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Section 609 requirements to purchase refrigerant due to change January 1

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Photo courtesy MACS worldwide.

The EPA established rules concerning the purchase of automotive refrigerant as part of the United States Clean Air Act. When enacted in 1992 as section 609 of the law, the requirement for purchasing R-12 refrigerant and recovering R-134a, R-12, and R-1234yf refrigerant stated that technicians needed to be trained in the use of CFCs and dangers from the release of CFCs into the atmosphere as well as in the proper recycling of these refrigerants. This meant, at least initially, that one had to be certified as section 609 compliant to purchase or recycle any ozone-depleting CFCs. Technicians take a course, offered by several resources, to obtain their certification card, which must be shown when purchasing refrigerant or be on file with the wholesale suppliers.

As of January 1, 2018, the rule has been expanded to include non-ozone depleting refrigerants like HFO-1234yf, R-744, and HFC-152a. The new standard does not apply to the purchase of small recharge cans of less than two pounds; however, any other refrigerant purchases of larger containers now require that section 609 credentials be shown or verified by the seller, and new bookkeeping requirements have been added to the rules and include that sellers must retain invoices that indicate detailed information about the purchaser, quantity purchased, and date of sale. These records must be made available to the EPA when asked.

Although it will not be necessary for sellers to keep a record of each certified purchaser, most vendors will, as a matter of policy, now require knowledge that the purchasing technician is indeed certified, either by viewing their certification card for each purchase and/or a signed statement kept in the repair shop’s or technician’s records for future purchases. Repair shops need to have at least one certified technician for them to purchase these products. Technicians and repair shops must also notify wholesalers of any changes of employment of these certified technicians, as well. If its only certified tech quits or leaves, the shop will need to find another certified tech or discontinue A/C service functions

For most do-it-yourself consumers, these changes will have little effect. Two-pound cans of R-134a can still be purchased without certification.

For car owners having their A/C systems serviced at their corner repair center, they may notice a marked increase in the cost of this service.

For technicians without section 609 credentials who have previously been able to purchase non-ozone depleting refrigerants without certification, these new rules may pose the most problems.

Theoretically, the new rules will have the most effect on sellers who try to turn a quick buck by low-balling established vendors with cheap 30-pound cylinders of R-134a for sale online or off the back of a pickup, as they cruise service departments in your area. Overseas wholesalers from East Asia could also have less of an effect on the retail A/C marketplace.  The new required paperwork and record keeping should virtually eliminate many of those vendors, if they are following the letter of the law. The uptick in A/C service costs would then be attributed to more restrictive availability, hence higher costs for the refrigerants.

Technicians do have several programs available to them through which they can be certified, if they have not yet been so. MACS, Robinair, and ASE all offer certification programs for a small fee, and several automotive employers also provide the necessary resources to certify their own people. Additional resources are listed on the EPA’s website.