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  1. #1
    Join Date
    May 2004
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    Los Angeles, CA
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    1,560
    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

  2. #2
    Join Date
    Jun 2004
    Location
    Florida
    Posts
    556
    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.

  3. #3
    Join Date
    Jan 2004
    Posts
    933
    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]
    Still learning opinions welcome.

  4. #4
    Join Date
    Oct 2004
    Posts
    3,400
    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.

  5. #5
    Join Date
    May 2004
    Location
    Los Angeles, CA
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    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

  6. #6
    Join Date
    Jan 2004
    Posts
    933
    I am siting my memory, I took the exam 2 years ago using esco materials.
    Still learning opinions welcome.

  7. #7
    Join Date
    May 2004
    Location
    Los Angeles, CA
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    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

  8. #8
    Join Date
    Sep 2002
    Location
    Hampton Roads, Virginia
    Posts
    1,627
    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/....html#techcert

    [Edited by klrogers on 05-17-2005 at 04:34 PM]
    "There are 10 types of people in the world.. those who understand binary, and those who don't."

  9. #9
    Join Date
    May 2004
    Location
    Los Angeles, CA
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    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

  10. #10
    Join Date
    Jan 2004
    Posts
    389
    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.

  11. #11
    Join Date
    Jun 2004
    Location
    Florida
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    556
    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.

  12. #12
    Join Date
    May 2004
    Location
    Los Angeles, CA
    Posts
    1,560

    Got the best job protection in the world........

    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

  13. #13
    Join Date
    May 2004
    Location
    Los Angeles, CA
    Posts
    1,560
    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.

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