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  1. #1

    Refrigerant leak law

    Wow! There seems to be a difference in opinion/interpretation governing refrigerant leaks and the legalities of "gas and go". I confess a level of confusion and ignorance due to the fact that I got my EPA card before they were required and haven't kept up on the laws. (Yeah I'm old) I was led to believe and have always operated under the rule that you can charge a residential system one time and after that if the system lost 15% or more of it's capacity you had to find the leak and repair it or replace the system.
    I know about the 50 lb or over law governing commercial systems but have encountered varying interpretations concerning residential systems. I haven't read the actual EPA law as I'm sure it's in lawyer speak.
    So if anyone knows the EPA law and can explain it so dumbies like me can understand it please do so. Please no "opinions" just the actual legal interpretation in laymens terms. Thank you!

  2. #2
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    There is no residential stipulation including your 15 percent rule, some municipalities have stricter rules but not the EPA.

  3. #3
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    Leak rates by law only apply to system containing over 50lbs of refrigerant...thus excluding all residential systems...

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  4. #4
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    Not if you ask our nearest competitor. They tell their customers it applies to all units

  5. #5
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    http://db.tt/S1bE2zvH
    Slide 12 of the linked powerpoint

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  6. #6
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    Quote Originally Posted by BaldLoonie View Post
    Not if you ask our nearest competitor. They tell their customers it applies to all units
    Correct......

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  7. #7
    Quote Originally Posted by TCreacy View Post
    http://db.tt/S1bE2zvH
    Slide 12 of the linked powerpoint

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    So the rule saying that a residential system can only be charged one time before finding the leak and repairing was obviously made up by some Service Manager out to increase his profits by first requiring a repair and possibly induce a replacement of the system.
    I know that I am not alone in the practice but was only going by what I was told by several Service Managers and fellow Techs. I to have passed this along as law. It's a shame to know that these "professionals" were not only dis-honest with customers but with their own Technicians.
    I assume responsibility for not knowing the law myself and taking some one else's information on the subject. It opens up a whole new approach for me as a professional.

  8. #8
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    Quote Originally Posted by pierre1811 View Post
    So the rule saying that a residential system can only be charged one time before finding the leak and repairing was obviously made up by some Service Manager out to increase his profits by first requiring a repair and possibly induce a replacement of the system.
    I know that I am not alone in the practice but was only going by what I was told by several Service Managers and fellow Techs. I to have passed this along as law. It's a shame to know that these "professionals" were not only dis-honest with customers but with their own Technicians.
    I assume responsibility for not knowing the law myself and taking some one else's information on the subject. It opens up a whole new approach for me as a professional.
    Unfortunately many are challenged when it comes to reading comprehension and retention, they knew enough to pass the test then either from laziness or a corrupt nature they adopted the misconception you and many others have.

    Now if you live in Austin Texas what you believe is for the most part correct; I do not remember the specifics but there was at one time a leakage rate/percentage and a sticker that must be applied to a unit when Refrigerant was added. I have not worked in that area since 1995 so things may have changed.

  9. #9
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    It's not a law but I always inform a customer that its better the environment directly and indirectly to replace the thing....

    Had a customer that wouldn't replace it and so every 6mths I would refill it...after 3 years I showed him the costs to prove that he should have replaced it back then


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  10. #10
    We all know as techs that it makes more sense to repair/replace then to keep gassing up. Convincing a customer who is unemployed or on a low fixed income is the trick. They know in the long run it costs more but it's less at one time to gas up.

  11. #11
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    If you want to see it with your own eyes on the EPA site below is the link to the page. My understanding is that it only pertains to CFCs and HCFCs, so HFC leaks aren't required to be repaired at all (I could be wrong about this):

    http://www.epa.gov/ozone/title6/608/leak.html
    B.O. = B.S.

  12. #12
    Quote Originally Posted by snewman24 View Post
    If you want to see it with your own eyes on the EPA site below is the link to the page. My understanding is that it only pertains to CFCs and HCFCs, so HFC leaks aren't required to be repaired at all (I could be wrong about this):

    http://www.epa.gov/ozone/title6/608/leak.html
    This page is a brief overview of the leak repair requirements for appliances containing class I or class II refrigerants (e.g. CFCs, HCFCs, or blends).

    You are apparently correct and of course it pertains to systems with a 50 lbs or greater capacity

  13. #13
    Join Date
    Aug 2004
    Location
    North Richland Hills, Texas
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    Even on systems containing >50# of refrigerant, our responsibility as technicians is only to provide the owner/operator of the equipment with a record of how much refrigerant we have added to a system. The repair invoice showing the amount of refrigerant used is sufficient.
    It is the owner/operators responsibility to track the leakage rate, and have it repaired if it is above the allowable levels, not the technicians.

    The EPA regulations don't make it illegal for us to add refrigerant, but there are local or state laws that do in some areas.

    I'm not advocating for "blow and go", but if after giving them the options, the customer just wants refrigerant added, it is perfectly legal for us to do so.
    In most states, telling someone that it is illegal to add refrigerant, and that they must repair or replace the equipment, is itself an illegal act known as fraud.
    In the mid 90's the Texas Attorney General went on a crusade prosecuting automotive shops for fraud that were pressuring people into repairs and retrofits of their automotive AC systems. The state even had a 1-800 hotline set up for reporting it.
    If more government is the answer, then it's a really stupid question.

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