EPA 608 Certification and the Refrigerant Rules Homeowners Should Know

Section 608 is part of the federal Clean Air Act. EPA's refrigerant regulations under it sit in 40 CFR Part 82, Subpart F.

Those regulations apply to any person who maintains, services or repairs appliances containing class I, class II or non-exempt substitute refrigerants. Class I and class II are the ozone-depleting types, and a non-exempt substitute is a replacement refrigerant, such as an HFC, that the rules have not exempted. They also reach people who dispose of such appliances and people who buy, sell or offer to sell those refrigerants.

Since January 1, 2018, the technician certification section has applied to technicians working on appliances with any non-exempt substitute refrigerant, such as HFCs, not only to ozone-depleting refrigerants. EPA has also said its 2020 rule did not rescind the refrigerant management provisions that had been extended to non-ozone-depleting refrigerants. For a homeowner, the practical result is that newer refrigerants are not a loophole: the same certification, recovery and reclamation expectations follow them.

The certification rule is written around the task, not a job title. It says any person who could reasonably be expected to violate the integrity of the refrigerant circuit while maintaining, servicing, repairing or disposing of a covered appliance must pass a certification exam offered by an approved technician certification program. If a job could involve opening the circuit where the refrigerant lives, the person doing it needs to be certified.

EPA has developed four types of certification, matched to the kind of equipment.

Type I: small appliances

Persons who maintain, service or repair small appliances must be certified as Type I technicians. A household refrigerator is the familiar example.

Type II: medium-, high- and very-high-pressure appliances

Persons who maintain, service, repair or dispose of medium-, high- or very-high-pressure appliances must be certified as Type II technicians. Small appliances, motor vehicle air conditioners (MVACs) and MVAC-like appliances are excluded from this type. For a homeowner, this is usually the type that matters, because a residential split-system air conditioner or heat pump is high-pressure equipment.

Type III: low-pressure appliances

Persons who maintain, service, repair or dispose of low-pressure appliances must be certified as Type III technicians. You are unlikely to meet low-pressure equipment in a house; it is more common in large commercial buildings.

Universal certification

Universal technicians are certified for all of the appliance types above. EPA notes that the core test must be taken as a proctored exam to earn Universal certification, and that a core test taken as an open-book exam cannot be used toward it.

What the credential tells you

EPA states that Section 608 certification credentials do not expire. That changes the useful question. It is less about whether a technician's certification is current and more about which type the technician holds and whether the person doing the work holds it. Section 608 certification belongs to individual technicians, not to the company that employs them.

Apprentices

Apprentices are exempt from the certification requirement, provided a certified technician closely and continually supervises them while they perform any maintenance, service, repair or disposal that could reasonably be expected to release refrigerant from an appliance into the environment. The supervision is a condition of the exemption. An apprentice working alone on your system is not covered by it.

In most cases, no. EPA states that only Section 608 certified technicians can purchase refrigerants intended for use with stationary refrigeration and air-conditioning equipment, with limited exceptions.

The regulation itself is written from the seller's side. It says no person may sell or distribute, or offer for sale or distribution, any class I or class II substance or, since January 1, 2018, any non-exempt substitute for use as a refrigerant unless a listed condition is met. Two of those conditions are that the buyer is a certified Type I, Type II, Type III or Universal technician, or that the buyer employs at least one such technician and provides proof of that to the seller.

Section 609 is a different certification. EPA states that Section 609 certified technicians cannot purchase refrigerants intended for use with stationary equipment, regardless of container size.

Why sales leave a paper trail

Wholesalers that sell ozone-depleting or substitute refrigerants must retain invoices that show the purchaser's name, the date of sale and the quantity of refrigerant purchased. The record ties each sale to a named buyer.

What the restriction does not cover

The sales restriction has exceptions that matter to homeowners. It does not apply to refrigerant contained in an appliance with a fully assembled refrigerant circuit, or in an appliance component. That exception describes refrigerant that is already inside equipment; it does not describe refrigerant sold on its own.

It also does not apply to refrigerant that a certified technician or an apprentice charges into an appliance during maintenance, service or repair. In other words, when a contractor adds refrigerant to your system as part of a repair, the restriction is not what stands in the way. What governs that job is the certification rule above: who is allowed to do the work.

If someone offers you refrigerant

If anyone offers to sell you refrigerant for your home system, or to leave some behind for you to add yourself, treat it as a reason to ask questions. The regulation covers selling and distributing refrigerant, and its exceptions turn on who the buyer is or who is charging it.

Refrigerant venting means letting refrigerant escape into the air on purpose instead of capturing it. The regulation says no person maintaining, servicing, repairing or disposing of an appliance may knowingly vent or otherwise release any refrigerant from it into the environment. EPA describes the same rule as a prohibition on intentionally venting ozone-depleting substances or their substitutes while maintaining, servicing, repairing or disposing of air-conditioning or refrigeration equipment.

The exceptions are narrow. The regulation exempts specific substitutes in specific end-uses. EPA says only three types of releases are permitted, and one of them is the release of substitute refrigerants that EPA has determined do not pose a threat to the environment. Exemptions EPA has described include isobutane (R-600a) and R-441A in household refrigerators and freezers, and propane (R-290) in stand-alone retail food refrigerators and freezers. None of those describes a central air conditioner or heat pump.

What this means when your system is opened

Two practical points follow. First, any job that opens the refrigerant circuit should include a plan for the refrigerant. EPA states that anyone removing refrigerant from an air-conditioning or refrigeration appliance must evacuate it to a set level using certified refrigerant recovery equipment before servicing or disposing of the appliance. Second, the prohibition covers disposal as well as repair. When an old system is taken out, the refrigerant inside it falls under the same rule.

EPA also states that all used refrigerant must be reclaimed to industry purity standards before it can be sold to another appliance owner. Recovery, which takes the refrigerant out of your system, is a separate step from reclamation.

These are fair questions for any contractor, and a contractor who works within the rules above should be able to answer them plainly.

1. Which Section 608 certification do your technicians hold? For a home air conditioner or heat pump the answer should be Type II or Universal. Certification belongs to the individual, so it is fair to ask about the technician who will actually do the work.
2. Will an apprentice be on the job, and who is supervising? An apprentice may work on refrigerant only under the close and continual supervision of a certified technician.
3. What happens to the refrigerant if the system has to be opened, or if it is being replaced? The answer should involve recovering it with certified recovery equipment, not letting it out. The venting prohibition covers disposal as well as repair.
4. Is the company licensed, and what is the license number? Section 608 certification is held by individual technicians. A Florida contractor license is a separate credential, issued by the state's Department of Business and Professional Regulation. Ask about both.
5. How will the refrigerant charge be checked when the job is finished? A charge should be verified by measurement, not by feel or rule of thumb, and the readings should be written down.

Blume Mechanical Service, LLC is a Class A licensed Florida mechanical contractor, license CAC-1822618, and is fully insured. Our refrigerant work is done by EPA Section 608 certified technicians. We handle design-build, maintenance, repair, installation and replacement for residential and commercial customers in Pinellas, Hillsborough and Pasco counties, and we are based in Belleair Bluffs, Florida.

We commission systems with measured static pressure, airflow and refrigerant charge, and we document the results.

The rules summarized on this page come from these EPA and eCFR pages.

• 40 CFR 82.161, technician certification
• 40 CFR 82.154, prohibitions (venting and sales restriction)
• 40 CFR 82.150, purpose and scope
• EPA: Section 608 Technician Certification Requirements
• EPA: Refrigerant Sales Restriction
• EPA: Prohibition on Venting Refrigerants
• EPA: Regulatory Updates: Section 608 Refrigerant Management Regulations