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Overlap between Section 608 and Section 609

EPA regulations (40 CFR Part 82, Subpart F) under Section 608 of the Clean Air Act address the handling and recycling of refrigerants used in stationary refrigeration and air conditioning systems. Regulations (40 CFR Part 82, Subpart B) under Section 609 of the Clean Air Act specifically address the servicing of motor vehicle air conditioners (MVACs).

Although MVACs are included in the definition of appliances in Section 608, they are not subject to the servicing requirements under Section 608 because their service and repair are addressed in Section 609. Procedures involving MVACs that are not covered by Section 609, such as the disposal of MVACs and the purchase of refrigerant for use in MVACs, are covered by Section 608.

Other areas of overlap are described below. More information is provided in these two fact sheets:

Technician Certification

Both sets of regulations require that technicians become certified. Technicians who repair or service MVACs must be trained and certified by an EPA-approved Section 609 Technician Training and Certification Program. These programs are specifically designed to cover MVAC recycling equipment in accordance with Society of Automotive Engineers (SAE) standards and Section 609 regulatory requirements. After completing a required training program, MVAC technicians must pass a test to become certified. These tests are different from the Section 608 technician certification tests.

Under Section 608, EPA has established four types of certification for technicians who service and repair appliances other than MVACs. Technicians must be certified by passing a test in the appropriate area. All training and review classes for Section 608 are voluntary; only passing the test is mandatory.

People who service or repair MVAC-like appliances (e.g., farm equipment and other non-road vehicles) can choose to be certified under either the Section 609 program or the Section 608 Type II program. Due to similarities between MVACs and MVAC-like appliances, EPA recommends that technicians servicing MVAC-like appliances consider certification under Section 609.

Note that buses that use chlorofluorocarbonHelpchlorofluorocarbonA compound consisting of chlorine, fluorine, and carbon. CFCs are very stable in the troposphere. They move to the stratosphere and are broken down by strong ultraviolet (UV) light, where they release chlorine atoms that then deplete the ozone layer. CFCs are commonly used as refrigerants, solvents, and foam blowing agents. The most common CFCs are CFC-11, CFC-12, CFC-113, CFC-114, and CFC-115. The ozone depletion potential (ODP) for each CFC is, respectively, 1, 1, 0.8, 1, and 0.6. A table of all ozone-depleting substances (http://www.epa.gov/ozone/science/ods/index.html) shows their ODPs, global warming potentials (GWPs), and CAS numbers. CFCs are numbered according to a standard scheme (http://www.epa.gov/ozone/geninfo/numbers.html). (CFC)-12 (also called R-12) are MVACs, but buses that use hydrochlorofluorocarbonHelphydrochlorofluorocarbonA compound consisting of hydrogen, chlorine, fluorine, and carbon. The HCFCs are one class of chemicals being used to replace the CFCs. They contain chlorine and thus deplete stratospheric ozone, but to a much lesser extent than CFCs. HCFCs have ozone depletion potentials (ODPs) ranging from 0.01 to 0.1. Production of HCFCs with the highest ODPs are being phased out first, followed by other HCFCs. A table of ozone-depleting substances (http://www.epa.gov/ozone/science/ods/classtwo.html) shows their ODPs, GWPs, and CAS numbers. HCFCs are numbered according to a standard scheme (http://www.epa.gov/ozone/geninfo/numbers.html). (HCFC)-22 (also called R-22) are not MVACs or MVAC-like appliances, but rather are high-pressure equipment covered under the Type II Section 608 certification.

Refrigerant Sales Restriction

Under EPA regulations, only EPA-certified technicians may purchase refrigerants. Currently this applies to refrigerants that consist wholly or in part of CFCs or HCFCs, but starting January 1, 2018 it also extends to non-ozone depleting refrigerants like HFCs and HFOs. Exception include the purchase of small cans (fewer than 2 pounds) of substitute refrigerants (e.g., HFC-134a) sold to DIY-ers for servicing MVACs and the purchase of exempt refrigerants (e.g., ammonia and hydrocarbons).

Section 608 technician certification is required to purchase ozone depleting or HFC refrigerants, with the exception of small containers (fewer than 20 lbs.) of CFC-12.

Section 609 technician certification is required to purchase CFC-12 or EPA-approved substitutes for MVACs containing an ODS. Section 609 technicians cannot purchase HCFC-22 in any size container.

Recordkeeping

Section 608 requires that all persons who sell refrigerants, and blends thereof, retain invoices that indicate the name of the purchaser, the date of the sale, and the quantity of the refrigerant purchased. These requirements are for all sales affected by Section 608. These requirements currently apply to ozone depleting refrigerant but will apply to HFC and non-exempt substitute refrigerants starting January 1, 2018.

Records must be maintained for the sale of:

  • All refrigerants in any size container.
  • Ozone-depleting MVAC refrigerants in containers of 20 pounds or more.

Recordkeeping requirements do not apply to the sale of small containers (fewer than 20 pounds of CFC-12 or fewer than 2 pounds of substitute MVAC refrigerants (e.g., HFC-134a). However, the sale of small containers of CFC-12 MVAC refrigerants is restricted to Section 609 technicians.

Learn more about recordkeeping requirements for refrigerant retailers.