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EPA’s Refrigerant Management Program: Questions and Answers for Section 608 Certified Technicians

General Questions:

Is section 608 certification required to service, repair, and install refrigeration and air-conditioning equipment?

Yes. Certification is required for anybody who in the course of maintenance, service, or repair of an appliance could be reasonably expected to violate the integrity of the refrigerant circuit and therefore release refrigerants into the environment. 

Is section 608 certification required to dispose of appliances?

Section 608 technician certification is required to dispose of appliances, except for small appliances (an appliance that is fully manufactured, charged, and hermetically sealed in a factory with five pounds or less of refrigerant), motor vehicle air conditioners (MVACs), or MVAC-like appliances.

Can my employer send another person to purchase refrigerant for me?

Yes. You or your employer can send a coworker to purchase refrigerant, or designate somebody else to receive delivery on your behalf. The purchasing account holder is the buyer, and anyone purchasing refrigerant under that account is allowed to conduct the transaction, provided that the account holder can demonstrate they are a certified technician or currently employ a certified technician.

What type of documentation do I need to purchase refrigerant?

Refrigerant sellers must verify that the buyer is a certified technician or currently employs a certified technician. Documentation such as a copy of a technician certification card, a technician certificate issued by the certification program, or documentation that demonstrates that the buyer currently employs a certified technician (if the buyer is an employer) is acceptable.

What should I do if I believe that someone is using my technician certification card to purchase refrigerant without my permission?

If you believe someone is using your technician certification card to purchase refrigerant without your permission, contact your refrigerant supplier and let them know that this person is not your employer or employee, and is not purchasing refrigerant for your use. You can also report possible violations to EPA.

Can I sell used refrigerant that I recover from customers’ appliances?

No. Before used refrigerant can be sold it must be reclaimed by an EPA certified reclaimer. Depending on the type of refrigerant and the level of contamination, EPA certified reclaimers and some distributors may offer money for it.

However, you may charge used refrigerant that you recovered from an appliance into another appliance owned by the same customer. 

Am I required to keep a copy of my certification?

Yes. As a section 608 certified technician who installs, services, and/or disposes of appliances, you are required to keep a copy of your certification at your place of business and keep it until three years after you are no longer operating as a technician.

Do I need to carry my certification card with me when I am performing refrigerant work?

No. EPA does not require you to carry your certification card with you when servicing appliances, although some customers may inquire about whether you have proof of certification. You may want to consider keeping a picture of your certification on your phone in case asked by a customer.

Is a section 608 certification required to pull the “heel” or residue out of an empty cylinders of refrigerant?

No. Cylinders that store or transport bulk refrigerant are not considered appliances.

Can I use my certification card to purchase refrigerant for a person that is not certified?

No. It is a violation of EPA’s regulations to sell, distribute, or offer for sale or distribution a refrigerant for use in an appliance, unless the recipient is, or employs, a certified technician. 

Questions on Servicing Appliances with 50 or More Pounds of Ozone-Depleting Refrigerant:

What is the difference between a leak inspection, an initial verification test, and a follow-up verification test?

A leak inspection is the examination of an appliance to determine the location of refrigerant leaks. Methods include ultrasonic tests, gas-imaging cameras, bubble tests, or the use of a leak detection device operated and maintained according to manufacturer guidelines. Methods that determine whether the appliance is leaking - but do not determine the location of a leak - such as standing pressure/vacuum decay tests, sight glass checks, viewing receiver levels, pressure checks, and charging charts are not leak inspections, and must be used in conjunction with methods that can determine the location of a leak.

An initial verification test is a check to make sure that repairs were successful before refrigerant is added back into the appliance. This test is performed after the leak has been located and repairs are made, but typically before the appliance (or isolated section) has been recharged and returned to normal operating conditions.

A follow-up verification test is done within 30 days of the appliance's returning to normal operating characteristics and conditions, except in cases where sound professional judgment dictates that these tests will be more meaningful if performed prior to the return to normal operating characteristics and conditions.

Leak inspections, initial verification tests, and follow-up verification tests are only required when an appliance with 50 or more pounds of ozone-depleting refrigerant exceeds the threshold leak rate. They are not required for smaller appliances, or appliances that do not leak above the threshold rate, or appliances containing substitute refrigerant, such as HFCs. 

What information am I, as certified technician, required to provide to customers?

If you are servicing appliances normally containing 50 or more pounds of ozone-depleting refrigerant, you must provide the customer an invoice or other documentation showing the amount of refrigerant added to the appliance.

When you conduct leak inspections on appliances that contain 50 or more pounds of ozone-depleting refrigerant, you must provide the customer with documentation that includes the date of inspection; the method(s) used to conduct the leak inspection; a list of the location(s) of each leak that was identified; and a certification that all visible and accessible parts of the appliance were inspected.

When you conduct initial or follow-up verification tests on appliances that contain 50 or more pounds of ozone-depleting refrigerant, you must provide the customer documentation of the dates and results of all initial and follow-up verification tests. The records must include the location of the appliance; the date(s) of the verification tests; the location(s) of all repaired leaks that were tested; the type(s) of verification test(s) used; and the results of those tests.

While technicians are not regulatorily required to provide other records, such as the full charge of the appliance, and the results of leak rate calculations, your customers are required to maintain that information for appliances that contain 50 or more pounds of ozone-depleting refrigerant. Owners and operators of AC and refrigeration equipment may contract technicians to perform these services. You should consider having an upfront conversation with your clients about whether they expect you to provide any additional records.

Learn more about the other reporting and recordkeeping requirements under the refrigerant management regulations.   

Questions on Servicing Appliances with 5 to 50 or More Pounds of Ozone-Depleting and Substitute Refrigerant:

What records am I required to keep?

Technicians who dispose of mid-sized appliances with 5-50 pounds of refrigerant (for example, residential split systems), must keep records of:

· The location, date of recovery, and type of refrigerant recovered for each disposed appliance;

· The quantity of refrigerant, by type, recovered from disposed appliances in each calendar month; and

· The quantity of refrigerant, and type, transferred for reclamation or destruction, the person to whom it was transferred, and the date of the transfer.

Can my employer keep the records for me?

Yes. While it is the technician’s responsibility to ensure that records are kept, the technician’s employer can keep records for their employees.  

Is there a required format for the records on refrigerant recovered from mid-sized appliances prior to disposal?

No. These records may be kept in the format most convenient for the technician. They may be kept electronically or as paper records. Records must be kept for three years.

Is technician certification required to install an R-410A mini-split?

Yes. Adding or removing refrigerant from a mini-split as part of installation, and/or connecting or disconnecting hoses or pre-charged lines requires a section 608 technician certification. Activities reasonably expected to violate the integrity of the refrigerant circuit include but are not limited to: Attaching or detaching hoses and gauges to and from the appliance; adding or removing refrigerant; adding or removing components; and cutting the refrigerant line.

Questions on Becoming a Certified Technician:

Can students in refrigeration or air conditioning courses perform work on appliances in a classroom or school laboratory prior to obtaining certification?

Yes. Performing laboratory course work prior to certification is allowed. However, training performed on the job, and training that is not part of formal, course-driven laboratory work is considered maintenance, service, repair or disposal, and requires an individual to be certified, or to be a registered apprentice. Apprentices must be closely and continually supervised by a certified technician.

Can apprentices work on appliances prior to obtaining certification?

Apprentices can work on appliances prior to certification if they are closely and continuously supervised by a technician that has the appropriate section 608 certification(s) for the type of appliance that is being serviced. To qualify as an apprentice, you must be currently registered as an apprentice in maintenance, service, repair, or disposal of appliances with the U.S. Department of Labor's Office of Apprenticeship (or a State Apprenticeship Council recognized by the Office of Apprenticeship). A person may only be an apprentice for two years from the date of first registering with that office.

Does EPA require an "R-410A Certification”?

EPA requires a section 608 certification regardless of refrigerant type based on the type of appliance (Type I, Type II, Type III, or Universal). However, EPA does not have a certification that is exclusively focused on R-410A. Because R-410A differs from R-22 in several respects, including operating pressure, some trade schools offered classes and certifications for R-410A specifically. These are not equivalent to a section 608 certification.

Other Information on the Section 608 Program for Technicians

More information is available on the following topics: