This episode of the HVAC school podcast is made possible by generous support from testo and carrier. Thank you to test2 and carrier for partnering with HVAC technicians all across the country, and helping provide this free training. And now the man whose body odor has been deemed at ozone-depleting substance according to the Montreal Protocol, Brian or yes, thank you for that pretend James Earl Jones. My initials aren't vo for nothing, we'll just leave that there.

So today, on the podcast we have Jeremy Arling from the EPA and Jeremy was kind enough to come on. I really appreciate it. I also appreciated Nesta Jones from the EPA for helping make this possible and we're going to talk about some of the some of the rule, changes that are upcoming, most of them going into effect on January 1st 2018. He answers a lot of really important questions.

Things you're going to want to know just a quick reminder: we talked about HFCS, which our modern refrigerants contain. Hydrogen fluorine and carbon refrigerants like r410a are 438, a are 407 C 134a. Those types of refrigerants there's a lot of changes coming to how HFCS have to be sold and handled a lot of the same stuff that you're already practicing, but they just kind of put some more detail into it. And then he also talks about HCFCs and CFC.

So CFCs would have been like old, refrigerant, R, 12 or r11. Hcfcs would be refrigerants, like r22 and so there's some changes in all the different categories and so you're going to want to listen carefully to the differences. Another thing that you're gon na want to listen carefully to is that there are differences, especially in leak, repair requirements for equipment that is under 50 pounds. So a lot of the questions.

I've been having all kinds of arguments lately and I don't intend to it's just like they fall in my lap, where technicians are misunderstanding, because they're applying the rules that apply to systems that contain over 50 pounds to small residential equipment and the rules are not the Same there are some new rules for record-keeping requirements for equipment that is kind of the small residential equipment, so you're going to want to listen for that, but most of all just pay close attention. Another thing is the difference between ODP ozone depletion potential, which you know, r22, has a zone, depletion potential and GWP global warming potential, which r410a still has global warming potential. So there's some differences there, and so when the EPA talks about global warming, potential and ozone depletion, potential they're talking about two different things and different types of refrigerants have different air is that they fall into as far as regulatory rules. Anyway, I'm not going to keep boring you with this.

I just wanted to point out that please pay attention to the details, because otherwise you could walk away with this. You hear some little thing and think that it applies to an area that it doesn't apply to or you could miss one of the new rules. If you want to see the final rules go to ETA gov forward, slash Section 608 epa.gov forward, slash Section 608. I didn't want you to miss that we're going to say it again at the end here we go, we've got Jeremy Arling from the EPA.

My entire career. I've feared the EPA it's kind of like you know, looking in your rear-view mirror and see if a police officers following you, but in meeting Jeremy, I found him to be a very likable guy and I appreciated the presentation that he gave at HVAC excellence, and so I'm excited to have you on Jeremy. Well, thank you for having me. If you wouldn't mind, tell us just a little bit about yourself and what you do for the EPA sure, so I have been in the EPA stratospheric protection division for about 10 years now I have mainly worked on regulations, phasing out or providing exemptions to the phase-out Of various ozone depleting substances, these include refrigerants and soya fumigants and most recently I have been the refrigerants Team Lead.

Where I manage the Section 608 program, how does one get into that line of work in the first place? You just got me curious. Ah. Well, I have a law degree and also a background in biology, so it has worked out well that I've worked on things like pesticides and kind of combining those two interests working on regulatory policy. Anyone who's a technician.

You know working out in the field in our trade, so essentially the entire audience is familiar with the 608 rules and that regulate the recovery, reclaim discharge of refrigerants into the atmosphere. That's our concern is we want to make sure that we're following the laws, and so there are some changes. Some of them have already actually taken effect, but we're mostly interested in the ones that are that are going into into place in January, 1st of 2018 or there abouts, and there are some different timeframes. The first question that I get a lot from technicians is their concern that they're going to have to be recertified for Section 608.

So can you speak to that yeah? We not requiring a recertification of currently certified technicians, those that have been certified who took the test? Ten years ago, they can continue to practice. What we are doing is we are updating the test Bank of questions that we provide to those testing organizations so that it covers the modern refrigerants and the new, updated provisions of the regulation. But currently certified technicians wouldn't have to come back and retake that test for any of you out there who are worried that you're going to have to take it again. You do not have to, but that actually makes this sort of thing that much more important, because the rules are changing.

So the things that you knew when you took your EPA exam say 10 years ago, you're not gon na be able to lie on what you learn. Then you're going to have to relearn some of these things. So can you briefly review the changes to the rules that relate specifically to the sale and recovery of HFCS? So a common one for the technicians out there who are listening would be say, r410a sure yeah. So it has always been illegal to vent our for 10a or any HFC refrigerant under the venting prohibition.

In the Section 608 Clean Air Act provisions. What this rule does is specify the standards and practices that would have to be performed by the technician. To avoid being considered venting of those refrigerants and those standards and those practices are exactly the same ones that have existed for the ozone depleting refrigerants like r22 and r12 for the last 20 years. Our goal is really to try to treat all commonly used refrigerants in the same manner.

Specifically what that means is that, starting January 1st 2018, you would have to be a Section 608 certified technician in order to open an HF C appliance like homeowners for 10. A split system you would have to use epa certified recovery, and/or recycling equipment, there are certain evacuation levels that would have to be, plants would have to be pulled down to and those are the same again standards and evacuation levels and equipment that have always been required For the ozone depleting refrigerants, you would also in order to purchase refrigerant, have to be Section 608 certified, and the distributor would have to verify that you are 6 1 608 certified technician when you purchase that refrigerant and again, the same manner in weight currently works today. For r22 got it, so if I understand correctly, we're really just providing some additional clarity to the practices that largely have already been practiced to, let you know the proper recovery of r410a and and that sort of thing, but we're just providing a little bit more regulation And clarity to what those standards are is that is that a fair way of summarizing that yeah, that's correct, got it okay, good. So a common question we see is whether it's illegal to recharge equipment containing less than 50 pounds of an HCFC.

So, for example, r22: is it illegal to recharge a system containing less than 50 pounds, and then will this change under the new rule? To answer your first question: no, it is not illegal to recharge an appliance that contains an HDFC refrigerant or even a CFC refrigerant. We have those that are still you know, 20 years old that are working just fine. Our goal has never been to drive people out of existing equipment that is functioning properly. They can continue to be recharged in serviced and kept in service.

What will change is that the availability of the r22 or other HDFC refrigerants will go down. As the phase-out you know fully takes effect safer r22 that would be in 2020 and at that point, any existing r22 equipment. You know they can still be recharged, but they would have to be charged with recovered recycled, reclaimed. R22 at that point, and so the the cost of it is going to continue to go up, and so there's a practical element to this, which is you know, just recharging equipment that has known leaks, is first of all not a great technical practice, but also is Going to make less and less financial sense as we move forward, that's correct.

Yes, I mean technicians should make the effort to repair any leaking appliance, but the requirement the leak repair requirements apply to those that are 50 or pounds 50 pounds or more of refrigerant charge. But just because an appliance is under that 50 pound threshold, the owner is still going to want that system to be. You know repaired if possible, because you know if you don't have enough charge you're operating it less efficiently. It's not working as it should and again yeah you're, adding more refrigerant that is potentially pretty costly.

So obviously, if you have a leak, if you have a leaking, a piece of equipment makes good technical sense and just good sense, all in all to that repaired and get it working properly. Can you tell us more about the new reporting requirements for the replacement, / decommissioning of systems containing five pounds of refrigerant or more I'm sure? So I will start off just by saying that there are no reporting requirements for technicians. There used to be a single reporting requirement when technicians purchase recovery and recycling equipment, and this rule did away with that reporting requirement. What you are talking about here is a record-keeping requirement for the disposal of appliances and what we are hoping for are records that are generally kept during the normal course of business, when a technician would be decommissioning or disposing of an appliance.

So I kind of put the records into three different bins, the first one you know for each appliance. It would be the technicians company's name, the location of the equipment, the date of the recovery and the type of recover of refrigerant recovered for each appliance, and that might be one that you know might not have normally been kept in the normal course of business. But it's not too difficult. A technician should know what type of gas they're recovering from a system there's.

Also, then, a monthly total of the refrigerant that has been recovered and on a transactional basis, the amount of refrigerant that is transferred for reclamation or destruction and that's by refrigerant type got it and I actually just learned something. So it's not so much reporting it's just record-keeping and then is this for all recovery, then so even recovery in the process of service. You also want to have that as part of the monthly record-keeping and again, obviously, that's a good practice anyway. So this is something that everybody should be doing as it stands, but just to be clear on the EPA stance on this, it is: is that monthly, just on systems that are taken out of service or is that on all recovery? This is a question that we actually we've gotten a few times now, where we understand that technicians will be taking evacuated, refrigerant and putting it into a recovery cylinder, and you know it may be from a servicing event.

It may be from disposal so that monthly total could include both, but what it should include at the bare minimum is the amount that has been recovered from dispos'd equipment got. It makes sense okay, so it's not like the EPA's gon na be saying: oh, my goodness, you recovered more than right right now I was taken out of exposed equipment. Yeah right makes sense, yeah and that's actually a good distinction to make. You don't have to separate the records.

But the point is: is that what's going to be easiest is for you just to keep a good tally on what you're bringing in and then also what's going out on a monthly basis? In addition to keeping exact records of, what's taken out of specific pieces of equipment as you remove it from service right, something that I discovered at HVAC excellence was a question as to who has to keep those records. And there was maybe a sense that the technician themself you know his him/herself has to keep the record, but it is the company that that technician works for so Acme HVAC company would be required to keep those records, not the individual technician. Similarly, if convenience store, you know chain, hires, Acme recovery, it's not the convenience store who's required, they're, not the ones who have hired that technician. As an EPA certified technician, the responsibility would be there to help support your organization in keeping those records, but ultimately the the burden is going to be on the organization itself by the sounds of it.

Yeah, that's correct, and, and you know the reason why we found this to be an important element of the rule. Change is that we have estimated about a third of the refrigerant. That's out there in installed. Equipment are in these sort of split system, unitary a/c equipment pieces.

You know like your heat pumps and your residential air conditioners, and it is the largest single use of refrigerant in the u.s.. This is an area where we hear that proper recovery isn't happening. So this was one of those elements where we want to make sure that technicians are doing the right thing. Those who are doing the right thing and have most of these records already so part of this is is just to say, hey look.

We see that maybe this isn't being done. Those of you who are already doing it great, but if you're not. This is a good way to kind of keep some tabs on that and at least be able to. If you have someone to you who could be an offender to go and say, okay, let's have a look at these records.

Potentially, I'm not that I'm putting it nothing, I'm putting a any words in your mouth, but it makes sense that that would that would be something to consider what are some of the changes. That text should be aware of when recharging leaking systems containing over 50 pounds of refrigerant, and is this apply to both hcfc and HFC refrigerants, so that, broadly, very quickly summarize the leak repair program which for a lot of equipment owners. This is sort of the meat of the Section 608 program, really briefly, appliances. You know that leak over a certain threshold rate have to be repaired within 30 days and if it cannot be repaired or if the owner chooses not to repair, then the appliance has to be retired or retrofitted within a year.

And then there are some extensions to those 30-day and one-year repair and replacement deadlines. So that's that's the leak repair program in a very small nutshell and it occupies a lot of you know. Space and the Code of Federal Regulations wanted just to sort of walk through that process. All of the updates to the leak repair provisions will take effect starting January 1st 2019.

This is the furthest out date that we have in these updates, because we recognize that the complexity of the leak repair provisions so by that date, that is, when the requirement to repair leaks in appliances that use HFCS would take effect in general. Most of these changes are intended to make sure that the repair is conducted properly, the first time to avoid that requirement to retrofit or retire the appliance first, just the threshold leak rates, those we lowered from 35 % for industrial process, refrigeration and commercial refrigeration down to 30 % and twenty percent respectively and then comfort, cooling appliances, we've lowered the threshold rate from 15 % to 10 %. Second, what we added to this rule is that, when that threshold leak rate has been exceeded - and there is the requirement to do the repair within 30 days - we're requiring that a 608 certified technician conduct a leak, inspection as part of that repair. So previously there could be any repair done on any part of the appliance that the owner or the technician think may have been the cause of the leak rate exceedance.

But you know there's no way to really know this helps to make sure that the appliance paired correctly, that all the potential leak points are identified and hopefully, if an appliance owner knows where the leaks are, that they choose that opportunity to repair as many as are Feasible in that 30-day window in the past you could have said: oh we've repaired a leak and then be really vague about it. We put new caps on it. You know it's something like that. You could fix a leak, but not the leak.

Whereas now you're saying you fix the leak because 608 certified technician needs to take a look at the piece of equipment and say all the known leaks have been repaired at this point. Not just a potential leak, basically right and we don't require the repair of all leaks. We require that the system be repaired so that it no longer leaks above that threshold rate. But if you're going in to do a repair, it makes sense to repair what you can.

You know beyond that single point, perhaps that caused the exceedance. Another thing that is new with the updated 608 leap repair provisions is that, as Section 608, certified technician would have to conduct verification tests to ensure that the repair worked. So this is a current requirement for industrial process. Refrigeration and we've extended that requirement to comfort, cooling and commercial refrigeration appliances as well.

Not only are we trying to treat similar refrigerants similarly, but also these large appliances. Similarly, so the to verification tests, one is the initial test. That's done before you add refrigerant back into the system after the repair is complete and then a follow-up verification test which is done after the appliance is fully charged and operating at its normal characteristics and conditions. We get a question frequently about how much time has to pass between the appliance being repaired and up and running, and that follow-up verification test and there's no minimum timeframe.

As long as that appliance is up and running as it normally would be. You can conduct that test. What we do say is that it should be conducted within 10 days of it being repaired, got it and so you're actually testing the point of the of the leak repair at that point. With that verification, correct, yes, so just from a practical standpoint, it would be something like you make the repair.

Then you do a standing. Nitrogen do. Am i chronic vacuum test which are both verifications of no leakage? Then you run it for say five days and then you go back and do say an electronic leak detection of that exact point to ensure that it's not leaking yeah, that that could be one of the ways that you would do. It definitely example of one way that it could be done.

Okay got it with these new requirements of the owner or operator of the appliances required to keep those records, showing that the verification test has been done and performed successfully. Similarly, the leak inspections met. Those were performed and any leaks were indicated in those records, and so while the owner and operator is required to keep those records, you know it is a the technicians responsibility to provide those records to the owner and operator. That is something that we heard through the public comment process that we do in regulations.

They have a difficult time frequently getting those required records from technicians. So that's another message that you know I want to put out there that technicians need to be providing these records and the regulation actually explicitly spells that out too. Okay, so another question: I'm getting a lot when I talk about the the changes or really any time. I talk about recovery.

This comes up the recovery of flammable refrigerants, like propane, which is our 290 and isobutane. Can you speak to any requirements related to, especially when it comes to these natural refrigerants sure? Yes, so EPA has been approving more uses for propane and isobutane and other flammable refrigerants in almost every situation. Epa has approved them for these small, hermetically sealed appliances that get charged at a factory like refrigerators and window units and water coolers. It also includes vending machines and ice machines for propane and isobutane, and EPA has also exempted these refrigerants from the venting prohibition.

So what that means is that all of the various standards and requirements that you know we discussed here wouldn't apply to the service of those appliances using that refrigerant there may be other substitutes, I'm thinking r32. Perhaps that may be used more widely in the future. That are flammable that are not exempt from the venting prohibition. There's a UL safety standard for the flammable refrigerants and what we did was we required that any recovery or recycling equipment that is intended for use with a flammable refrigerant, be up to the that standard to ensure that flammable refrigerants can be safely recovered and that went Into effect at the beginning of 2017, so that is currently out there that would again before recovery equipment that is specifically designed for flem award right right and so there's a couple different considerations here.

Just because something is flammable doesn't mean that it's a natural refrigerant. That's exempted from the venting prohibition, so there's refrigerants that are flammable that still require recovery, and when they do, you have to have specific recovery equipment. That's you well rated for that purpose. On the other hand, you have the question that comes up.

All the time is about our 290 understand. You can't take our 290 and put it in a piece of equipment. You know the regular piece of equipment that it's not designed for it's not allowed for that purpose. The only allowable situations are in very very small quantities and in that case it's not illegal to vent, but there are certainly safety questions that you need to be thinking about when you're, whenever you're going to event something that could catch on fire.

So that's that's my commentary there, but I, but I think it goes along with with what you're saying there. So you've got to know the refrigerant that you have whether or not it is or is not exempted from the from the venting requirements, and if it does need to be recovered, then you need to make sure that your recovery machine is ul rated for that yeah And I might add that you know you mentioned propane and I discussed propane where it is. You know lawful to be used where it does make sense as a good substitute. It's got great refrigerant properties, it's got a low GWP, it doesn't deplete the ozone layer.

We've seen propane being marketed, as you know, r22, a sort of a drop-in replacement for r22 in residential split systems, and, as you mentioned, you don't want to be putting propane into a system. That's not designed to handle a flammable refrigerant. There have been instances where appliances have exploded on on the technicians themselves and led to serious property damage and personal harm. So what this rule did - and there was a companion rule that EPA issued.

At the same time, they made clear that the use and the sale of our 22, a and other you know flammable refrigerants - is illegal for retrofits and that's something that's come up a lot over the years is just how dangerous this is, and a lot of it Is marketing in other word I say that exact marketing that you referred to where it said hey. This is a direct drop in basically and and so that's a no-no. Don't do that? That's that's not good propane has it has its uses out there, but currently it's just in in very, very small units that are designed specifically for for that. Can you comment on how the EPA intends to enforce a 608 in general and then maybe some of these sure? Yes, so EPA has brought a number of cases to enforce the Section 608 provisions.

In the last few years, we've brought a series of cases against supermarkets and cold storage, warehouses and other owners of large appliances that have not been following the venting prohibition requirements. We've brought a series of cases against scrap yards for failing to recover refrigerant from disposed appliances or failing to keep the proper records. We have been helping out on other cases where copper thief, for instance, would cut the lines and steal the copper from you know. In our 22 system, multiple cases there, where we were able to enforce the venting prohibition against that theft, I mentioned our 22, a the flammable refrigerant and it being illegal to sell, distribute or use.

We have taken action against a couple of the major distributors of Network. Don't even want to call it a refrigerant of that gas, it's propane in a repair, exactly right, right and then you know we're also revoking certifications for testing companies and reclaim errs that have not been meeting our standards. So we have an active enforcement program, but I know that you know what your listeners are most interested in our technicians and we hear from the technician community. Very interestingly, they ask us, please, please enforce against the bad actors in the sector, because those who are following the requirements of the law are put at a disadvantage by those who are just sort of cutting a line, or you know not taking the time to evacuate.

The refrigerant one of the goals of this 608 update was to make the rule more enforceable. We've tried to build on previous cases that the EPA has brought mentioned, some of those venting cases, for instance, to make it easier for us. If we choose to do so, you know successfully enforce the venting prohibition in sort of the technician space, the point being that whenever there's a rules like this that are laying down by the federal government, just the fact that maybe it hasn't been enforced in one particular Way doesn't mean that it can't be at any point so be cautious to follow the rules to the best of your knowledge and ability at all times, for those of those technicians out there who really want to understand the rule, which is actually gon na, be fairly Important seeing as how it is changing from from what it was that you learned when you took your EPA certification in the first place, what would be the best resource or resources that they should go to to learn more about? So we have tried to provide as many resources as we can on our website. Wwe PA gov, /, Section 608, there's a what's new box there that has a link to the rule, some sector-specific fact sheets.

So if you're a technician or if you're, an appliance owner or if you're, a reclaimer, there's a FAQ sheet for you and then there is a slide deck of the PowerPoint presentation. That summarizes the major changes to the rule, and I would I would definitely start there as a go-to resource for sort of the more technical information about the changes to the rule. Well, I really appreciated Jeremy. It's actually been surprisingly educational.

Even for me there's some. You definitely gave some great perspective on it, and - and I know it's certainly something that you don't have to do, but I'm very thankful that you and the EPA we're willing to to take the time to help educate technicians in this way, because I think it makes A huge difference, and - and I know I know at least I appreciate it and I know a lot of technicians out there who do appreciate you know. Thank you. I mean I appreciate being able to speak to as many people as possible really and I'm glad that you're able to provide another venue and mechanism for us to explain the rule.

Thank you. So much have a great to give you too once again big. Thank you to both Jeremy Arling and enesta jones, as well as the entire epa for being willing to come on and do this podcast. I sent an email request and they got back to me, they're, very responsive and since that time, Jeremy has also been willing to clarify some other questions that I had one of those questions being a question that one of the listeners had about mixing refrigerants and essentially What Jeremy came back and said, is you know when you mix refrigerants you're, creating a new refrigerant that has not been approved by the EPA and all refrigerants have to be approved, and so it's against the rules since against the rules to mix refrigerants, you can't take Say our 438, a our are 407 C and put it on top of our 22, that's already in a system because you're creating something that is completely new.

Besides the fact that you not going to be able to really know what's going on inside that system, when you mix - because you don't know the exact proportion that you're mixing and you create all kinds of problems, besides the fact that the equipment manufacturers - don't you to Do it so mixing refrigerants, not a good idea when people talk about drop-ins, what they're saying is - and I don't like the term drop-in at all, but what they're saying is you can take the r22 out and put in our 438 a or our 4 or 7 C or something like that, and but you still have to remove all of the r22 properly recover and then have it recycled. So that's the that's the procedure there, but anyway again once again, thank you for Jeremy for doing that. Thank you to the EPA for being willing to clarify the rules. Like we've already said twice before.

If you want to see the whole thing, you can go to epa.gov forward, slash Section 608. If you have any questions for me, you can email me if you'd, like Brian, be rya n at HVAC, our school comm, but what I would really suggest doing if you have questions technical questions, is join our private Facebook group on Facebook. If you go to Facebook, look up in groups, HVAC school will join there and that way, not only can I help answer any questions you might have, but then our whole group of happy contributors can also help you, because I certainly have some areas that I know Some things, but there's a lot of areas that I'm weak as well. So if you have a pretty much any question, you can ask it there, and hopefully one of those guys will go to help you out.

Thank you. So much see you next time on HVAC school 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.