National Refrigerant Recycling and Emission Reduction Program

Recordkeeping and
Reporting for the 608
Refrigerant Management
Program

March 8, 2017

U.S. Environmental Protection Agency
Stratospheric Protection Division
Office of Atmospheric Programs
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Recordkeeping and Reporting for the 608 Refrigerant Management Program

I. Introduction
The following guide describes the recordkeeping and reporting requirements of the Section 608
Refrigerant Management Program. These requirements are applicable to refrigerant reclaimers,
refrigerant wholesalers, technician certification programs, small appliance disposal facilities, technicians,
owners/operators of appliances with charge sizes of more than 50 pounds, manufacturers of small cans
of MVAC refrigerant, and refrigerant recovery/recycling equipment testing organizations.
This document is intended to assist entities with their recordkeeping and reporting obligations. This
guidance does not supersede the Code of Federal Regulations (CFR). Please consult the CFR for the
complete list of requirements.
This guidance and the requirements in 40 CFR part 82, subpart F do not apply to certain refrigerants. As
of March 2017, the list of exempt substitute refrigerants includes:


Carbon dioxide in any application;



Nitrogen in any application;



Water in any application;



Ammonia in commercial or industrial process refrigeration or in absorption units;



Chlorine in industrial process refrigeration (processing of chlorine and chlorine compounds);



Hydrocarbons in industrial process refrigeration (processing of hydrocarbons);



Ethane (R-170) in very low temperature refrigeration equipment and equipment for non-mechanical
heat transfer;



Propane (R-290) in retail food refrigerators and freezers (stand-alone units only); household
refrigerators, freezers, and combination refrigerators and freezers; self-contained room air
conditioners for residential and light commercial air-conditioning and heat pumps; vending
machines; and self-contained commercial ice machines, very low temperature refrigeration
equipment, and water coolers;



Isobutane (R-600a) in retail food refrigerators and freezers (stand-alone units only); household
refrigerators, freezers, and combination refrigerators and freezers; and vending machines; and



R-441A in retail food refrigerators and freezers (stand-alone units only); household refrigerators,
freezers, and combination refrigerators and freezers; self-contained room air conditioners for
residential and light commercial air-conditioning; heat pumps; and vending machines.

The most up-to-date list of substitutes that are exempt from the Clean Air Act Section 608 program can
be found at https://go.usa.gov/xXaZU.

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Recordkeeping and Reporting for the 608 Refrigerant Management Program

II. Summary of Recordkeeping by Appliance Charge Size
5 pounds and Under

Between 5 and 50 Pounds

50 pounds and Over

Technician

None

Yes- Only for disposal of
the appliance

Yes- Must provide records
to the owner/operator
that are generated by the
technician

Owner/Operator

None

None

Yes

Appliance
Disposal Facility

Yes

None

None

III. Recordkeeping and Reporting Requirements by
Entity
All records that must be maintained under the Section 608 program must be available onsite at the
respondents' place of business for a minimum of three years (or longer if specified). Records may be
kept in hard copy or electronically. Electronic records may be off-site but must still accessible through
the internet or other means at the specified site (e.g., site of the appliance or site of the disposal
facility).
When reporting is required, EPA encourages entities to submit reports electronically to
[email protected]. Entities may also submit reports by mail to: Section 608 Program Manager;
Stratospheric Protection Division; Mail Code: 6205T; U.S. Environmental Protection Agency; 1200
Pennsylvania Avenue, NW; Washington, DC 20460.

1) Refrigerant Reclaimers
A. Records
Refrigerant Reclaimers must maintain the following records:


Records of the analysis conducted to verify that each batch of reclaimed refrigerant meets the
necessary specifications in Appendix A of 40 CFR part 82, subpart F.



Records on the names and addresses of persons sending refrigerant for reclamation and the
quantity of each refrigerant (by ASHRAE type) sent for reclamation.

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Recordkeeping and Reporting for the 608 Refrigerant Management Program
Additional Guidance: These requirements are specified in 40 CFR 82.164(d). These requirements are
currently effective for ODS refrigerants and will apply to substitute refrigerants starting on January
1, 2018.

B. Reports or Other Submissions to EPA


To become an EPA certified reclaimer, a reclaimer must submit a one-time application to EPA. The
certification must include the name and address of the reclaimer and a list of equipment used to
reclaim the refrigerant to the required standard, and to analyze the refrigerant to ensure it meets
these specifications. The certification must also state that the reclaimer will:

 Reclaim refrigerant to all the specifications in Appendix A of Subpart F that are applicable to that
refrigerant;

 Verify that each batch of refrigerant reclaimed meets these specifications using the analytical
methodology prescribed in Appendix A;

 Release no more than 1.5 percent of the refrigerant during the reclamation process;
 Dispose of wastes from the reclamation process in accordance with all applicable laws and
regulations; and



Maintain records and submit reports.

Additional Guidance: EPA has not developed a specific form for reclaimer applications.


Annual reports noting the total annual quantity of material (the combined mass of refrigerant and
contaminants) by refrigerant type sent to them for reclamation, the mass of refrigerant reclaimed
by refrigerant type, and the mass of waste products produced.
Additional Guidance: These reports are due by February 1. EPA encourages reclaimers to use the
Excel form found at https://www.epa.gov/section608/major-recordkeeping-requirementsstationary-refrigeration for this annual report. This requirement is specified in 40 CFR 82.164(d).
These requirements are currently effective for ODS refrigerants and will apply to substitute
refrigerants January 1, 2018. This means that the first report required for substitutes will be due in
2019.



Notify EPA within 30 days of a change in business management, location, or contact information.
Additional Guidance: This requirement is specified in 40 CFR 82.164(c).

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Recordkeeping and Reporting for the 608 Refrigerant Management Program

2) Refrigerant Wholesalers and Distributors
A. Records
Any person or company that sells or distributes, or offers to sell or distribute, any refrigerant must
maintain the following records:


Refrigerant sales records that indicate the name of the purchaser, the date of sale, and the quantity
purchased as well as records indicating that the purchaser is a certified technician (as applicable).



If the purchaser is not a certified technician, the wholesaler must maintain documentation that the
purchaser is employed by a certified technician.
Additional Guidance: These requirements do not apply to sales of refrigerant that are exempt from
the sales restriction, including small cans of MVAC refrigerant. These requirements are currently
effective for ODS refrigerants and will apply to substitute refrigerants starting on January 1, 2018.
This requirement is specified in 40 CFR 82.154(c)(3).

B. Reports or Other Submissions to EPA
EPA does not require the submission of any reports or other documents.

3) Technician Certification Programs
A. Records


Records of the names and addresses of all individuals taking the tests, the scores of all certification
tests administered, and the dates and locations of all testing administered.
Additional Guidance: These records must be retained indefinitely. This requirement is specified in 40
CFR Part 82, Subpart F, Appendix D.

B. Reports or Other Submissions to EPA


Prepare a one-time application to become an approved technician certification program. The
application will verify:

 Ability to produce multiple versions of examinations for each test site;
 Sufficient internal capacity to process the scoring and the accompanying documentation; and

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Recordkeeping and Reporting for the 608 Refrigerant Management Program

 Ability to ensure the confidentiality and security of test questions and answers.
Additional Guidance: EPA has not developed a specific form for technician certification program
applications. This requirement is specified in 40 CFR Part 82, Subpart F, Appendix D. For questions
on the application process, please contact [email protected].


Publish online a list of technicians certified through the program, including:

 First name, middle initial, and last name of the technician;
 Technician’s city of residence when taking the test;
 Type(s) of certification received; and
 Date each certification was completed.
Additional Guidance: This requirement does not apply to Federally-run programs. This list must be
updated at least annually. Programs must provide notice to technicians that such information will be
published online and allow technicians to opt out of being included. This requirement is specified in
40 CFR 82.161(b)(6).


Report to EPA every six months on the pass/fail rate, by test Type, and the total number of
technicians certified by that program.
Additional Guidance: Reports are due by January 30 and June 30. EPA encourages technician
certifying programs to use the form found at https://www.epa.gov/section608/majorrecordkeeping-requirements-stationary-refrigeration for this report. This requirement is specified in
40 CFR Part 82, Subpart F, Appendix D.



Organizations that stop certifying technicians must transfer their records to another certifying
program or EPA. Organizations that receive records from technician certification programs that have
ceased operations must inform EPA within 30 days of the records being transferred.
Additional Guidance: This requirement is specified in 40 CFR Part 82, Subpart F, Appendix D.

4) Small Appliance Disposal Establishments
A. Records
Any person or company that is the final disposer of small appliances must maintain the following
records:

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Recordkeeping and Reporting for the 608 Refrigerant Management Program


Copies of signed statements attesting that refrigerant has been recovered prior to the disposal of
each appliance. The signed statement must include the name and address of the person who
recovered the refrigerant and the date the refrigerant was recovered; and/or



Copies of contracts from a supplier of multiple appliances that refrigerant will be recovered prior to
delivery at the disposal establishment or had been properly recovered prior to receipt by the
supplier.
Additional Guidance: This requirement is specified in 40 CFR 82.155(c).

B. Reports or Other Submissions to EPA
EPA does not require the submission of any reports or other documents.

5) Technicians
A. Records
All certified technicians must maintain the following records:


A copy of their Section 608 certification card must be maintained at their place of business.
Additional Guidance: This requirement is specified in 40 CFR 82.161(a)(4). This requirement is
currently effective for ODS refrigerants and will apply to substitute refrigerants starting on January
1, 2018.



Records on the disposal of appliances with charges between 5 and 50 pounds which include:

 Company name, location of equipment, date of recovery, and type of refrigerant recovered for
each appliance;

 Total quantity of refrigerant recovered from such appliances each calendar month, by
refrigerant type; and

 Quantity of refrigerant transferred for reclamation or destruction (by refrigerant type), the
person to whom it was transferred, and the date of transfer.
Additional Guidance: Technicians are not required to keep records on the disposal of appliances
with a charge larger than 50 pounds. However, monthly totals may include refrigerant recovered
from appliances with 50 or more pounds of refrigerant. There is no need to segregate refrigerant
recovered from the different sized appliances if cylinder weighing is the preferred method of
determining the monthly total. This requirement is effective January 1, 2018. This requirement is
specified in 40 CFR 82.156(a)(3).

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Recordkeeping and Reporting for the 608 Refrigerant Management Program

B. Reports or Other Submissions to EPA
EPA does not require the submission of any reports or other documents.

C. Third Party Reporting
Technicians must provide the following records to customers:


For appliances that have a charge of 50 pounds or more of refrigerant, service invoices to
owners/operators with:

 The identity and location of the appliance;
 The date and type of service performed;
 The part of the appliance being serviced;
 The name of the person performing the service; and
 The quantity and type of refrigerant added (or removed in the case of disposal).
Additional Guidance: These records must be provided for all appliances that have a charge of 50
pounds or more. This requirement is effective January 1, 2019. Until that date, technicians must
provide service invoices that at a minimum indicate the quantity of refrigerant added. This
requirement is specified in 40 CFR 82.157(l).


For appliances that have a charge of 50 pounds or more of refrigerant, records of leak inspections:

 Date of inspections;
 Method(s) used to conduct the leak inspection;
 A list of the location of each leak that was identified; and
 A certification that all visible and accessible parts of the appliance were inspected.
Additional Guidance: These records only need to be provided for appliances leaking above the
threshold rate. This requirement is effective January 1, 2019. This requirement is specified in 40 CFR
82.157(l). EPA has not developed a sample form for such inspections.


For appliances that have a charge of 50 pounds or more of refrigerant, records of all initial and
follow-up verification tests:

 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
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Recordkeeping and Reporting for the 608 Refrigerant Management Program

 The results of those tests.
Additional Guidance: These records only need to be provided for appliances leaking above the
threshold rate. This requirement is effective January 1, 2019. This requirement is specified in 40 CFR
82.157(l). EPA has not developed a sample form for such tests.

6) Owners/Operators of Appliances with Charge Sizes of 50 or More
Pounds
Until January 1, 2019, the previous recordkeeping and reporting provisions still apply. The required data
items are specified in 40 CFR 82.166. After January 1, 2019, the revised reporting and recordkeeping
provisions at 40 CFR 82.157(l) and (m) (as presented below) will apply.
EPA’s regulations do not require owners/operators to maintain any records relating to appliances with
less than 50 pounds of refrigerant.

A. Records
Owners and operators of appliances containing 50 or more pounds of refrigerant must maintain the
following records:


Records related to determining the full charge of an appliance, including:

 The identification of the owner or operator of the appliance;
 The address where the appliance is located;
 The full charge of the appliance and the method for how the full charge was determined;
 If using an established range for determining full charge, records must include the range for the
full charge of the appliance, its midpoint, and how the range was determined; and

 Any revisions of the full charge, how they were determined, and the dates such revisions
occurred.
Additional Guidance: This requirement is specified in 40 CFR 82.157(l)(1).


Service invoices with:

 The identity and location of the appliance;
 The date and type of service performed;
 The part of the appliance being serviced;

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Recordkeeping and Reporting for the 608 Refrigerant Management Program

 The name of the person performing the service; and
 The quantity and type of refrigerant added (or removed in the case of disposal).
Additional Guidance: Technicians are required to provide these records, but owners/operators are
required to maintain the records. Service invoices are not required for appliances with a charge of
less than 50 pounds, even if larger appliances are present at the same facility. This requirement is
specified in 40 CFR 82.157(l)(2).


Records indicating the leak rate of the appliance, and the full charge used to calculate that leak rate
Additional Guidance: This record must be generated every time refrigerant is added to the
appliance. This requirement is specified in 40 CFR 82.157(l)(2).



Records from leak inspections triggered by the leak repair requirements.

 Date of inspections;
 Method(s) used to conduct the leak inspection;
 A list of the location of each leak that was identified; and
 A certification that all visible and accessible parts of the appliance were inspected.
Additional Guidance: These records are only required for appliances leaking above the threshold
rate. Technicians are required to provide these records, but owners/operators are required to
maintain the records. This requirement is specified in 40 CFR 82.157(l)(3).


Owners/operators using an automatic leak detection system in lieu of leak inspections must
maintain the following records:

 Records regarding the installation and the annual audit and calibration of the system; and
 A record of each date the monitoring system identified a leak and the location of the leak.
Additional Guidance: This requirement is specified in 40 CFR 82.157(l)(4).


Owners or operators must maintain records of all initial and follow-up verification tests.

 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.

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Recordkeeping and Reporting for the 608 Refrigerant Management Program
Additional Guidance: These records are only required for appliances leaking above the threshold
rate. Technicians are required to provide these records, but owners/operators are required to
maintain the records. This requirement is specified in 40 CFR 82.157(l)(5).


A copy of retrofit/retirement plans (if applicable). Plans must include:

 Identification and location of the appliance;
 Type and full charge of the refrigerant used in the appliance;
 Type and full charge of the refrigerant to which the appliance will be converted, if retrofitted;
 Itemized procedure for converting the appliance to a different refrigerant, including changes
required for compatibility with the new substitute, if retrofitted;

 Plan for the disposition of recovered refrigerant;
 Plan for the disposition of the appliance, if retired; and
 One-year schedule for completion of the appliance retrofit or retirement.
Additional Guidance: These records are only required for appliances leaking above the threshold
rate. This requirement is specified in 40 CFR 82.157(h)(2).


A copy of any requests for extensions to the 30-day repair timeline or the one-year retrofit/retire
timeline (as applicable).
Additional Guidance: This requirement is specified in 40 CFR 82.157(l)(7). A description of the
contents of the request is found under the reporting section below.



Records when appliances are mothballed to suspend a regulatory deadline, including:

 The date when a system is mothballed; and
 The date when refrigerant is added back into the system.
Additional Guidance: This requirement is specified in 40 CFR 82.157(l)(8).


Records on purged or destroyed refrigerant, including:

 Information on flow rate, quantity or concentration of the refrigerant in the vent stream; and
periods of purge flow;

 The identification of the facility and a contact person, including the address and telephone
number;

 A description of the appliance, focusing on aspects relevant to the purging of refrigerant and
subsequent destruction;

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Recordkeeping and Reporting for the 608 Refrigerant Management Program

 A description of the methods used to determine the quantity of refrigerant sent for destruction
and type of records that are being kept by the owners or operators where the appliance is
located;

 The frequency of monitoring and data-recording; and
 A description of the control device, and its destruction efficiency.
Additional Guidance: This requirement is specified in 40 CFR 82.157(l)(9).


Records documenting an owner/operator is using the seasonal variance flexibility.
Additional Guidance: This requirement is specified in 40 CFR 82.157(l)(10).

B. Reports or Other Submissions to EPA


Report to EPA when an appliance loses more than 125 percent of its total charge within a calendar
year.

 The report must describe efforts to identify leaks and repair the appliance.
Additional Guidance: The first report of any appliance leaking 125% or more would be due March 1,
2020, for leaks that occurred over 2019. The report could include records generated during the
course of repairing the appliance (e.g., requests for extensions, retrofit/retirement plan, etc.). EPA
has not developed a specific form for this report. The report must demonstrate that the
owner/operators is in compliance with the repair provisions or the retrofit or retirement provisions
of this program. This requirement is specified in 40 CFR 82.157(j).


Requests for extensions to the 30-day repair timeline (or 120 days in the event of an IPR shutdown).
Submissions include the following information:

 Date of notification to EPA;
 Identification of the appliance;
 Name of the owner or operator;
 Leak rate;
 Method used to determine the leak rate and full charge;
 Date a leak rate above the applicable allowable rate was discovered;
 Location of leaks(s) to the extent determined to date;
 Any repair work that has been finished thus far, including the date that work was completed;
 Reasons why more than 30 days (or 120 in the event of an IPR shutdown) is necessary to
complete the repair; and

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Recordkeeping and Reporting for the 608 Refrigerant Management Program

 Estimate of when the repair will be completed.
Additional Guidance: A request for extension will be considered approved unless EPA notifies the
owners or operators otherwise. The request must be provided within the 30-day (or 120-day, if
applicable) repair timeframe. Owners and operators can request subsequent extensions if they
provide EPA with documentation of the reason for the extension within 30 days of identifying the
need for the subsequent extension. This requirement is specified in 40 CFR 82.157(f).


Requests for extensions to the one-year retrofit/retire timeline. Submissions include the following
information:

 Date of notification to EPA;
 Identification of the appliance;
 Name of the owner or operator;
 Leak rate;
 Method used to determine the leak rate and full charge;
 Date a leak rate above the applicable allowable rate was discovered;
 Location of leaks(s) to the extent determined to date;
 Any repair work that has been finished thus far, including the date that work was finished;
 Plan to finish the retrofit or retirement of the system;
 Reasons why more than one year is necessary to retrofit or retire the system; and
 An estimate of when retrofit or retirement work will be finished.
Additional Guidance: A request for extension will be considered approved unless EPA notifies the
owners or operators within 60 days of receipt of the request. The request must be provided within
seven months of discovering that the appliance exceeded the threshold leak rate. Owners and
operators can request subsequent extensions if they provide EPA with documentation of the reason
for the extension within 30 days of identifying the need for the subsequent extension. The elements
of this request are the same as the request for an extension to the 30-day repair timeframe except
that this request must also include a copy of the retrofit/retirement plan. See the recordkeeping
section above for required elements of a retrofit/retirement plan. This requirement is specified in 40
CFR 82.157(i).


Requests to cease a retrofit/retirement if all leaks are repaired. Submissions include the following
information:

 The retrofit or retirement plan;
 The date that the requirement to develop a retrofit or retirement plan was triggered;

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Recordkeeping and Reporting for the 608 Refrigerant Management Program

 The leak rate;
 The method used to determine the leak rate and full charge;
 The location of the leak(s) identified in the leak inspection;
 A description of repair work that has been completed;
 A description of repair work that has not been completed;
 A description of why the repair was not conducted within the 30-day (or 120-day) timeframes,
including any possible extensions;

 A statement signed by an authorized official that all identified leaks will be repaired; and
 An estimate of when those repairs will be completed (not to exceed one year from date of the
plan).
Additional Guidance: Owners and operators can request relief within 180 days of the plan's creation
date. The request will be considered approved unless EPA notifies the owners or operators within 60
days of receipt of the request that it is not approved. This requirement is specified in 40 CFR
82.157(h)(5).


Notice when excluding purged refrigerants that are destroyed from annual leak rate calculations.
Additional Guidance: See above for required elements of such notice. The owner/operator must
notify EPA within 60 days after the first time the exclusion is used by the facility where the appliance
is located. This requirement is specified in 40 CFR 82.157(l)(9).

7) Small Can Manufacturers
A. Records
Small can manufacturers must maintain the following records:


Log forms detailing results from self-sealing valve testing.
Additional Guidance: EPA has prepared a sample form found at
https://www.epa.gov/section608/major-recordkeeping-requirements-stationary-refrigeration for
these records. This requirement is specified in 40 CFR 82.154(c)(2) and in 40 CFR Part 82, Subpart F,
Appendix E.

B. Reports or Other Submissions to EPA
EPA does not require the submission of any reports or other documents.

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Recordkeeping and Reporting for the 608 Refrigerant Management Program

8) Refrigerant Recovery/Recycling Equipment Testing Organizations
A. Records
Organizations that test refrigerant recovery/recycling equipment must maintain the following records:


Records of refrigerant recovery/recycling equipment testing and performance.



List of certified refrigerant recovery/recycling equipment that includes the name of the
manufacturer and the name or serial number of the model line.
Additional Guidance: This requirement is specified in 40 CFR 82.160(e).

B. Reports or Other Submissions to EPA


Application for approval by EPA to certify refrigerant recovery/recycling equipment (as applicable).
Information includes:

 List refrigerant recovery/recycling equipment present at the organization that will be used for
testing;

 Verification of expertise in refrigerant recovery/recycling equipment testing and the technical
experience of the organization's personnel;

 Verification of the organization’s knowledge of the standards and recordkeeping and reporting
requirements in 40 CFR Part 82, Subpart F; and

 Description of the organization’s program for verifying the performance of certified recycling
and recovery equipment manufactured over the long term, specifying whether retests of
equipment or inspections of equipment at manufacturing facilities will be used;

 Verification that the organization has no conflict of interest and receives no direct or indirect
financial benefit from the outcome of certification testing; and

 Agreement to allow EPA access to records and personnel to verify the information contained in
the application.
Additional Guidance: EPA has not developed a specific form for reclaimer applications. This
requirement is specified in 40 CFR 82.160(b).


Notice of when a previously certified model of refrigerant recovery/recycling equipment fails a
three-year recertification test.

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Recordkeeping and Reporting for the 608 Refrigerant Management Program
Additional Guidance: This notice must be provided to EPA within 30 days of retesting or inspection.
This requirement is specified in 40 CFR 82.160(e).


Publish online a list of all equipment certified by that organization that includes the name of the
manufacturer and the name or serial number of the model line.
Additional Guidance: The testing organization must update the list published online annually. Online
lists must contain certified equipment until three years after that equipment is no longer offered for
sale. This list does not need to be submitted to EPA. This requirement is specified in 40 CFR
82.160(e).

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