The EPA has submitted a
, immediately affecting everyone in the HVACR industry.
This ruling will revise the refrigerant management requirements,
. That is unless the industry speaks out and voices its objection.
One of the changes is to rescind the refrigerant management requirements of subpart F from substitute refrigerants. These requirements include a sales restriction for substitute refrigerants.
What does this mean?
- Substitute refrigerants and equipment could be sold by anyone, including big box or online retailers, cutting out the wholesaler.
- Anyone could purchase refrigerants and work on their own systems, devastating for contractors, and even worse for manufacturers. What will this do to warranty costs, and brand perception?
- The HVACR industry would have different regulations for different refrigerants, confusing for all.
- It would be illegal to vent substitute refrigerants, but there would be no requirement to recover them. What does this mean?
- Educators having just revised their curriculum, would have to do so, again.
- Wholesalers would have to prepare their customers and update their point of sales software to comply, again (immediately).
- Publishers would have to revise their textbooks and supplemental materials, again.
- Certification programs would need to revise the training materials and exams, again. A revision now could result in three different exams in one year, creating confusion in knowing what to teach and which regulations to comply with.
- It has taken two years to prepare the workforce and its trainers to comply with the 2016 regulations. Another change now, would require a massive effort to retrain everyone to comply, again.
A periodic review of regulations is essential to ensure they keep up with technologies. However, a revision this soon into the process of complying with the 2016 rules (which were supported by the industry) would be costly, and confusing for everyone in the industry. While you may not agree with every regulation, the sales restriction has ensured that people purchasing and working with refrigerants are licensed, certified professionals,
lets keep it that way
What do you need to do at this point?
Nothing! the purpose of this email is to keep you apprised of this proposal. As we have more information, we will gladly share it with you.