Can a child install a compressor legally????

[john dalton]

Until this morning, I always thought that the following work required the service technician to have a type I, II, or UNIVERSAL EPA 608 card:

Replace and braze a compressor in a system, repair refrigeration leaks by brazing, replace a refrigerant safety or operational component, connect and braze split system refrigeration line sets, installed or replaced filter driers, replace or install a condensing or evaporative coil, and even evacuated the refrigeration circuit.

I’m beginning to see that if an existing refrigeration system, of any size and type, has been properly recovered of all refrigerant, then anyone, even a child, could do whatever they wanted to the system, as long as a service technician, who had an EPA card, leak checked, and charged the system.

Is this correct?

I know that it seems lately that every building engineer, maintenance man, handyman, and even janitor seems to be able to obtain a card today, but have we slipped so far down the path that the above is correct?

Your comments are very much appreciated at this time my friends.

Respectfully Submitted,
John J. Dalton

[Reliant Air]

I don't think those tasks would be under the EPA. I may be wrong though. Those would be common tasks for a helper to perform. As far as a child doing it OSHA wouldn't allow that. IMO those tasks you mentioned would require mechanical license in Florida. I do think that there are a lot of misconceptions about what the EPA certificate is and what it allows you to do.

[2story]

As long as a child has an epa card, yes! according to my epa study material a card is required to perform any maintenance/service. I take that to mean that a cond. fan replacement can not be done without a card.

[Edited by 2story on 05-17-2005 at 03:25 PM]

[Wild Leg]

Originally posted by 2story
As long as a child has an epa card, yes! according to my epa study material a card is required to perform any maintenance/service. I take that to mean that a cond. fan replacement can not be done without a card.

[Edited by 2story on 05-17-2005 at 03:25 PM]

What study material are you quoting?

I read section 608, and didn't see any mention of fan motors.

[john dalton]

Dear Dhanna,

Here in Los Angeles, a child of sixteen (some may argue whether sixteen is a child, but to a father of three boys, trust me, they’re still children at times, but then again, at forty-nine, so am I) could legally perform all the tasks I listed above, according to the actual wording of EPA’s rule 608. The certified service technician is only required to recover the refrigerant, then verify that the system is leak tight, and then charge the system up again, all other work in-between requires NO EPA certification!

And yes, I would certainly agree with you that there are a lot of misconceptions as to who can do what. I took my first training and certification test back in 1990 at the world’s first refrigerant management seminar put on by RSES in San Francisco, there were only 200 of us there that weekend. I’ve since taken, and passed the RSES’s EPA approved refrigerant management test in November 1993, and of course like every other yahoo out there, have a type UNIVERSAL card.

Respectfully Submitted,
John J. Dalton

[2story]

I am siting my memory, I took the exam 2 years ago using esco materials.

[john dalton]

Dear 2story,

I thought so too my friend, but as of this morning, I have found that Bwal2 is probably correct in his assertion, given the fact that EPA is only concerned with “refrigerant handling and leak testing” as far as certified, or non certified service technicians are concerned.

Respectfully Submitted,
John J. Dalton

[klrogers]

Posted below is an EPA summary of their rules, the only time you need to be certified is when you are handling or likely to open a refrigeration circuit.

From EPA site "Technician Certification"

EPA has established a technician certification program for persons ("technicians") who perform maintenance, service, repair, or disposal that could be reasonably expected to release refrigerants into the atmosphere. The definition of "technician" specifically includes and excludes certain activities as follows:

Included:

* attaching and detaching hoses and gauges to and from the appliance to measure pressure within the appliance;
* adding refrigerant to (for example "topping-off") or removing refrigerant from the appliance
* any other activity that violates the integrity of the MVAC-like appliances, and small appliances.

In addition, apprentices are exempt from certification requirements provided the apprentice is closely and continually supervised by a certified technician.

The Agency has developed four types of certification:

1. For servicing small appliances (Type I).
2. For servicing or disposing of high- or very high-pressure appliances, except small appliances and MVACs (Type II).
3. For servicing or disposing of low-pressure appliances (Type III).
4. For servicing all types of equipment (Universal).


End of EPA quote

When they talk about servicing in the types of certification, I believe they do NOT mean any type of servicing rather anything directly connected with the refrigerant circuit.


Heres the link for those interested: http://www.epa.gov/ozone/title6/608/608fact.html#techcert

[Edited by klrogers on 05-17-2005 at 04:34 PM]

[john dalton]

Dear 2story,

Don’t bother sifting through your material my friend, I just read the entire EPA rule 608 and it says the following only:
“EPA has established a technician certification program for persons ("technicians") who
perform maintenance, service, repair, or disposal that could be reasonably expected to release refrigerant.”
Based on the above statement, anyone can work on any piece or component on a refrigeration system as long as a certified service technician has first removed the refrigerant.

As much as I don’t like the statement, it would appear straightforward in its definition.

Respectfully Submitted,
John J. Dalton

[bku46]

There are no laws in place to stop anyone who is certified to handle refrigerant, to go out and call himself a HVAC tech or work in the field for that matter. Until we become licensed like electricians, your mother can pass a certification test and buy a set of gauges and go find work.
So whats new??? You want something to be concerned about, the illegal aliens are on the march and are looking to the trades for work, its already starting to happen. go luck with your job protection because you ant got any.

[Reliant Air]

When I took the test I thought it was fairly easy, and I think that anyone with average intelligence could pass it. I do not think everyone with a EPA license is qualified to service a/c equipment. IMO the goal of the license is to insure that the technician knows that releasing refrigerant is a no no.

[john dalton]

Dear Bku46,

Regarding your previous post:

“You want something to be concerned about, the illegal aliens are on the march and are looking to the trades for work, its already starting to happen. go luck with your job protection because you ant got any.”

That’s where your wrong my friend, I have the “best job protection” any man, or woman, can have. I didn’t get it when I first started in this profession, but after thirty-one years in the trade I do have it now………..it’s my knowledge and experience of the HVAC industry, and their application to my work. You see, no illegal alien is going to take my jobs away because of the inherent difficulty of them. I don’t do residential, or even light commercial, I’m heavy into industrial, and institutional projects that still require service technicians with ahead on their shoulder, not just hands at the end of their arms!

So as you see, it took over three decades, but I am protected my friend.

Respectfully Submitted,
John J. Dalton

[john dalton]

Dear Bku46,

Regarding your previous post:

“When I took the test I thought it was fairly easy, and I think that anyone with average intelligence could pass it. I do not think everyone with a EPA license is qualified to service a/c equipment. IMO the goal of the license is to insure that the technician knows that releasing refrigerant is a no no.”

Although I’ve taken threads off their original paths with my answers and comments, I’d like to stick to my original thoughts on the subject, namely the following:

Anyone can replace major refrigeration components and lines for systems if the refrigerant has first been recovered.


Respectfully Submitted,
John J. Dalton

PS: That could be another great thread, EPA type “UNIVERSAL” cards tell you NOTHING of the service technicians qualifications to even install a set of gages on the refrigeration system correctly.

[bku46]

I have been in the field myself for 20 yrs John and I agree with you but it dosent take 30 yrs of experience to replace filters, belts and lube, thats what Im talking about. They can pay sombody to do maintance cheap but still need us old timers for trouble shooting for now now.

[Edited by bku46 on 05-17-2005 at 05:38 PM]

[Reliant Air]

Originally posted by john dalton

Although I’ve taken threads off their original paths with my answers and comments, I’d like to stick to my original thoughts on the subject, namely the following:

Anyone can replace major refrigeration components and lines for systems if the refrigerant has first been recovered.



Sorry about the thread drift. I agree that as long as the refrigerant has been recovered the EPA is no longer concerned. However, State and local regulations may address who can service equipment and who can't.

[Shophound]

know that it seems lately that every building engineer, maintenance man, handyman, and even janitor seems to be able to obtain a card today, but have we slipped so far down the path that the above is correct?


Dear John,

I wish to convey to you that, far from "busting on you" regarding the above quote, I seek to gently remind you that many of us who are building engineers and maintenance men are not only involved in the HVAC field, but are not archetypical of the no-load slouches often found staffing these positions.

Respectfully submitted,

Shophound

:D

To address the true topic of your OP, I'd say the rules seem primarily concerned with the release of refrigerant into the atmosphere. If the refrigerant is removed or not affected by other repairs to the system, then it's open season, it would appear.

[john dalton]

Dear Shophound,

Regarding you post:

“I wish to convey to you that, far from "busting on you" regarding the above quote, I seek to gently remind you that many of us who are building engineers and maintenance men are not only involved in the HVAC field, but are not archetypical of the no-load slouches often found staffing these positions.”

And to that end, my statement was not addressed to you sir. I have read your posts, analyzed your comments, and have even visited your website, and viewed its photos, and find you to be an educated, experienced, and rather helpful HVAC service technician here at this forum, who happens to be a building engineer to boot.

My comment was referring to the fact that an EPA refrigerant management card should not be so easy to obtain that “ANY BUILDING EMPLOYEE” could get it. It was not directed at building personnel who actually work on the HVAC systems with any degree of knowledge.

I apologize for any of my comments that may have offended anyone else of this thread, or forum, in reference to the above.

Respectfully Submitted,
John J. Dalton

[seaboard]

"The Card" has gotten a few plumbers with gauges out of the AC business but little else. I do have a customer that has process equipment with semi-hermetic compressors and they will occasionally call us to recover the refrigerant and then come back and check their nitrogen holding charge and evacuate and recharge. I had to check for myself when they approached us with this to make sure it was OK because I wasn't sure. They do a lot of other work while the machine is down and don't want to pay us to stand around. Most reasonably inteligent people can take a one day class and at the end of that class take and pass the test. As with BOCA code and journeyman testing it's about being able to use the book and not knowing everything in the book. NATE testing may be the ticket but it won't take hold until the customers demand it and the customer's won't demand it if the industry doesn't promote it better. I'm not a believer yet.

[Shophound]

I apologize for any of my comments that may have offended anyone else of this thread, or forum, in reference to the above.

John, no offense taken. I guess I should've made my grinning emoticon BIGGER.

:D

And thank you for your kind words. It's quite encouraging. I have also gained from reading your posts. Although your writing style may strike some as a bit formal, I find the "articulate" aspect of your posts refreshing.

[john dalton]

Dear Shophound,

Although I saw your posted “grinning emoticon”, I did not want to take a chance at offending a fellow colleague, especial one of your caliber. As for my “formal writing style”, I’ll blame that on my technical writing courses in college.

Thank you for not only your kind words, but your understanding of my apparent lack of the English language at expressing myself at times.

Respectfully Submitted,
John J. Dalton

[coolestacman]

John
Unfortunately there are organizations out there such as RSES and some colleges that will educate one enough to get these cards, which only takes the work from the professionals that are trying to make a living within this industry. The other unfortunate thing is the same organizations that are degrading our trade by training anyone are the same organizations the many of us have relied on for our education.
So you just have to suck it up because you know if you complain to the Government they will just make sure those children that are changing those compressors are Mexican in the USA and in Canada we will just import refrigeration mechanics from some country that does not have any refrigeration.

Life can be frustrating

[Wild Leg]

It's a 25 page study guide, then a hundred question test.
Multiple choice.
P&T chart provided.
Education & training is not required to take or pass the test.
It is strictly regurgitation of a few items in the study guide.
All you've got to have is the $75.00 or so, and a photo ID.

A nine year old could be EPA certified.
But that does not mean he has a clue when working on your system.
But he would be "LEGAL" to handle refrigerants.

Local laws may prevent it, but federal would not.

Technician competency is a different thing entirely.

[Diceman]

I am a child, and I do this stuff all the time.

[pecmsg]

Forgive me if I’m wrong, but the whole idea of the EPA certification was to prevent the loss of refrigerant (chlorine gas) into the atmosphere. Beyond that anybody can work on these units. As long as they don’t “Knowingly discharge”

[Diceman]

Say 10 Our Father's & 15 Hail Mary's and I'll think about it.

[john dalton]

Dear Pecmsg,

Regarding your previous post:

“Forgive me if I’m wrong, but the whole idea of the EPA certification was to prevent the loss of refrigerant (chlorine gas) into the atmosphere. Beyond that anybody can work on these units. As long as they don’t “Knowingly discharge””

It’s the “Beyond that….” that we are discussing, for example, does someone have to be certified to do the following two things once the refrigerant has been recovered from the system:

Replace or work on the TXV (remember that the TXV’s power head assembly is charged with refrigerant)?

Braze a joint (bad brazing can cause immediate or future refrigeration leaks)

Respectfully Submitted,
John J. Dalton

[pecmsg]

From the U S EPA Code Book:
(1) Effective July 1, 1992, it shall be unlawful for any person, in
the course of maintaining, servicing, repairing, or disposing of an
appliance or industrial process refrigeration, to knowingly vent or
otherwise knowingly release or dispose of any class I or class II
substance used as a refrigerant in such appliance (or industrial process
refrigeration) in a manner which permits such substance to enter the
environment. De minimis releases associated with good faith attempts to
recapture and recycle or safely dispose of any such substance shall not
be subject to the prohibition set forth in the preceding sentence.
(2) Effective 5 years after November 15, 1990, paragraph (1) shall
also apply to the venting, release, or disposal of any substitute
substance for a class I or class II substance by any person maintaining,
servicing, repairing, or disposing of an appliance or industrial process
refrigeration which contains and uses as a refrigerant any such
substance, unless the Administrator determines that venting, releasing,
or disposing of such substance does not pose a threat to the
environment. For purposes of this paragraph, the term ``appliance''
includes any device which contains and uses as a refrigerant a
substitute substance and which is used for household or commercial
purposes, including any air conditioner, refrigerator, chiller, or
freezer.

(July 14, 1955, ch. 360, title VI, Sec. 608, as added Pub. L. 101-549,
title VI, Sec. 602(a), Nov. 15, 1990, 104 Stat. 2661.)

[john dalton]

Dear Pecmsg,

Yes we know what the EPA code book states, but it can be as ambiguous to interrupt as the EPA wants it to be. What is your option or comments as to whether an EPA card is needed to work on a TXV or braze a refrigeration joint inside, or outside a unit if all the refrigerant has been recovered from the system?

Respectfully Submitted,
John J. Dalton

[seaboard]

When I looked at this again today I was reminded about the property manager that I know consistently hiring people that were unqualified to work on her HVAC equipment. Each one had an EPA card so she assumed that meant they were qualified. I'm sure that there are many more people like her. Really, how are they to know?

[pecmsg]

“To knowingly vent or otherwise knowingly release or dispose of any class I or class II substance used as a refrigerant in such appliance.”


Knowingly is the key word.

This regulation was set up to change “OUR” past habits. Anyone who has been doing this for more than 15 years.
To correct a wrong.
I wont speak for others, but for myself.
In the past did I Cool off a bucket of Beer with R-12. Yes.
Did I use R-12 to quickly cool down a solution of ice and water for the New York Rangers when the Zamboni cut to deep? Yes. (We also used CO2.)
Did I fill a cup with R-12 to show a customer? Yes.

Were those things legal? YES at the time, but now NO.

Can a homeowner cut a refrigeration line on his equipment??? I think he could get away with it. Did he “Knowingly release refrigerant? NO, I don’t think so.

Can my son who has worked with me for 2 years “Knowingly release refrigerant? No I don’t think so.


“What is your option or comments as to whether an EPA card is needed to work on a TXV or braze a refrigeration joint inside, or outside a unit if all the refrigerant has been recovered from the system?”

No you don’t need an EPA card to Braze, Troubleshoot, Change parts, Etc. Etc. as long as refrigerant is not involved.

I don’t think the question should be EPA certification but Qualifications.
NATE-RSES and all the others, have they shown their students how to use their hands, their heads, there “Gut” feelings? No. That is the problem with our industry and others to.

[Wild Leg]

Originally posted by seaboard
When I looked at this again today I was reminded about the property manager that I know consistently hiring people that were unqualified to work on her HVAC equipment. Each one had an EPA card so she assumed that meant they were qualified. I'm sure that there are many more people like her. Really, how are they to know?

Around here the ads read "Must be HVAC Certified."
Always an apartment complex.
Always confusing competence with legality.

We don't have "HVAC Certified" around here.

Do you?

[secorp]

While I agree even a child can pass the EPA test, (my condolences to those of you who may have failed, I am only class two?) I do not think it is wise that a child should work on a burn out, (sorry Mr Dice)
If the child did not solder tight and developed leaks, the said child would throw a tantrum and cry for an hour. I do not think that the company could recoup the lost time crying, or pass on the crying time to the customer. also I would like to point out that school busses would have to pick up the children and drop them off at there job sites, (mostly because there little feet can not reach the gas and break pedals of a service Van).

Respectfullly, Humbly, without Humility, and with great care not to offend, bad grammer and all.........
submitted this day the year of our Lord 2005.

John Doe Secorp.:)

PS, I also believe that it would take two or three children to carry a reclaim machine to a rooftop job site.

Dear John, this board is full of great characters who I have learned an enormous amount from. (most of it is useless :), still it is knowledge gained)
Please never change you writting style I look forward to learning from you as well.

Respectfully submitted again on this day the year of our Lord 2005.
John doe want a bee Secorp. :)

[Diceman]

I want my mommy........

[vlt]

Let me tell my little story of the cert. card. John like you 30 years in the trade.The last 12 years strictly cascade test chambers.My best and home account 75% of my work has hired a electrican with a cert. card. He is now buying there refrigerant for them cutting are profit. He has yet to try and service anything(he can't).He would have never been hired if he didn't have the card.Two of the largest wholesales in town have put up a red flag on them due to not having contractors liecence.How thing have changed, when i was trying to brake into this trade if your dad or a family member or friend didn't help you it was tuff.In this part of the country you couldn't service anything alone without a city journeyman card.This guy will never take my service work,this silly card is just another way to take advantage of the contractor. Iam still not sure if it legal for him to buy the gas it is a very grey area, but there is one supplier in town that sells to him.For those of you who are not familar with this type of work the gas is very costly and cuts a huge profit.

[the_guru]

Interesting subject....


The EPA cretification card means you are eligible to perform work on systems containing refrigerents,know the laws and know the consequences when breaking those laws.It does not make you eligible to perform any labor on mechanical equipment.

As far as working on a TXV or any other device i would think one wouldn't even attempt to do such a thing unless this person had atleast some experience in the feild.

In my area it is required to have an EPA card to maintain any HVAC/R Equipment and you must also have completed a four year schooling apprenticeship program as well.I was under the assumption it was like this in every state.Am i wrong in thinking so ?

[secorp]

Originally posted by the_guru
Interesting subject....
In my area it is required to have an EPA card to maintain any HVAC/R Equipment and you must also have completed a four year schooling apprenticeship program as well.I was under the assumption it was like this in every state.Am i wrong in thinking so ?



Everywere you need a EPA card but not schooling. I have four years Sheet Metal, four Years HVAC. I am in Florida and school is not a requirement. Florida is a right to work state, Thank God.