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New EPA Regulations for Freon System (Non-Exempt Refrigerants) effective January 2019

Existing regulations affecting systems containing 50 pounds or more of class 1 or 2 refrigerants (I.E. R22, R12) was expanded to include any system containing 50 pounds or more of any non-exempt refrigerants. 40 CFR 82.154 list exempt refrigerants as Carbon dioxide in any application; Nitrogen in any application; Water in any application; Ammonia in commercial or industrial process refrigeration or in absorption units; Chlorine in industrial process refrigeration (processing of chlorine and chlorine compounds); Ethane (R-170) in some applications; Propane (R-290) in some applications; Isobutane (R-600a); R-441A in some applications.


These new regulations require records to be kept by the owner/operator of the equipment; required documents include but are not limited to the following:

  • Repairs made to the system
  • Type of system, system charge, and the refrigerant used
  • Initial verification of repair
  • Follow-up verification of repair
  • Leak inspections (How often is determined by system type and size)
  • Leak detector calibration and testing (where applicable)
  • Identification and location of equipment
  • Leak rate percentage

Records must be kept of all maintenance/ service to equipment, including but not limited to the following:

  • Date of service
  • Part of system serviced
  • Type of service
  • Name of person performing work
  • Amount of refrigerant added/or removed from system
  • Updated system charge, and method used to calculate

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HCG Associates | EHS & Safety Consultants

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(857) 299-7240