Managing refrigerant beyond compliance in your facilities

Environmental legislation is constantly evolving and impacting day-to-day facilities management, especially in the area of refrigerant compliance. Nowadays, it makes far more sense to institute a strategy for remaining compliant, than it does trying to skirt regulations. The EPA can enforce up to $37,500 in daily fines for non-compliance with refrigerant management and reporting. There is good reason behind this as heat-trapping gases like chlorofluorocarbons (CFCs) and hydrofluorocarbons (HFCs) can be thousands of times more dangerous than traditional CO2.

Compliance and sustainability are great reasons to institute a rigorous refrigerant management program in your facilities, but with one pound of refrigerant costing up to $80, reducing leaks also makes good financial sense. Moreover, energy costs to power refrigeration units can constitute as much as 75% of operational expenditure in businesses such as restaurants, grocery and convenience stores, life sciences companies, and data centers.

Below we’ll review the most pertinent U.S. federal and state compliance laws as well as some of the more stringent laws in EMEA and Canada. We’ll also discuss how to implement technology that can help you stay ahead.

Regulations around the use and management of refrigerants have gained significant importance. The Environmental Protection Agency (EPA) 608 regulations aim to reduce the emissions of ozone-depleting substances (ODS) with high global warming potential (GWP) from industrial and commercial sources. Specifically targeted are equipment assets with high ozone-depleting potential (ODP) and more than 50 pounds of refrigerant.

These regulations were established to enforce safe practices in handling and managing refrigerants and include certification of technicians, leak repairs, record-keeping, and reporting requirements related to refrigerant usage. Facility managers should familiarize themselves with the following:

1. 1. Technicians Certification Levels: To handle refrigerants legally, technicians must obtain the appropriate certification. EPA 608 offers four levels of technician certification – Type I, Type II, Type III, and Universal with each corresponding to specific equipment and refrigerant types. Facility managers should ensure their techs hold the necessary certifications based on their job responsibilities.
2. 2. Compliance Deadlines and Phase-Outs: EPA 608 regulations include deadlines and phase-outs for specific refrigerants. These deadlines outline when certain types of refrigerants must be phased out or replaced with more environmentally friendly alternatives to reduce their impact on the ozone layer. Facility managers should stay updated on these deadlines and ensure compliance with phase-out schedules.
3. 3. Leak Repair and Reporting: Another crucial aspect covered by EPA 608 regulations is the requirement to promptly repair refrigerant leaks. Leveraging real-time leak detection and automated reporting technology can simplify the process substantially.
4. 4. Data Management and Record-Keeping: Accurate record-keeping is vital for EPA 608 compliance. Facility management technology can help streamline the data management processes, ensuring all necessary records are properly documented and accessible. Ideally, facility managers should adopt an integrated Refrigerant Tracking & Compliance (RTC) software that integrates seamlessly with core work order management software, like a CMMS. Automated record-keeping systems can significantly reduce administrative burdens given that the EPA requires businesses to retain documentation for 3 years!
5. 5. Training and Education: To ensure adherence to EPA 608 regulations, facility managers should focus on providing comprehensive training and education to their teams. Facility teams in food retail businesses can partner with the EPA in their GreenChill program to ensure best practice.

The American Innovation and Manufacturing (AIM) Act is transformative legislation that could be enforced as early as January 2025. With this legislation, the threshold for refrigeration assets monitored would be reduced from those with greater than 50 pounds of refrigerant down to 15 pounds.

The act authorizes the EPA to phase down the use of HFCs, promote the transition to next-gen leak detection technologies, and introduce stricter refrigerant management practices. Facility teams should anticipate the following:

• Phase Down of HFCs: The AIM Act outlines a schedule to gradually decrease the production and availability of HFCs 85% by 2036, aligning with the Montreal Protocol. This reduction will impact the supply of certain HFC refrigerants, potentially leading to price increases.
• Technology Transition: To comply with the AIM Act, facility management teams must embrace alternative refrigerants with lower global warming potentials (GWPs). This transition will require careful evaluation of HVACR systems to identify suitable replacement options that align with the new GWP restrictions. Upgrading to low-GWP can also achieve reductions in associated costs.

To be get ahead of the regulations in the AIM act, facility managers should prioritize:
 

• Leak Repair and Detection: Facility management teams must promptly address refrigerant leaks and prioritize using Automatic Leak Detection (ALD) systems for appliances with more than 1,500 pounds of refrigerant.
• Reclamation and Proper Handling: The AIM Act emphasizes maximizing reclamation and minimizing HFC emissions. Facility teams should consider reclaiming and reusing refrigerants when possible and complying with new regulations related to fire suppression equipment.
• Recordkeeping and Reporting: Stricter requirements are expected under the AIM Act. Facility management teams should implement technology to track activity accordingly.

Beyond federal regulations in the US, state and international regulations should also be considered. With each jurisdiction having its own requirements, keeping track of these regulations can quickly become unmanageable. First, let’s look at state regulations that complement the EPA:

• California’s CARB Law: The California Air Resources Board (CARB), requires leak Repairs within 14 days, service records for equipment for a minimum of 5 years, and carries penalties up to $10,000. Reporting for CARB is due annually on March 1st.
• Washington State’s Refrigerant Management Program: This program requires additional reporting to EPA 608. All refrigeration systems were required to be registered by March 15, 2024.
• New Jersey’s Greenhouse Gas Monitoring and Reporting Rule: This rule gathers data on greenhouse gas emissions from various sources, including facilities with equipment with over 50 pounds of ODS.

Two of the more relevant environmental regulations to consider for international facility teams with refrigerant are:

• EU F-Gas Regulation: This is a set of rules implemented by the European Union to reduce emissions of fluorinated greenhouse gases (F-gas) with the goal of curbing F-gases by 67% by 2030. F-gas regulation goes as far as the AIM Act aspires to and implements strong maintenance standards as well as phasedowns and restrictions on GWP refrigerants.
• Canada’s Halocarbon Regulations: International facility management teams should also be aware of Canada’s Halocarbon Regulations, which were recently updated in 2022 and restrict production, import, export, and use of various halocarbons, including HFCs.

These state and international regulations impact facility teams responsible for refrigerant management. Facility managers must stay updated on the requirements of each jurisdiction in which they operate and ensure compliance in their day-to-day operations.

Remember, it’s always advisable to consult with legal and industry experts for specific guidance on EPA 608, AIM Act, and other regulations.

Facility managers can leverage refrigerant management technology to remain compliant, while cutting wasteful spending. For those running facility management software, like a CMMS, integrating compliant refrigerant tracking simplifies operational compliance.

JLL Corrigo’s Refrigerant Tracking and Compliance (RTC) powered by MSA Parasense technology is foundational to ensuring your business has accurate and centralized documentation of all refrigeration maintenance. Facility Management teams can track work orders and transactions all-in-one place. In addition to reporting reliable ESG metrics, teams obtain the following benefits:

1. 1. Avoid costly fines for noncompliance such as EPA’s $37,500 daily penalties.
2. 2. Reduce leak rates by 67%. With refrigerant costing up to $80 pound, a single unit with 50 pounds of refrigerant could cost $560 less per year.
3. 3. By installing CMMS and RTC technology you can dramatically reduce energy costs which could constitute up to 75% of OpEx.
4. 4. Simply by instituting more proactive maintenance, customers of JLL Corrigo save on average 38% vs. reactive maintenance costs.

Regulations are complex and multilayered, but they don’t have to constitute a risk to the business. With the right technology in place and the right proactive strategy, facility management teams can not only remain compliant, but can clearly demonstrate ROI to the business.