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Videos on both of them, you can find on my channel, as well as the true tech tools channel, the vpat 5 vacuum pump and the mr 45 recovery machine, both great devices that I know you will enjoy a legend. In his own mind, your favorite host of an HVAC training podcast based out of Clermont Florida, Brian or yo yo yo. This is the HVAC school podcast. Thanks for listening, I appreciate you taking the time out of your busy day, you're, probably driving.

That's when most Tech's listen to this podcast, while they're driving on the road in between calls and says something about you for sure, because this is the podcast that helps you remember some things that you might have forgotten along the way as well as helps you remember. Some things you forgot to know in the first place and if you are a listener to this podcast, I can tell you that you're investing in your career, you're doing the right thing for you, your family, the industry and good on ya, and today we're talking about A very important industry topic, which is changes to the EPA 6:08 regulations. Yes, the 6:08 regulations are the regulations that we have to abide by. It's what we certify when we take our EPA certification and never fear you don't have to get recertified.

That's not in the cards, but there's some other weird things that are going on that you want to be aware of a lot of it coming down the pike right now and we've got Jason Taub Jude on the podcast to talk about it. Jason is a great guy. I have an Adam on the podcast yet, but he's been a big influence behind the scenes on what we do here and he is all up in what's going on at the EPA because he helps write the exams and a lot of other things for our industry. So here we go Jason AUVs, you with EPA regulations, what's going on with them, thanks for coming on the podcast Jason, no problem, thank you for having me Jason's done a whole bunch of stuff and right now, one of the things that I'm most excited about is He's working on the ninth edition of the wracked manual, I've talked about rack, refrigeration and air conditioning technologies.

Many times in the podcast. It's the book that I really learned the trade from so tell us a little bit about that. How you got into doing that? Second. Gage had contact been doing a lot of different things with Sun gage little projects.

They had contacted me about the lab manual. I don't know if you've seen the lab manual that the Eugene and I had put out it came out in August. It's an 800 page lab manual very big book to be used in schools. It has lab exercises and worksheets for HVAC programs concerning all different types of specialties, from airflow to heat pumps, air conditioners, different forms of heating, and the experience was really good and they asked me.

Would I be interested in getting on the team for the big book and the upcoming ninth edition that they're working on and I said, yeah sure no problem and I didn't realize the amount of work that goes into revising one of these books. You'd say: well, it's already written. What is there to do? There's quite a bit to do it's nerve-racking. It does tie up a lot of time.

In addition to that, you are an educator you're, also working with ESCO. So tell us a little bit about that. I'm a Content developer with ESCO. We write certification exams for students for technicians, for instructors, we publish specialized titles and couple them with certification programs and one of the big things that everybody knows us for is the Section 608 certification exam ESCO is a big part of any time.

There's going to be any kind of revision to that exam. Esco is part of that group that meets with the epa to discuss the questions that should or should not be asked. We maintained the question database. We drew up a review book for the exam and we're heavily involved in the new exam that is being used now, one of my jobs there, as well this year.

Finally, after a year of work, there'll be a gas heat textbook that I've written that is coming out January, 1st 2019, if you're an instructor or a teacher or trainer of any kind, there's a guide that goes with it. That has PowerPoint presentations, lecture notes, answers to the questions in the book, there's a lot that goes with it, and there are two or three certification exams that we updated to go along with it awesome. You know that's very much needed for anybody. Who's looked for good training material on the gas side, it's really tough to come by.

So I'm glad you're working on that, but yeah. Today we wanted to talk about specifically the EPA regulations, because you have been involved with that through ESCO and also you actually worked on a mobile application for tracking refrigerant usage. Right, yes, with Robert yeah, our log, so through all that you've got as much experience as anybody and looking at the regulations. Thinking about the changes writing about them all that sort of thing, and I had Jeremy Arling from the EPA on probably almost a year ago.

Talking about all these changes - and I wrote an article on it and all this - I do remember that yeah. If you listen to this, you want to know what we're talking about. You can go back on the archives and just type in Jeremy darling. You can find the podcast you can find the articles about that.

But now I got a take a text message from Jason just a couple months ago and he basically he said, have you seen the recent changes? I think this was back in maybe in August and I'm like no, I hadn't seen it and Jason told me that there's been some big changes that have happened. That's me, peeing you up, you take it from there just kind of describe what went on. I was actually in Washington DC for this at the EPA's building to testify in front of Jeremy and Brian, about our opposition to the direction that the EPA is going. Their proposed ruling was to roll back some of the regulations concerning HFC refrigerants that had just been passed in 2016.

The ruling in 2016 took two years to do to come up with. It took involvement from all kinds of industry stakeholders and was done in good faith to try and clarify and codify everything. One set of rules for all refrigerants. The latest administration and the EPA has been asked to interpret the language a little differently and the proposed rule is to roll back the leak rates, the new leak rates and repair mandates for systems that contain HFCS, HF o --'s things like that.

If it has a zone depleting refrigerant, it would still require the leak repair. The mandatory leak rates, those sorts of things, but if it uses an HF C, they are proposing to roll back any regulation that concerns HFCS, they're, also seeking comment on whether they have the authority to apply any regulations to any refrigerant that does not deplete the ozone Which is very scary? Yes, so this goes back to the Clean Air Act, correct some of the language in the Clean Air Act that was specific to ozone, depletion or ODP, as we know it, and not necessarily GWP. If you want to comment on that, a little bit, there's a lot of people that don't believe in global warming or GWP. But it's not specifically stated there's a point of view that could be taken, that the Clean Air Act was written specifically for ozone depleting substances and that if it's a nanos own depleting substance that it doesn't get covered by 608 ooh the Clean Air Act.

There is language in there that is ambiguous, that can be interpreted either way to either include these refrigerants or not include them, and the issue we're having is, as we get different EPA administrators, they choose to interpret it differently, which then has the trickle-down effect to manufacturers Service technicians, supply houses that have to update and learn all these new rules and regulations and to clarify a little bit more like the Clean Air Act, was initially signed in back in 1990, and so at that time a lot of it was surrounding r12. It was still being used in a lot of different applications back at that point in time, right. That was the big one. Yes, yeah, that was the big one, and so that was a CFC and so at that time there was all this talk about the ozone depletion and that's what's kind of on everyone's radar.

Nobody was really thinking about global warming potential at that time, and so my understanding - and I don't know this fully and I'm no legal expert, but my understanding is that the Clean Air Act has kind of been what everyone's been using to create regulation or the EPA's Been creating regulation using the Clean Air Act and then there was a judge that essentially struck down somebody challenged it. It's challenged. The ability for the EPA to regulate mhf sees like r410a, because the argument was, they have zero ozone depletion potential and there was some court. That said, that's correct, right, yeah.

It was a issue and actually 612 of the EPA, which is the snap ruling and what the snap ruling is is it allows the EPA to certify refrigerants for specific uses. They will say that r22 is certified for use in residential commercial air conditioning refrigeration and basically, what they were doing was D listing refrigerants, like 134, a in 404 a for mobile air conditioning for refrigerators. Things like that and listing certain HF O's to replace them and that's where the lawsuits came about, they said: listen, they don't have the authority to list or D list these refrigerants, let alone regulate them, and then that kind of created this legal trickle-down effect, which happens Sometimes where now the whole thing is up for grabs like okay? Not only does it not apply to this situation where you're listening and delisting, but maybe we don't have the right to make regulation about HFCS at all because they have a global warming potential, but they don't have an ozone depletion potential based on the interpretation of the Original Clean Air Act, that's my understanding. Is that a correct understanding of how this kind of went down? Yes, 6:08.

A specifically mentions class, 1 class 2 substances and things, but it doesn't mention substitutes, however, 6:08 see specifically States substitute refrigerants cannot be vented, and the main argument is that in 608, a which calls for the promulgation of regulations regarding these refrigerants. It wasn't mentioned in 608. A 608 C is the prohibition on venting. You can't let refrigerants out so they're saying while it's illegal to let these refrigerants out, we don't have the right to regulate them in the way that we regulate class 1, which is your H, CFCs and CFCs.

So there's no question that you're not allowed to take refrigerants and vent them. That's not up for debate here. Right right, I mean at least the classes of refrigerants are talking about here. Obviously naturals you can bend but HFC CFCs, a CFCs, H, fos you're not allowed to vent them correct, there's a list of exempted refrigerants and that's where all your natural Phrygians fall on that exempted list cool.

I didn't know there was a actual list of those. So that's something for me to find in post. So that makes sense. So we lived in this world where we haven't been able to vent refrigerants for a long time, but then the EPA came along now with this latest change and said: ok, let's clarify some of this.

So when we say you can't invent here specifically what we mean by that, and so they started adding in leak repair requirements on larger equipment that contains over 50 pounds of refrigerant, which I always have to qualify, because everybody thinks there's all these Grubin legends that exist Around that, and so we kind of all got geared up, and then there was this big change and obviously this change is ticked. You off I'm a lot of other people so clarify why that is. Why isn't it a good thing that just hey free-for-all, eliminate all the rules well like what it comes back to is Section 608 has what's called subpart, F and subpart F has all of the different requirements that were familiar with Technician: Certification, refrigerant reclamation, restriction of sales, The recovery requirement, all these things that we've been doing since we entered the and what they're looking to do are taking comment on is just to rescind all of these subpart F requirements from HFCS, which would give you a scenario where you aren't allowed to vent. The refrigerant but you're not legally required to recover it either.

However, it is allowed to leak into the atmosphere and you're not required to repair it. I mean, if you think, about that situation, what should the technician do or what are they required to do? Got it? So you create a situation where there is something that's illegal, but you give no guidance on how to actually behave in a legal manner. What must be done right? The other one is the technician certification. If they revoke the technician, certification for HFCS, anybody can buy refrigerant.

In any quantity, it's not necessarily a ten pound or 20 pound or a fifty pound without any kind of certification requirement. Jo homeowner can walk into any place in purchased refrigerant, that's dangerous, yeah for several reasons, one of them being. Obviously it's damaging to us as businesses, because now anybody can purchase it, but talk about some of the other, maybe societal or ramifications that can go along with that sort of behavior. One of the big issues we're gon na have is cross-contaminated systems that create all these new mixtures of refrigerants.

That could be a very flammable hazardous dispose of chemical just by mixing multiple refrigerants in a system. The lack of knowledge knowing what to do with this refrigerant leaving tanks in a trunk where you live in Arizona and it's 120 degrees that things going to explode and kill somebody refrigerant huffing, is a major one that nobody likes to talk about right now. The refrigerants are restricted to technicians that have a license, and these people that are huffing refrigerant are forced to go to the systems and push the pin in and you've seen the emergence of these locking caps to stop all of this. This just opens up a whole new avenue for them to buy this refrigerant yes get high on.

I don't get the draw of that, but there are those out there. I mean, and it hasn't been a major problem to now, because it's been under control. We restrict the sales we've got, locking caps, those sorts of things, but we're gon na blow this wide open from the industry standpoint there's almost no way that we can argue that it would be a good thing for the industry. So if it's not a good thing for the industry, a lot of us are going to be unhappy, but also talk about there ramifications on the industry of having all of these changes back and forth that keep happening well.

If we keep making changes for one we're going to be assured for sure less compliance, I can tell you that in 2016, when the regulations were updated - and we came out with the ANU exam and we've put it in place - there are still tons of people out There that don't even know there's a new exam and the more we change these regulations, who's, disseminating this information who's, getting this information out to the technicians and the manufacturers and the distribute they're, not aware of it most people weren't aware of this ruling. It was just a little bit that popped up on the EPA's website, oh by the way, we're gon na do this and nobody was really aware of it. The other thing is the lack of regulations on HFCS may. Have the states start to get involved? Well, if there's no federal regulation that governs this, the state of California is going to do it and Minnesota is gon na do this and Indiana is gon na.

Do that and you're gon na have a regulatory landscape? That's different, no matter what state you're in. If you're in Colorado, you have to do this if you're in California, you have to do this and the manufacturers are going to have to we're going to make this new heat pump. But we can't sell in California, but we could sell it in Texas. So this is our Texas unit, and this is our Colorado unit, because each of the individual states some may not pass any, was at all.

It's gon na vary from state to state, so as technicians we're thinking all right, I'm in this state. I have to follow these rules, but if I go ahead and go over to Colorado or California, then I got to learn all these new rules and they may even come up with their own certifications, individual state certifications. It seems like it's pretty obvious that we don't want these changes in our industry, but who are the winners if these changes do occur like who stands to benefit? It's the industrial process, refrigeration sector of our industry, where there are companies that are less likely to call a service company out and work on their system. They have their own technicians that they keep on staff, they use thousands of pounds of refrigerant and their staff is trained.

They have all their procedures in place, they have their own little program, they do their own record-keeping, they do their own repairs. Charging that sort of thing and they're the ones that are filed for the petition for administrative and judicial review of the 2016 ruling. They represent the IPF, the industrial process, refrigeration, sack they're large companies that are using HFCS in one fashion or another and they're, claiming that this is going to be a financial burden on them and the record-keeping individually is a financial burden and having to retrain that their Technicians that they keep on staff yeah I mean the old saying, is follow the money whenever there's a change with anything or whenever there's anything. That is the way it is there's always generally some monetary driver there, and so what we're saying here is that one of the monetary drivers would be very large companies that do industrial processes, so manufacturing of some sort or food processing, or something like that and they Buy tons of refrigerant - and they don't want to have to deal with all this additional record-keeping and all this additional mumbo-jumbo, because that was one of the big changes, was that you had to repair leaks and nulli.

Did they increase the thresholds or make it a little more stringent, but then they lumped in HFCS with that were previously HF, C's weren't on the record-keeping last right, yes, and the other requirement was that you had to report them to the epa, your leak rates and Things like that, and i don't necessarily think they wanted public how much refrigerant they were actually leaking all right, so i'm gon na take a quick second here. Just to oh, we pause just a wee pause. That's why that's a terrible joke, but i'm not gon na say this to the end. Why do broadcasters have tiny hands? And it's because we pause for station identification? If you like under the age of 40, you won't even get that of it anyway.

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They will make sure to take special care of you. Make sure that you tell them that Brian Brian, with Y J or Esquire sent you all right here. We go back to Jason, I'm gon na do a couple. Devil's advocate questions, so don't be threatened here.

These are just questions anytime. I talk about anything EPA related and I'm sure you get the same thing. I get this like in rush of people who make these politically motivated statements, so I want to get them out of the way in this podcast quick caveat. I do not view this politically, I'm politically active.

I care about politics just like the next guy, but when it comes to my livelihood in my business, I think about this very pragmatically, which is how is this going to affect the industry and the people I care about in the industry? That's really what I care about here, but a couple of the questions that immediately come up. Whenever you talk about dangerous substances, customers buying the kind of thing I've heard, a lot of people say: okay, well, they can buy. Gasoline gasoline is an explosive substance, gasoline something that you don't want to Huff, and nobody has a problem with that. So what makes this different than a lot of other toxic chemicals that people can go out and buy at a store.

If you look at gasoline, you also see criminals use it to start fires gasoline, I would say you taking you put in your car. The application is very simple: your card they make different fuels and the fuel pumps are different sizes. So you can't accidentally put the wrong fuel in your car. They do that on purpose refrigerants.

We know that they go in systems, but what refrigerant goes in? Which system there's so many out there there's only one type of gasoline and only one nozzle fits inside your car. So it's kind of simplified to the point where anyone can do it refrigerants. Aren't that simplified yet, and I would also add that we accept certain risks. Like with gasoline, for example, or maybe, chlorine and swimming pools, things like that, we accept certain risks, because you've built an entire world on top of being able to add gasoline to your car.

Even though yes, there are people who take it and create fires with it and do things they shouldn't do, but we're talking about something here. That already is a controlled substance, like you mentioned, there's huge variety in its application and you're going to add in lack of safety or an unsafe condition where there previously was a fairly safe condition, and why the heck would you want to do that? Those are kind of my thoughts to stack on top of what you said. Yeah, that's a good point. So another thing that always comes up is people will say: well, okay, fine! We do the right thing here in the US, which I mean.

I think a lot of us in the trade know that the right thing actually isn't done as often as we would claim. It is right, but we do the right thing here in the US, but you see these emerging countries and they're venting like crazy. So why does it matter if we vent when everyone else is venting anyway? That's a good point. If you do see the emerging countries, you're gon na see a lot of those refrigerants being vented.

However, if you also look at the industrialized countries, they're already moving away from HFCS and a lot of places and we're the only country that isn't moving away from HFCS, they're using flammable refrigerants, like our 32 and propane and butane they've, been using them for years and We're just now starting to get into it. So when you look at the industrialized countries we're well behind them, so we can give ourselves a pat on the back and say yeah we're better than these emerging countries, but we're not as good as the other industrialized countries. When it comes to this sort of thing, I'll agree with that and I'll also add in something else here which is going to be controversial and I'm going to get nasty emails about it. But I'm just hey.

Look it's one guy's opinion whether you believe in global warming, the way that it's talked about in the science community or not. Okay, we can agree that taking stuff that is essentially a chemical that does not naturally occur. It's something that we're creating in huge quantities and venting it into the atmosphere. Just isn't a good thing to do.

Let's just all agree to that, whether or not you believe in global warming or not and yeah, and I wish that everybody would do a little more research to be a little more thoughtful and their approaches to these things. But whether you do or not taking chemicals and venting them into the atmosphere is not a good thing and anytime we can create processes that prevent us from doing that, or we move towards things that are more natural. I think we can agree that. That's a good thing and the same things truth food.

So you may not know all of the ramifications of eating some weird chemical, but we can pretty much agree that if it didn't come from nature, it's not naturally occurring is probably not the best thing to stick in our body, so we've kind of been through enough Trial and error to recognize that, so don't send me the emails and don't give me the messages, don't leave me the Facebook messages saying it's all a scam follow the money. Patents by I've heard it all. Okay, I've heard it all at this. Let's think about.

What's best for the environment and, let's think about what's best for the industry, and I think most of us can agree that, what's going on with all this, erratic changes really isn't good for anybody. At least anybody that we care about in the industry. Maybe there's some big players who are making monetary decisions and whatever that's my take on that, so there anything you would add to my week take there. No that was a good argument.

One of the things I you don't have to necessarily believe in climate change or global warming, but think about the air that you're breathing and how clean it is. There's hundreds of millions of pounds of refrigerants sitting in systems across the country and they're all being phased. The HCFCs are anyway, being phased over to HFCS or hf, o --'s, and if there are no regulations regarding these refrigerants you're talking about hundreds of millions of pounds of refrigerants that are gon na be allowed to just leak into the atmosphere. And this is the air that we're going to breathe.

If you look at the downtown areas of all the major cities, there's these huge units and roofs everywhere, grouped together in one type place and if they're all legally allowed to be leaking. What's the air quality going to be look like, I don't know if you've ever seen those pictures of China with the smog and everyone wearing the masks, I mean I'm like I'm playing the devils. I don't want to get to that point where okay, listen, we've created this problem. Now we have to fix it.

We already have the safeguards in place to prevent that problem. Just from a breathability standpoint, people that have COPD asthma breathing issues like that when you get into areas where there's large concentrations of refrigerant that's legally allowed to leak - and, let's be honest, these refrigerants aren't that expensive. It is cheaper to a point for owners of equipment that are leaking to just keep recharging the system until the tipping point is reached where the cost of the refrigerant is now more than the cost of the repair and they're gon na keep doing that until the You know it's a business decision, it's a monetary decision, it's cheaper for me to buy a 150 dollar tank of refrigerant to put into here, then then shut the whole system down for two or three days. While we find this leak and repair it and pay.

Three. Four five grand to have it repaired: it's just cheaper to pound refrigerant in there exactly and the changes that were made - or I should say the clarifications that were made in 2016 - they weren't drastic. I mean it wasn't like. Yes, they made some standards about leakage rates for HFCS, but they weren't drastic.

I mean system had to be leaking significant enough amount that any of us in the field wouldn't just leave it leaking for good technicians, and so the standards that were put in place were essentially to say, look, don't take giant systems and let them just keep leaking Refrigerant out, at least on that side and then there of course there was a lot of other pieces to that it from a record-keeping standpoint and so on and so forth. But they were all designed to sort of be practical applications to what the rulings already were, which comes down to the at it's very basic form. You're not allowed to vent, and the EPA has always stood that leakage in good faith is not the same as venting, but we all know the guy who's made the joke of haha it's leaking when you know that it wasn't a leak or it was caused by Him or he pulled a Schrader out halfway or whatever the case may be, and that's exactly what the EPA is trying to prevent is people who aren't making good-faith efforts to reduce league rates and to prevent venting and if there's no requirements for it I mean, and Then it's up to the technician to decide what to do. If there are no okay, here's the law, you can't vent it.

Alright, that's it! That's the end all right. What should I do, whatever you want so long as you don't vent it right, and that also puts the liability on the technician a lot too, and so maybe your employer doesn't have to provide you with the necessary tools and it all just gets thrown back on The tack and none of that's good for the technician and none of it's good for the industry and when there isn't clarity. So, yes, it's better to work towards clarity, and I think to your point, when you were talking about some emerging societies, do we want to have the air quality that some of these emerging countries have, and the answer is no and whether or not you believe in Global climate change, or not, let's just work together - to reduce what we're putting in the atmosphere - that's not natural, because I think a lot of people today who make all these exotic claims about conspiracy theories and all this stuff they're the same ones who would have been? Ok with the deforestation that happened to the eastern part of the United States and even creeps into the West that we ended up having to have some regulation, because it's undisputed that there was a point in US history where we were exploiting our natural resources and we Needed some regulation to help prevent complete deforestation and really unhealthy conditions for people, and when you talk about shared resources, it's very different than a lot of people. I have a pretty strong, libertarian streak in me politically, and that is fine dandy with what people do with their own stuff, but when you start inventing stuff into the atmosphere, you're affecting other people and so things that you do that affect the health of others.

Well, that really is undisputedly the proper role of government. I mean you have to have government in place because you can't have people putting chemicals into the water supply or doing things that could hurt us or our children that everybody agrees to some extent. It's just a matter of degree how much regulation there should be, and if you're gon na have regulation, it should make sense. It needs to be clear.

Otherwise, nobody wins, especially nobody in our industry. I used the example. There was in Phoenix a homeowner back in 2016. 2015, you could buy tanks of 410 a on Amazon and he purchased a tank and for those technicians out there, they're gon na say let him buy it.

They're just gon na screw the system up and make more work. For me, this person had purchased a tank of 410, a left it sitting on the deck in his backyard. His neighbor was in the pool with his kids and the tank ruptured and exploded, and it actually caused injury to the neighbor and his daughter who happened to be in the swimming pool twenty yards away so again go ahead. Let him buy it.

They'll screw up there. Yeah, but they also may hurt people other than themselves that you may hurt the people around you so, like you said, I believe the government has to step in and protect others from this type of thing. I would also add in that a really good, practical argument that you made already is the mixing issue, because we all know what a pain-in-the-butt that is you recover refrigerant that you believe is our 22. You know you did it the right way and you get it back and then the reclamation facility says no, it's we're not gon na pay, you anything or we're gon na charge you something because the mix isn't pure and you're like.

I know it was pure. We run into this all the time we cannot get in most cases, much above 90 % purity and it isn't our practices, it's that we're running into mixed refrigerant conditions and when you add homeowners and di wires into the mix. Oh, my gosh, it's just gon na get worse and that's also something we don't want. That's what I was gon na say you're running into those mixtures now and there are restrictions in place.

Can you imagine what that's going to look like with no restrictions in place? Yeah, when you can go down to your local Walmart and pull a tank of our 410 a off the shelf, it's like that's, not something that we want. One of the things I'd like to point out is this is gon na cost jobs as well. When I was in Washington, I listened to a person addressed the EPA. He was from Texas and he was part of the Association of reclaimers down there, and one of the subpart F requirements is that refrigerant must be reclaimed before it can be resold or reused.

And if they rescind the subpart, F requirements, that reclamation requirement also goes out the window and his testimony was to the effect of listen. The reclaimers are not going to survive on reclaiming CFCs and HCFCs without the requirement to recover or reclaim hf seized. He said if you cut that out no one's going to bring 4:10 a back in to be reclaimed they're not going to survive on just reclaiming the old refrigerants. The ODP refrigerants they're gon na lose 50 to 60 percent of their business.

They're gon na lay people off closed factories. That sort of thing I didn't even realize that until he went up there to speak, say listen, we employ five, six, seven thousand people in just our state alone. Each different state has thousands of jobs where refrigerant is being reclaimed. If you don't have to reclaim HFC refrigerants who's, gon na bring in 410 a 134 a 404 a if they don't have to you just reuse it in another system.

Oh, I got some 410 a in this tank I'll just use it in my next job, I'll put it in that system, because the reclamation requirement would be gone and the reclaimers are not going to survive on the dwindling supplies of CFCs and HCFCs alone. There'll be massive layoffs in that industry. Oh you make a good point yeah. So that would be something if it subpart, F was removed and you had no regulation other than you can't vent.

Then you could potentially take refrigerant out of one system and put it right into another system and have correct amination yeah. That's a big problem and it's gon na cost jobs as well yeah as well as profitability for a company where now you're competing with chucking a truck who's, pulling out contaminated refrigerant from one system and putting in it at five bucks a pound into the next and The customer thinks it's the same, which is another thing. We don't want right. That's another issue, you're putting new refrigerant in you're, recovering refrigerant and reclaiming it like you're supposed to, and the next technician is selling you the r22 that he took out of the system.

He replaced this morning yeah exactly you paid 400 bucks for your tank and he didn't pay anything. He recovered it out of a system that he replaced yeah all things we don't want to have happen. That's the reason why I wanted you to come on because at this point, there's not a whole lot we're gon na do this round! Comments already closed. I'm sorry that I didn't get to this sooner.

I really should have, but I think the industry and the industry's voice on this is going to drive what happens moving forward. So if there is a rule, change we're going to be able to change it again, really quickly as long as we're vocal about it about what it is that we hope to have happen, and I'll just be clear about my stance on this. My stance is, there needs to be clarity in the rules, and the rules need to be specific enough, that a technician knows what they are supposed to do and what they're not supposed to do that to me is the most important thing, and we also want to Protect the industry so that we don't have potentially all these different refrigerants on the marketplace or anybody can just go out and buy them, because it's that just isn't good for anybody. It really isn't there's nobody who can argue that it's actually good for an end-user.

A customer anyone to have all these huge amounts of chemicals out there that anybody can just get and start messing around with and cross contaminating and everything else. That is correct. So for the update. The current ruling that they're proposing is to withdraw the leak rates from HFCS, and during this comment period they were asking for comments on just rescinding all of subpart F, based on their interpretation of the Clean Air Act.

Now we're expecting a ruling. The comments closed November 15th and there should be some sort of a ruling within 45 days of that, once that ruling is posted, we'll know better, which way they decided to go with it. They could, in this ruling, rescind all of it and just say: listen if it's an hf c or an hf o doesn't hit deplete the ozone, it doesn't concern us or they might just rescind the leak rate or they may postpone it, there's no indication of which Way, they're gon na go with this, but I will tell you that the ruling is technically supposed to be out within 45 days of closure of comments. I don't know that we'll get that with the changeover coming in Congress and things like that.

I'm sure there's gon na be some reappointing of officials. The current head of the EPA is andrew wheeler and he's acting administrator and they're trying to put him in his permanent administrator. So he has to be approved, and i don't know if that's gon na hold up the ruling or not, but we should be hearing something by the end of the year about direction and which way we're gon na go with this or they're gon na go with It yeah - I spoke to Jeremy just yesterday and so that's his early December and it spoke to me in person at the hardy conference and I'm always careful. I don't want to put words into his mouth and, of course, Jeremy does not speak for the EPA, and he was clear about that, but I have a sense that I don't think we're gon na see subpart F fully rescinded.

I would be shocked if that does happen. That'll be great. If we don't have that whole thing rescinded. If we do, then I think as an industry, we need to be vocal, pretty quick, so you keep an eye out for that.

I'm gon na have Jason on and maybe try to get Jeremy on again after we have the ruling and we know where everything stands so that way we can kind of reinterpret and in this episode I didn't want to be too specific about everything. Because again it's all up in the air, so we don't know, but I just wanted to cover an overview of what's been going on, so that you all can be aware. A couple of key things to mention is that even in the new standard - because this is the most common question I get, there was no need for recertification nobody's talking about needing to recertify for your EPA certification that wasn't part of it before it's, not anything anybody's. Talking about mostly what we're saying is that the rules, change and the new test questions obviously need to change, and, of course, that's all these changes are really wreaking havoc on your ability to write books.

I bet yeah those that are making arguments against the record-keeping requirements as an undue stress or creating extra work. There are so many apps and programs that were developed for refrigerant, tracking and you're talking about a dollar dollar 99 amp up to you know a hundred hour app where you can scan tanks in by barcode and track weights and everything there was so much software. That was developed to make this easy, and I can't see how the record-keeping requirement could be a burden on anyone. If you have a cellphone, you probably have numerous apps in your phone.

There are free ones. There are ones that cost a dollar or two dollars three dollars that allow you to accomplish all of the record-keeping requirements with very little effort on your part. As far as writing goes a lot of the big textbooks. We cover the EPA regulations and the issue we're having it.

The only way to really correct this is to have Congress. Do something that's in writing right now. The Clean Air Act is open to interpretation by whatever administrator comes, and it was written years and years ago and hasn't been amended or updated cents. Every time we come out with a new ruling, that's based on an interpretation of the existing Clean Air Act.

No language has really been added, and the only way to come up with a permanent solution is to have Congress passed, something there's a few acts that are pending that may be called there's one called the American manufacturing act, there's a bunch, the kigali amendment that the Rest of the world is ratified. The point is that each time there's gon na be an administration change. There is the possibility for a change in interpretation and then again a change in regulations. So in a lot of these text, books, you're gon na see specific EPA regulations no longer be listed just because the costs associated with having to reprint all of these text books with the updated information is in the millions of dollars.

So you'll see general best practices listed and then for exact regulations. Go to the EPA's website for the most up-to-date regulations regarding this refrigerant or that refrigerant. These books won't be able to have the updated regulations printed right in them, because, if they're going to be changing going forward, as the country gets more polarized left right, middle we're gon na have these things keep changing until there's a permanent solution. You're, not gon na see the regs printed in books, anymore, yeah, which is really frustrating from an academic standpoint, because the goal is again to have technicians who know how to do their job properly and they're properly trained to do it that way, and hopefully the books And tests that technicians take will properly reinforce those things and when it's constantly changing it's very tough to do so, I think, as an industry, we just need to come together and say: look we may not like all of it.

We may not even agree with all of it, but for business for us to do our jobs effectively, it's more important that we have stability and when you have an unstable business climate, where things just keep changing and regulations keep changing. Then the only people who went out the lawyers yeah, the lawyers do great when regulations keep changing and everybody's fighting in court and all that kind of stuff, and that's not what we want. We want to be able to do our jobs. You want to know what we're supposed to do.

We want the professionals to be in the industry and those who are gon na hurt people or cause trouble for us to stay out of the industry. I think we can all be pretty clear on that. No matter what your political leaning might be right, that's the one thing I've done a couple of interviews with newspapers and HVAC newspapers, and that's the one thing I stress is listen. This is not political, I'm not going to make it political politics divides everybody, and we can't be divided on this.

The only way that we're going to be heard is, if we're all together on this, we can't let this become political. It's got to become our baby. This is our business and we can't have it be fractured like this. We can't let a well I'm a Democrat or aa, I'm a conservative or I'm a liberal.

You know what that has nothing to do with the regulations or our industry in general. We are all HVAC technicians, we install systems, we service systems and we want to do it the best we can, with the knowledge that we're doing the right thing and if we can have regulations that are simplistic that are uniform across the board, so that I don't Have to have a reference manual? Okay, what refrigerant is this? Okay, here's the regulations for this refrigerant. Well, what refrigerant is this one? Well, that one has no rag, so you you, don't need a reference manual to look up what the regulations are for the specific refrigerant in your system. If we could have a unified and simplified set of regulations that just apply to all refrigerants, no matter what's in them, it makes it a lot easier for us to do our job and it makes a safer environment yep absolutely.

I agree and I think we all support clean air and water, and so that's something that we can all get behind as well. No matter where you stand on all that other science stuff, we all want clean air and water and we all want to be world leaders in the US, but the way that we do things so. Having said that, thank you, Jason, for coming on. I appreciate everything you do for the industry, for those of you who don't know Jason or haven't had a chance to interact with him.

Are you gon na be at ahr by any chance? I will in January? Yes, okay great, are you gon na be at any particular booth or anything you're, just gon na be wandering around? I will be at the green mechanical council booth, okay, great! So if you wan na stop by visit Jason, he is one of the good guys in the industry he's one of the people who I definitely look up to for sure. Jason's been very kind to me over the last few years as I've started, HVAC school he's, giving me great feedback on things and so make sure to look him up, make sure. Once his book comes out and the new rack manual comes out that you go out and buy it, it's a great value for, what's in it and again Jason. Thank you for everything you do for the industry right now.

I would say the same about you. You do a lot for our industry getting information, good, reliable information out to technicians before. If you wanted information, you got it from school and once you graduated, it was you're out in the field you're on your own. You provide technicians, students alike, with good valid information.

In a way, that's easy to digest and you keep people up-to-date on things and I think the industry needs more people like you all right man. Well, thank you. So much means a lot coming from you and have a great rest of your day and I'm gon na see you soon at the educators conference. So I'm looking forward to that all right.

I will talk to you big thanks to Jason, for taking the time to talk to us. I know that that is a controversial episode. If I said anything that upsets you, please just let it go. You know that I come from the field and then I'm Faria I'm free and not again, yeah.

Hopefully that was educational without getting you too fired up. But again, thank you to Jason for everything he does for the industry and thank you to you for working in the field. I just spent a couple days with a bunch of people at the hearty conference and the hearty is an organization that, for reps and for distributors, manufacturers, those sorts of things and man. I can tell you that I prefer people who work out in the field.

I'm not saying I didn't like the people that hard, even there's a lot of really nice people. There had a lot of nice conversations, but I prefer those of you who live by the sweat of your brow every day and make a good honest living, not that I'm saying they don't make an honest living. Okay, don't get the wrong idea here, but those of you in the field gave me a fresh appreciation for you appreciation Perea as we say. So thanks for doing what you do and thanks for listen to this podcast and if you haven't downloaded our new app, you can find the hvac school app on both Android and iOS.

Even if you listen to the podcast through iTunes or some other way, the HVAC school app is another easy way to do that and there's some other additional benefits to listening on the app which you'll find out when you download it. So give it a try and tell me what you think give me a review if you hate it, give me a one-star I'm up for it, I'm ready for some one-star reviews. If you hate my guts, then by golly tell the world, you should speak truth to power. Alright, thanks for listening, we will talk to you next time on the HVAC school podcast and yes, the dad joke was in the middle on this one, all right doc.

You soon, thanks for listening to the hvac school podcast, you can find more great HVAC our education material and subscribe to our short daily tech tips by going to HVAC our school comm. If you enjoy the podcast, would you mind hopping on iTunes or the podcast app and leave us a review? We would really appreciate it. See you next week on the HVAC school podcast.