On April 24, the Automotive Service Association (ASA) hosted a Webinar Wednesday, the second of the month, featuring a presentation titled “An Update on EPA Section 609 Certification” by Dave Cappert of ASE.
ASA Vice President Tony Molla said, “Anyone doing A/C work that involves handling or charging refrigerant into the system must have their EPA Section 609 certification or could face a fine! Dave Cappert, technical expert responsible for the ASE Section 609 certification, will offer training, tips and advice on preparing for the certification test, along with comments on the latest information from the 2019 MACS convention.”
Noting that there have been a lot of changes since the EPA requirements were first passed, Cappert began by reading an excerpt from the final 609 ruling, passed on July 14, 1992.
“There are three parts to section 609,” Cappert explained. “There’s the requirement for the technician to obtain the credential from an EPA-approved provider and be able to provide it on demand, a need for EPA-approved equipment, and a sales restriction put in place on Class I and Class II substances. That sales part is getting more attention recently. A little-known fact is that the EPA reserves the right to request a demonstration proving you can perform the proper procedures.”
Cappert talked a bit about the different vehicles covered under Section 609 versus the ones to which Section 608 applies, noting that 608 is a much more stringent program. He then explained that SAE has developed a MAC manufacturer database where equipment can be listed after completing the necessary information. The database is found at https://macdb.sae.org
ASE offers its Section 609 program via paper and web-based training for $19. The online version provides instant results with the permanent certificate being mailed within 60 days.
“The EPA doesn’t require recertification, but if it’s been a long time since you took it, you need to realize there’s been a lot of change. If you’re a professional, you might want to be fair to yourself and take the newer program. At the very least, download the free book from the website and look at the newer stuff that’s going on,” Cappert encouraged.
Regarding the EPA-approved equipment, Cappert explained that a list of equipment that has been evaluated and approved by the EPA’s two key testing labs is available online at https://www.epa.gov/mvac/section-609-certified-equipment Cappert also recommended another resource, https://macdb.sae.org, for equipment information.
The EPA is still working on the rules for equipment related to R-1234yf, and Cappert anticipates that a more homogenized list of equipment will be available later this year.
Regarding R-1234yf refrigerant RRR equipment, Cappert urged, “If you’re looking at R-1234yf service, make sure the machine meets the latest SAE J2843_201301 revision so that it blocks recovery of refrigerant from a contaminated system. Check with your equipment rep to make sure the equipment has this feature. R-1234yf recovery, recycling and recharging takes longer due to leaks and refrigerant purity checks.”
Asking what happens to shops that don’t play by the rules, Cappert noted that the EPA assesses penalties on a case-by-case basis but explained that shops could be subject to the Clean Air Act maximium statutory daily penalty.
“You’re flirting with the potential danger of being subjected to a huge fine. I would try to make myself immune from any of those punitive actions,” Cappert recommended.
Discussing the newer component of the refrigerant sales restriction that went into effect Jan. 1, 2018, Cappert explained that it included R-134a and R-1234yf and applies to containers weighing 2 pounds or more; small cans containing less than 2 pounds with self-sealing valves are exempt. The restriction also mandates recordkeeping requirements for distributors, and Cappert stressed the importance of maintaining documentation to prove technicians’ certification.
Cappert addressed the common question of whether the new sales restriction means that a new Section 609 credential is required. While the older 609 is still sufficient, technicians must possess proof of the credential, and Cappert strongly recommends retaking the program or at least reviewing the new material due to the many changes that have taken place over the years.
The sales restriction is currently under review to determine whether it should apply to substitute refrigerants.
Cappert said, “It applies more to the regulations of global warming. There are plans for the EPA to talk more about this and issue some guidance on where this may be headed, but for right now, the current sales restriction still applies.”
Cappert also explained that the Section 609 credential is tied to a person, not a company. Recordkeeping must keep track to ensure that a person with the credential is employed by the company and that all technicians servicing MVACs have the 609 credential.
He elaborated, “If you have the Section 609 credential, you may only purchase refrigerants approved for use in MVACs. Purchase of stationary air conditioning refrigerants is not allowed. Section 608 credentials only allow refrigerant purchase for those systems.”
While students generally don’t need the Section 609 credential, apprenticeship scenarios can muddy those waters, and Cappert recommends students obtain it since it’s something they can carry forward and will always need. He also clarified that ASE HVAC certifications do not meet the Section 609 credential requirement.
Although recertification is not currently required, Section 609 regulations provides the potential for recertification at a later date. Cappert acknowledged that there is some discussion surrounding the possibility of requiring a recertification given the amount of technological changes that have occurred since 1992.
Cappert spent a few moments talking about the SNAP program, the fate of R-134a, which is going through a phase down period, and the increase in production of R-1234yf. He briefly mentioned how R-744 is being used on limited Mercedes-Benz models in Europe before offering his time to answer attendees’ questions.
ASA’s next Webinar Wednesday will be held on May 15 and will feature Rick White of 180 BIZ Solutions, who will present “Stop Reacting and Start Succeeding.”
For more information, visit asashop.org.