Many questions have been going around about the new rules for Section 608 of the Clean Air Act. As a retired instructor given the opportunity to chair the committee to redo the exam questions, I think the changes made are an improvement to the test bank of questions. We tried to get rid of questions requiring dates, negative type questions and the ones with an “all of the above” answer.
EPA supplied the ESCO Institute with over 400 revised questions submitted by the committee and other organizations to do the pilot testing.  We are constantly analyzing the results to give feedback to EPA and to improve our new 28-page study guide.
The court filing by refrigerant manufactures and some companies for or against the new rules may delay some of the projected dates for implementation of some rules.  In addition, a few exam questions may need to be modified but not enough to affect what has been achieved so far.
I find one of the big changes besides the leak rates for large systems is the record keeping for disposal of Appliances with 5 to 50 pounds of refrigerant. This one will affect all HVACR contractors.
New records for the disposal of appliances containing between 5 and 50 pounds of refrigerant (Scheduled to starting 1/1/18) must be maintained by the technician/contractor.
  • Company name, location of the appliance, date of recovery, and type of refrigerant recovered for each appliance;
  • Amount of refrigerant (by type) recovered from all disposed appliances in each calendar month; and
  •  Quantity of refrigerant (by type) transferred for reclamation and/or destruction, the person to whom it was transferred, and the date.
  • These records must be maintained by the technician and not the owner or operator of the appliance