Title VI - Stratospheric Ozone Protection - Refrigerant

Last updated by ess-home on 12/15/2008

U.S. Environmental Protection Agency (EPA) - United States

Refrigerant Regulations/Standards

Title VI is a program of the United States Clean Air Act Amendments (CAAA) that regulates stratospheric ozone-depleting substances – CFCs and HCFCs. Section 608 of the Amendments places responsibility on stationary air conditioning equipment owners, technicians, contractors, refrigerant manufacturers, wholesalers, and reclaimers/disposers. Section 609 addresses mobile vehicle air conditioning (MVAC) – automobile AC. Specific refrigerant use, recovery/recycling, and reclamation requirements are addressed under 40 CFR Part 82 subpart f.

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Management System and Data Management Implications

Owners and operators of air conditioning or refrigeration systems are responsible for maintaining three years of service records on systems/circuits that contain 50 pound or more of CFC or HCFC refrigerants. Additionally, they must document and calculate each system's refrigerant charge, leakage rate, and repair within 30 days. Each system must have an EPA-defined Duty Type and Leak Rate threshold assigned depending on what they are cooling. Refrigerant recovery is required for all sizes of systems.

Most Title V Air Permits require compliance with these rules as a General Condition.

Refrigerant-specific policies and procedures that are communicated to all affected employees - including contractors – will help organizations meet the requirements and demonstrate good faith efforts to comply.

Automated refrigerant data management reduces complexity and eases the compliance burden:

• Work order style data entry familiar to facilities groups
• Facility-based inventory of air conditioning systems classified by Refrigerant type and charge
• EPA Duty Type and automatic Leak Rate alert for each system
• 30-day Repair Alert function
• Reminder functions for mandated repair verification tests
• Technician certification alert for each system
• Refrigerant inventory and 5-year Hydro test reminder for recovery cylinders
• 1500 preset drill-down reports and graphs
  
  
  • quick identification of problem leaking systems
  • at-a-glance compliance check-up for all systems
  • rapid response to EPA demands for records
  • useful as budgeting tool, which systems to prioritize

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Fast Facts

Jurisdiction	United States plus Territories
Applicability	Facility and Appliance owners/operators, technicians, HVAC/R contractors, refrigerant manufacturers, distributors, and reclaimers.
Regulatory Driver	Title VI of Clean Air Act, as amended in 1990. Section 608/609 of Clean Air Act. 40 CFR Part 82 subpart f
Promulgating Entity	U.S. EPA
Enforcing Entity	U.S. EPA – 10 regional offices
Entity Summary	http://www.epa.gov/ozone/strathome.html
Regulatory Text	http://www.epa.gov/air/caa/title6.html
Regulatory Submissions Required	Service Records to be maintained for three (3) years at the facility owner/operator, available for review by EPA inspectors. Records retention may be longer due to Title V requirements, other regulatory agency requirements, or company policy. Self-disclosure may be required in certain cases.

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Case Studies

• Beale Air Force Base
  Receives Recognition for Outstanding Refrigerant Management AND Saves $45,000
• Linc Facility Services
  Achieves Zero Refrigerant Violations and ISO 14001 Certification

More Information

For details about how the IHS solutions can help your organization comply with Title VI, call 800.289.6116 or email us.