Background: Since July 1992, regulations promulgated under the CAA require that motor vehicle air conditioning refrigerant be recycled. Last week, auto dealers in San Francisco area were penalized for violations arising under this act. 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 approved by EPA approved refrigerant).
- Clean Air Act Section 609 Approved Equipment: Must utilize EPA approved recycling equipment and mail a completed USEPA Refrigerant or Recycling Device Acquisition Certification Form to EPA.