the equipment is used only to recover, but not to recycle, the refrigerant. In the future, EPA may issue regulations allowing these conversions but placing certain restrictions on who performs the conversions, what models may be converted, etc.
Technician Training and Certification
Technicians who repair or service MVACs that use blend refrigerants must be trained and certified by an EPA-approved organization. If a technician is already trained and certified to handle CFC-12 or HFC-134a, he does not need to be recertified to handle a blend refrigerant.
Service facilities that work on vehicles that use blend substitutes must certify to EPA that they own approved equipment designed to service these refrigerants. Note that this certification is a one-time requirement, so that if a shop purchased a piece of CFC-12 or HFC-134a recycling 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 a second piece of equipment, no matter what refrigerant that equipment is designed to handle. If refrigerant is recovered and sent to a reclamation facility, the shop must retain the name and address of that reclaimer.
Section 608 regulations prohibit the sale of any size container of any blend refrigerant to anyone other than a certified technician. This prohibition began in November, 1994.
Retrofitting Vehicles to Alternative RefrigerantsAlthough Section 609 of the Act does not govern retrofitting, Section 612 of the Act, which describes the Agency's Significant New Alternatives Policy (SNAP) program, does require that when retrofitting a CFC-12 vehicle for use with another refrigerant, the technician must first extract the CFC-12, must cover the CFC-12 label with a label that indicates the new refrigerant in the system and other information, and must affix new fittings unique to that refrigerant. In addition, if a technician is retrofitting a vehicle to a refrigerant that contains R-22, the technician must ensure that only barrier hoses are used in the A/C system. Finally, if the system includes a pressure relief device, the technician must install a high-pressure compressor shutoff switch to prevent the compressor from increasing pressure until the refrigerant is vented.
Much more information about the SNAP program and about retrofitting procedures is available in a fact sheet called Choosing and Using Alternative Refrigerants.