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Servicing Farm and Heavy-Duty Equipment

This fact sheet should help owners and servicers of farm and heavy-duty equipment understand how the Clean Air Act governs the servicing of MVAC-like appliances -- the term used in the Act for open-drive compressor appliances used to cool the driver's or passenger's compartment of non-road motor vehicles, such as agricultural, construction, mining, or quarry equipment.

EPA published a rule on December 30, 1997, (62 FR 68025) (32 pp, 351 KB) that implements provisions in section 609 of the Clean Air Act requiring automotive service technicians to recycle HFC-134a and other non-ozone-depleting refrigerants that are used in the servicing of motor vehicle air-conditioners (MVACs). This rule also clarifies how the Act applies to some A/C service practices, such as mobile servicing of vehicles, and the disposition of refrigerant at salvage yards and automotive recyclers. A summary of this rule can be found here. The regulation affects MVAC-like appliances in two ways.

To understand the first way that the new regulations affect MVAC-like appliances, keep in mind that historically, section 609 of the Clean Air Act, together with the regulations that implement section 609, have governed MVACs. Section 608 of the Act and the regulations implemented under section 608 have governed not only any type of stationary or commercial A/C or refrigeration system (anything from window unit A/Cs to ice skating rinks), but also MVAC-like appliances. The MVAC regulations that implement section 609 are located in the Code of Federal Regulations, Title 40, Part 82, subpart B, which consists of sections 82.30-82.42, and the stationary and commercial A/C regulations that implement section 608 are located in Part 82, subpart F, which consists of sections 82.150-82.166. The new regulation will copy into subpart B many of the subpart F regulations that govern MVAC-like appliances (see the "Required practices," "Equipment requirements," and "Technician certification" bullets below).

MVACs and MVAC-like appliances are very similar, and many of the current requirements for MVAC-like appliances under the subpart F regulations have historically referred back to the requirements for MVACs under subpart B. In addition, MVACs and MVAC-like appliances are often serviced by the same group of people, and therefore publishing the requirements for both MVACs and MVAC-like appliances in the same place will minimize confusion within this group. Persons who own or service MVAC-like appliances should be able to find most of the regulations that govern MVAC-like appliances in subpart B. You can read further details about where specific requirements are located under "MVAC-Like Appliances Under the Section 608 and 609 Regulations" below.

Second, the regulations include substantive changes that affect MVAC-like appliances. These changes relate primarily to mobile servicing and to the safe disposal of refrigerant from MVAC-like appliances prior to the disposal of the appliances. You can find further details about these substantive changes under "Provisions that Govern MVAC-Like Appliances" below.

MVAC-Like Appliances Under the Section 608 and 609 Regulations

Scope of the subpart B regulations

Section 82.30 states that the purpose of the subpart B regulations is not only to implement section 609 of the Act with respect to MVACs, but also to implement section 608 of the Act with respect to MVAC-like appliances.

Definition of MVAC-Like Appliance

The definition, set forth in section 82.152, will remain in subpart F; the regulation does not copy this definition into subpart B.

Venting prohibition

Under section 82.154(a), in subpart F, it is illegal to vent refrigerant from an MVAC-like appliance. Requirements that apply to both the automotive and stationary/commercial sectors -- the regulations that prohibit refrigerant venting and restrict refrigerant sales -- are always found under subpart F, the section 608 regulations.

Required practices

Under section 82.156(a)(5), anyone servicing an MVAC-like appliance must recover and recycle refrigerant in accordance with the regulations located in 82.32 (the definition of "properly using" recover/recycle equipment for MVACs).

Equipment requirements

Sections 82.158(f) and (g) require that equipment used to recover or recycle refrigerant in MVAC-like appliances that was manufactured or imported on or after November 15, 1993 must be certified in accordance with 82.36(a) (the requirements for certifying MVAC recover or recycle equipment, including testing by an approved laboratory such as UL or ETL), and that equipment manufactured or imported any earlier must be capable of achieving a 4-inch (102 mm) mercury vacuum. The December 30, 1997, regulation extends to MVAC-like appliances both the requirement to use approved recovery/recycling equipment set forth in section 82.34, and the description of the requirements for approved equipment set forth in section 82.36.

Technician certification

Section 82.161(a)(5) states that techs who service MVAC-like appliances must be certified either as Type II technicians or pursuant to the training and testing requirements set forth in section 82.40 (MVAC technician training and certification). The December 30, 1997, regulation extended to MVAC-like appliances both the requirement to be properly trained and certified by an EPA-approved technician certification program set forth in section 82.34, and the description of the specific requirements for approved training and testing set forth in section 82.40.

Safe disposal of refrigerant

Sections 82.154(f), 82.156(g), 82.158(l), and 82.166(i) outline some requirements for recovering refrigerant from MVAC-like appliances during the process of disposing of these appliances. These provisions continue to apply. The December 30, 1997, regulation included provisions located in section 82.34(d) of subpart B that address instances in which an owner or operator of a salvage yard or other motor vehicle disposal facility wishes to return refrigerant recovered from an MVAC-like appliance back to the MVAC/ MVAC-like appliance service sector for reuse, instead of sending the refrigerant to a reclaimer.

Differences between MVACs and MVAC-Like Appliances in the Regulations

The regulations implementing sections 609 and 608 treat MVACs and MVAC-like appliances (and persons servicing them) slightly differently.

One key difference you should be aware of is that persons who service MVACs are subject to the section 609 equipment and technician certification requirements only if they perform "service for consideration," while persons who service MVAC-like appliances are subject to the equipment and technician certification requirements set forth in the section 608 and 609 regulations regardless of whether they are compensated for their work.

Another difference is that persons servicing MVAC-like appliances have the option of becoming certified as Type II technicians instead of becoming certified as MVAC technicians under subpart B. Persons servicing MVACs do not have this choice.

Provisions that Govern MVAC-Like Appliances

Mobile servicing

Under section 82.32(e)(3), mobile servicing of MVAC-like appliances (and MVACs) is permitted, as discussed below under "Mobile Servicing."

Topping off

Section 82.32(e)(4) states that facilities that "top off" MVAC-like appliances (or MVACs) but don't perform any other type of refrigerant servicing (such as some quick-lubes) are still considered to be performing service involving refrigerant, and therefore are subject to all requirements that apply to facilities that perform a wide range of refrigerant servicing. Facilities that only charge MVAC-like appliances are not required to purchase approved refrigerant recycling equipment, but technicians there must be properly trained and certified by an EPA-approved section 608 or section 609 technician certification program.

In addition, persons opening MVAC-like appliances are required to have recovery equipment available. Opening an appliance means any service, maintenance, or repair on an appliance that would release ozone-depleting refrigerant from the appliance to the atmosphere unless the refrigerant was recovered previously from the appliance. Finally, keep in mind that all persons are subject to the prohibition on venting refrigerant.

Recharging refrigerant back into the vehicle from which the refrigerant was taken

Section 82.32(e)(1) states that technicians must recycle refrigerant prior to recharging it into an MVAC-like appliance, even if the equipment is the same equipment from which the refrigerant was extracted.

Safe disposal of refrigerant

Section 82.34(d) outlines requirements for recovering refrigerant from MVAC-like appliances located at motor vehicle disposal facilities (i.e., scrap and salvage yards), if the person recovering the refrigerant wishes to return the refrigerant for re-use in the MVAC/MVAC-like appliance service sector rather than to send the refrigerant off for reclamation. More information about salvage yards is found here.

Mobile Servicing

EPA allows for mobile refrigerant recovery and recycling and has established conditions for when doing so. Specifically, section 82.32(e)(3) permits the transportation of recovery and recycling equipment from service facilities where they are usually stored and used, to other motor vehicle and MVAC-like appliance service locations (which would include auto body shops, used car dealers, farms, construction sites, mines, and quarries), in order to perform refrigerant servicing, or to recover refrigerant from salvaged vehicles.

Keep in mind that certain states and localities might prohibit mobile servicing.

Prior to December 30, 1997, EPA has discouraged mobile servicing. The Agency believed that refrigerant recovery would be maximized if each service facility were encouraged to obtain its own equipment and have its own employees certified under section 609, even if the facility only rarely performed air conditioning service. EPA now believes that this policy has not served to maximize refrigerant recovery, because many facilities that rarely perform air conditioning service have decided to release refrigerant into the atmosphere rather than to bear the expense of purchasing equipment and having their technicians properly trained and certified. The Agency believes, however, that many of these non-complying facilities would be willing to contract with certified technicians from other service facilities who could then transport equipment to their location for refrigerant servicing. Allowing mobile service should therefore enhance refrigerant recovery.

EPA believes that it is clearly easier to move A/C recycling equipment to an air-conditioned tractor for servicing than to move the tractor to the recycling equipment.

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