EPA Refrigerant Management Program Update
Over the last month, a number of stories have appeared pertaining to the HFC court ruling. As a result, ESCO Institute has received large number of inquires as, to how this may impact the EPA’s efforts in modernizing the Section 608 program.
The following post will provide a little history and where the industry will go from here. In addition, we enclosed a number of articles at the bottom providing further details.
  • Section 608 requires that all persons who maintain, service, repair or dispose of appliances that contain regulated refrigerants be certified in proper refrigerant handling techniques.
  • Section 612 requires EPA to evaluate substitutes for the ozone-depleting substances to reduce overall risk to human health and the environment.
The EPA first proposed a Status Change Rule to limit use of HFCs on August 6, 2014. Having done so, in March of 2015 the EPA presented this plan at the National HVACR Educators and Trainers Conference hosted by ESCO Institute and HVAC Excellence.
To ensure modernization of the Section 608 program was successful, in 2016 EPA approved certification organizations were invited to aide in the process of updating the bank of test questions. The purpose was to have the organizations responsible for testing, collaborate in the development of a new bank of questions. Randy Petit of ESCO Institute chaired the rewrite committee which included the following EPA approved organizations as well as other industry members: Air Conditioning Contractors of America (ACCA), ESCO Institute, Elgin Community College, Ferris State University, Harper College, International Association of Operating Engineers (IUOE), Lupson Associates, Refrigeration Service Engineers Society (RSES), United Association of Apprentices and Journeymen, and Video General Inc. (VGI).
Armed with industry input, the EPA finalized two rules, Section 608 and Section 612, to regulate HFCs. Having done so, they published the final ruling in the Federal Register on November 18, 2016. Once the public commenting period concluded, the ruling became effective on January 1, 2017.
With new regulations in effect, and more being phased in over a two-year period, the EPA returned to the conference to present the regulatory changes. In doing so, they removed any uncertainty, as instructors received the information direct from the source.
Having collaborated with industry stakeholders to update the program, the EPA needed the program to be pilot tested prior to releasing it. As such, the EPA provided ESCO Institute with a proposed set of test bank questions for review and pilot testing. To complete the pilot testing process, ESCO Institute developed a new preparatory manual, PowerPoint presentation and multiple versions of the new examination based on the new bank of test questions.
With a successful pilot test, and new regulations going into effect on January 1, 2018, it was the intent of the EPA to release a new test bank of questions by/before this time. (See slide 6 / See page 1) Due recent litigation under Section 612 the SNAP program, the EPA is delaying the new bank of test questions for Section 608, until a final court decision is reached. In doing so, it will provide clarity in implementing the new program.
Where We Go from Here
Industry leading stakeholders having met with the EPA on September 8, 2017, filed an appeal of the HFC court ruling. Until a final court decision is made, a date for release of a revised test bank remains undetermined. Until such notification, registered proctors should continue to use the current exam.
As additional information becomes available, we will continue to share it with you. However, feel free to contact us toll free at 1-800-726-9696 should you have any questions.
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