Background: Since July 1992, regulations promulgated under the CAA require that motor vehicle air conditioning refrigerant be recycled. In 2006, auto dealers in San Francisco area were penalized for violations arising under this act. Serious penalties and legal drama followed. (https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/bfbf6466f34e57b785257368007177bc.html). We must note that these CAA regulations are federal regulations and are applicable to all auto dealers in the US and not to San Francisco dealers alone. To achieve compliance under this regulation, dealers must act as follows:
- Clean Air Act Section 609 Technician Certification Program: All employees working on A/C systems must be trained and tested by a program approved by EPA on how to properly recover and recycle refrigerant (such as Freon 12, HFC-134(a) or any other EPA approved refrigerant).
- Clean Air Act Section 609 Approved Equipment: Section 609 mandates that technicians must use EPA approved equipment to perform refrigerant recovery and recycling. Visit https://www.epa.gov/mvac/section-609-certified-equipment for a list of approved equipment.
Technician Certification: All shop employees repairing/servicing/diagnosing or working in any way on A/C systems must receive training and certificate from an EPA approved training program. The list of training programs is available on https://www.epa.gov/mvac/section-609-technician-training-and-certification-programs. We note that training programs on A/C systems provided by auto manufacturers are a requirement to repair and service automobiles, but they do not in any shape or form help in compliance with this law. Training programs provided by other government bodies such as the South Coast Air Quality Management District also do not help achieve compliance with this law. The training program undertaken by the employees must be on the EPA approved list.
We recommended that you do not allow any employee without training to work on A/C repair or service unless the employee has provided the management with a copy of certification from an EPA approved body. A copy of the certificate should be retained in the Black Box under the file “Air Quality” and a copy sent to Human Resources (Business Office) for retention in the employee file. You may need a copy of the certification three years beyond the date of departure of the tech! (More reading on this issue is available at https://www.epa.gov/mvac/epa-regulatory-requirements-mvac-system-servicing)