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.”