This article's "best practices" checklist was created from working with organizations throughout the USA to develop and implement U.S. Environmental Protection Agency (EPA) refrigerant-regulations compliance programs.
By Robert Johnson
The checklist presented here contains what the EPA considers "must do" requirements, as well as industry practices that are considered "should do" recommendations to meet compliance guidelines. Best practices recommendations are included to aid organizations implement a framework of procedures, systems, and information that will help ensure commitment to the "must do" requirements.
To ensure that your organization is prepared to meet compliance requirements, you need a well-defined and documented refrigerant compliance program. You can do a self-check of how well your company is prepared by answering the following questions.
Self-check—Policy
Do you have a written policy for conducting annual internal refrigerant-compliance GAP-analysis surveys to ensure that your organization is in compliance with all EPA requirements?
Do you have a written unintentional refrigerant venting, leaking, and reporting policy for your refrigerant appliances, equipment, and refrigerant inventory?
Does your organization have a written refrigerant-inventory management policy including disbursement, cradle-to-grave record keeping, and audit tracking of all refrigerants?
Have you established an on-going process and infrastructure to collect, distribute, and communicate the various refrigerant regulations updates and amendments issued by the EPA?
Self-check—Documentation
Do you have copies and a complete understanding of the various EPA regulations and requirements applying to refrigerants and their use?
Do you have copies and a complete understanding of all of the various updates, amendments, and changes the EPA has issued on the original refrigerant regulations since 1993?
Do you have copies and a complete understanding of the penalties and enforcement actions at EPA's disposal for non-compliance?
Does your organization have copies of EPA certifications for all in-house, as well as contracted, technicians working at your facility to present to the agency upon request?
Does your organization have a written mission statement for EPA refrigerant-regulations compliance specifically documenting your "intent to comply" with EPA regulations?
Self-check—Operations Fulfillment, Personnel
Does your organization have a written job description for a facility manager, responsible for refrigerant management and compliance with regulations, as EPA recommends in its Action Guide?
Has someone in your organization been officially designated as your refrigerant compliance manager? (The EPA will want to speak to this person during a refrigerant-compliance inspection).
Has your designated refrigerant-compliance manager been formally trained in EPA refrigerant regulations compliance management to ensure effective and complete implementation of your refrigerant compliance program?
Does your designated refrigerant-compliance manager have the financial resources and authority to implement your organization's refrigerant compliance program?
Do you have a written refrigerant purchase policy and a designated certified technician or contractor responsible for all purchases?
Does your organization provide all maintenance personnel with written EPA refrigerant compliance policies and procedures manuals?
Have your organization's EPA refrigerant-compliance policies and procedures been "effectively communicated to all affected personnel" through documented compliance-training sessions?
Do you conduct ongoing EPA refrigerant-regulations training for your technicians and other affected personnel that includes updates, amendments, and changes issued by the EPA?
Self-check—Operations Fulfillment, Record Keeping
Does your organization have a written policy for EPA-required refrigerant usage record keeping, including a defined and uniform method of collecting, maintaining, and making records available to EPA inspectors upon request?
Do you have a written appliance-servicing policy including EPA compliance requirements and specific refrigerant handling procedures?
Do you have a written labeling policy for refrigerant cylinders and appliances using refrigerants per EPA requirements?
Do you have a written refrigerant inventory and storage policy incorporating national and state regulations and building codes?
Self-check—Operations Fulfillment, Safety/Liability Concerns
Does your organization have a written leak-testing process and defined service procedures for positive-pressure equipment to ensure EPA compliance?
Does your organization have a written refrigerant emergency-response plan including policy for major venting incidents, maximum exposure levels, and evacuation procedures?
Do you have "contractor EPA refrigerant-compliance requirements" language written into your service-maintenance agreements to ensure that your contractors are not exposing you to liability?
Self-check—Operations Fulfillment, Equipment/Materials Handling
Does your organization have a written policy for disposal of refrigerant equipment and parts?
Does your organization have a written policy for disposal of used refrigerant lubricants?
Does your organization have a written policy for shipping and transporting of refrigerants, both into and out of your facility?
Does your organization have a written refrigerant safety policy for handling all refrigerants, including required safety equipment and procedures?
Environmental Support Solutions provides environmental compliance software, training and consulting to organizations affected by refrigerant, waste, IAQ, and health- and safety-management issues.
Contact: Environmental Support Solutions, Tempe, AZ. Tel: 800-289-6116 X 1; E-mail: info@environ.com.
About the author: Robert Johnson is president of Environmental Support Solutions.
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