Last Opportunity to Comment on the New EPA Ruling Impacting the Entire HVACR Industry
Contributed by Howard Weiss, ESCO Group
On October 1, 2018 the EPA issued a new ruling that will revise refrigerant regulations again, impacting the entire HVACR industry.
The current regulations (November 2016) was the result of two years of industry engagement to clarify regulations, remove ambiguity, and to modernize the program. In pursuit of these changes, the EPA actively conducted stakeholder meetings (beginning in November of 2014), presented at industry events, and published their intentions to seek industry comment. Only after a two-year process of seeking industry input did the EPA publish the 2016 Ruling.
The new ruling looks to rescind the refrigerant management requirements of subpart F, (sales restriction) from substitute refrigerants. The removal of this sales restriction would enable anyone (do-it-yourselfers “DIY”), to purchase substitute refrigerants. With no sales restriction, it will be easy for DIYers to purchase equipment and refrigerants from box retailers and online stores. Will the home owner DIYer use a recovery machine, purchase leak detection tools, utilize reclaimers services, go to school to learn the trade, know how to safely work with or store refrigerants? The answer is no! It is likely that wholesalers and contractors will see less business opportunities, manufacturers will see their warranty costs rise, and the quality of available technicians will diminish.
The HVACR industry collaborated with the EPA for two years, to modernize the Section 608 Refrigerant Management Program. While no regulation is perfect, this regulation has always been good for business and the environment, and we should voice our opinions to keep it that way. You can view the ruling and comment here. However, to be heard, you must submit your comment no later than November 15, 2018.
As this issue impacts everyone in the industry, I hope that you will consider sharing the ruling and comment date with everyone.