In our last post we discussed the EPA’s recent proposed revisions to the Section 608 Refrigerant Management Rules. These revisions would eliminate requirements for leak repair maintenance in stationary refrigerants and air conditioning equipment containing HFCs. The EPA accepted public comments on these proposed revisions and other possible rule revisions through November 15th, 2018. In total, there were 285 comments submitted through the EPA’s regulations.gov site. Dynatemp International submitted comments asking that the EPA not revise their leak repair provisions or the other possible revisions. A quote from our comments regarding HFC Certification rescission:
Speaking with many HVAC wholesalers, the HFC certification rescission may have negative impacts on their liability and business. The benefit of certification is that wholesalers are able to sell refrigerants to a technician which has sufficient background and understanding of their liability of the Clean Air Act. Without EPA’s direct enforcement, requiring the wholesaler to verify certification acts as a local check on bad actors willing to buy refrigerants.
You can find our full comments here.
In addition to Dynatemp International’s opposition to the rule revisions, 15 US state Attorney Generals and the District of Columbia sent a letter to the EPA “strongly opposing” it’s proposed rule.
At the HARDI conference, Jeremy Arling, Lead Environmental Protection Specialist at US EPA, indicated that the EPA would release their decision on their proposed rule revisions around the beginning of 2019. We will keep you informed as new information becomes available.