What is Refrigerant Management?

Refrigerant management is the proper handling of refrigerants in your HVAC/R systems so that they are not just vented into the atmosphere. Because the most commonly used refrigerants have high ozone-depleting and/or global warming potential, refrigerant management is overseen by the Environmental Protection Agency (EPA) in the United States and other regulatory agencies around the world.

Refrigerant management involves:

• Routine and reactive maintenance of HVAC and refrigeration systems
• Creating a system that promotes energy efficiency
• Training staffing proper usage
• Creating effective emergency response protocols
• Keeping detailed maintenance logs
• Investing in modern, energy-efficient equipment
• Implementing appropriate protocols for handling potentially flammable and toxic compounds
• Conducting routine performance audits
• Compliance with all tracking and reporting requirements

Why Is Refrigerant Management important?

Project Drawdown, the world’s leading climate change solutions database, views refrigerant management as an essential part of solving the global warming crisis. Present in commercial refrigeration systems, household appliances, industrial cooling systems, and air conditioning systems in trains, ships, aircraft, and cars, refrigerants contribute significantly to climate change.

By controlling these fluids and limiting their release into the environment, companies that utilize HVAC/R systems can protect our planet and reduce the damage that humans are doing to the environment.

Project Drawdown finds that if we were able to prevent 100% of refrigerant leaks, that would reduce our carbon dioxide emissions by 57.15 gigatons over 30 years. That’s a lifetime savings of $622.73 billion USD. 

For today’s companies, refrigerant management is important for three key reasons:

1. The ethical obligation to sustainability and the prevention of global warming
2. The business implications of full compliance with regulations
3. The potential impact on your reputation among consumers who value sustainability 

By creating and adhering to rigorous refrigerant management protocols, every organization that uses HVAC/R units can make a positive impact on climate change. 

What are the key regulations involving refrigerants? And why is compliance important? 

Compliance issues are one of the necessary challenges of running a successful business. Even though they can be complicated and at times a logistical headache, they are also one of the most important tools we have for ensuring that corporations engage in things like environmental sustainability, consumer protection, and occupational health.  

The EPA’s AIM ACT

The goals of the EPA’s refrigerant management regulations are two-fold: 

1. Prevent the release of ozone-depleting substances (ODS) from HVAC/R appliances
2. Improve the  process of recapturing and recycling refrigerant substances

The latest version of these rules is found in the EPA’s AIM Act regulations, which were finalized in the fall of 2024. Key takeaways from the refrigerant rules include the goals of the program: 

• Achieve 85% phasedown of HFCs by 2036
• Reduce approximately 120 million metric tons of CO2 equivalent between 2026 and 2050
• See an expected net benefit of at least $6.9 billion

To accomplish this the new requirements include: 

• Mandatory repair of leaking equipment
• Installation of automatic leak detection systems on large refrigeration systems
• Use of reclaimed HFCs for servicing existing equipment
• Proper HFC removal from disposable cylinders
• Fire suppression equipment standards and technician training 

These rules are part of a larger refrigerant strategy, which includes limits on both production and imports and transitioning to next-generation refrigerants.

Section 608 of the Clean Air Act

Section 608 of the Clean Air Act outlines requirements for companies that deal with HVAC/R units. 

Its objectives are: 

• Prohibit the venting of ODS refrigerants (including both CFCs and HCFCs) and their substitutes (namely, HFCs)
• Reduce total CFC and HCFC emissions
• Maximize refrigerant recovery and recycling
• Ensure safe disposal of refrigerants
• Protect the Earth’s ozone layer 

To accomplish these goals, the Clean Air Act prohibits intentional venting of all ODS refrigerants and governs the maintenance, servicing, repair, and disposal activities associated with HVAC/R systems. 

It also requires HVAC/R technicians to pass an EPA-approved exam to receive certification. Additionally, special requirements are implemented for systems that produce more than 50 lbs of ODS. 

Before appliances and systems can be resold, their refrigerants must meet purity specifications and be processed by an EPA-certified reclaimer. To meet disposal requirements, the handler must ensure and verify that the refrigerants have been removed correctly. 

Climate Accountability Acts (SB 253 and SB 261)

California has two state-based rules that govern refrigerant management for any business that does business in the state: SB 253 and SB 261. 

SB 253 is the Climate Corporate Data Accountability Act, and it requires large companies doing business in California to publicly disclose their greenhouse gas emissions. This requirement aims to provide transparency for all stakeholders, including consumers and investors. 

Any company that does business in California with revenues exceeding $1 billion annually is required to comply with these rules. Failure to do so can lead to $500,000 in annual fines. 

SB 261 is titled the Greenhouse Gases: Climate-Related Financial Risk bill. It requires large companies to disclose their climate-related financial risks. The same companies that are required to report their greenhouse gas emissions are required to disclose these climate-related financial risks.

What are the risks associated with non-compliance?

The fines for failing to abide by new and existing regulations are steep. 

In addition to monetary penalties and reputational damage, non-compliance can lead to several other serious consequences that your organization must consider. Criminal prosecution is possible in cases of willful violations, potentially leading to jail time for responsible parties. Additionally, non-compliant businesses may face operational disruptions as regulatory agencies can force the shutdown of equipment until all violations are addressed.

Non-compliance can have a cascading effect, leading to: 

• Loss of business licenses or operating permits
• Increased insurance premiums
• Difficulty securing future contracts, especially with government entities
• Mandatory third-party oversight and monitoring
• Decreased property value for affected facilities
• Higher borrowing costs as lenders view regulatory violations as increased risk
• Loss of valuable employees who don’t want to be associated with environmental violations

There are also indirect costs associated with non-compliance. Non-compliant companies may be required to: 

• Hire additional compliance personnel
• Invest in emergency equipment upgrades
• Pay for rushed technician training and certification
• Engage expensive environmental consultants
• Retain specialized legal counsel
• Launch costly public relations campaigns to repair their image
• Implement more frequent and comprehensive auditing procedures

When you consider the complete impact of non-compliance, investing in proper refrigerant management becomes not just an environmental imperative but a sound business decision. The cost of compliance, while significant, pales in comparison to the potential financial and operational impacts of violations.

Among other things, any technician who tops off the refrigerant without repairing a leak can lose their EPA certification and be fined. For companies, the fine for refrigerant leaks can be tens of thousands of dollars per day from the EPA.

Here’s an example of just how serious the fines can be: a Colorado salvage company was recently fined $195,000 for failing to appropriately dispose of refrigerants that were in appliances they accepted at their scrapyard. A New York City grocer was fined $400,000 for refrigerant violations. 

Fines for violating the Clean Air Act continue to increase, ranging from $55,000-117,000 daily (with a maximum $446,000 fine per violation). 

If you do business in California and fail to comply with the Climate Accountability Acts, you could face up to $500,000 in penalties for failing to disclose emissions and up to $50,000 if you don’t disclose climate-related financial risks. 

Clearly, these fines have the potential to dramatically impact your company’s bottom line. However, there is also a reputational risk to consider. Today’s consumers value sustainability so much that a recent study found that consumers would pay a 9.7% premium just to choose sustainably produced goods. Most consumers probably don’t think about refrigerant management when making purchasing decisions, but what happens when your name gets dragged through the mud as a business that doesn’t care about carbon emissions or the environment? 

The potential fallout from failing to comply with refrigerant management regulations is significant.  

How can effective Refrigerant Tracking improve compliance?

Refrigerant tracking is a key component to full compliance with EPA and other regulations. When you choose the right refrigerant tracking system, you set yourself up for compliance success. This is accomplished through multiple channels of tracking. 

Documentation & Record Keeping

Effective documentation and record-keeping should involve automated logging of refrigerant usage, including real-time inventory tracking. 

Additionally, compliance requires tracking: 

• Service history (with documentation)
• Leak rate calculations
• Maintenance records
• Digital certificate storage 

Tracking with EPA Section 608

To comply with the Clean Air Act’s Section 608, tracking should include:

• Automatic threshold monitory
• All required report generation
• Deadline tracking (with alerts for upcoming deadlines)
• Documentation for external and internal audits
• Verification of technicians’ certifications

Equipment Management 

Tracking your equipment will keep you in line with all regulations. This means:

• Asset tracking and history
• Leak detection monitoring
• Service schedule tracking
• Equipment performance data
• Replacement planning
• Warranty information 

Usage Monitoring

Do you know exactly how much refrigerant you are using, recapturing, and recycling? You certainly need to know it for compliance purposes. 

Usage monitoring involves: 

• Documenting real-time inventory levels
• Tracking all purchases 
• Usage trends analysis
• Loss and leak monitoring
• Recovery tracking 
• Disposal documentation

Environmental Impact Tracking

Sustainable, compliant businesses participate in required environmental impact tracking. This is important everywhere, not just in California where standards are especially high for reporting. 

This kind of tracking pays attention to: 

• Global Warming Potential (GWP) calculations
• Carbon footprint monitoring
• Emissions reporting
• Environmental impact assessments 
• Sustainability goals tracking 

Risk Management

Last but not least, your refrigerant tracking should help you monitor the following: 

• Risk management issues
• Early warning alerts
• Historical data preservation
• Audit trail maintenance
• Compliance violation prevention
• Chain of custody tracking
• Incident documentation

Are there tools and technologies available for Refrigerant Management?

Here’s the great news: you do not need to “reinvent the wheel,” as the saying goes, to achieve all of these complex compliance requirements. Refrigerant management software companies like Fexa are here to help you improve your sustainability practices, comply with all regulations, and avoid costly mistakes in your workflow. 

Using the latest technologies for refrigerant tracking guarantees: 

• a record of refrigerant loss from your HVAC units
• reduced risks of compliance issues
• accurate monitoring of equipment, leaks, repairs, maintenance, and emissions
• real-time analytics and readymade reports that you can use to assess and report your performance

The best software options are user-friendly, well-supported, and able to be integrated across multiple locations. Facility managers, technicians, and both sustainability and operations teams should be able to use these newer software solutions to move beyond outdated methods of compliance management. 

Today’s leaders in the refrigerant management industry offer state-of-the-art platforms that value operational efficiency, sustainability, and compliance. 

What are some common challenges associated with Refrigerant Management?

Refrigerant management is nothing if not complicated! The work requires technical knowledge, software skills, strong organizational thinking, and problem-solving. Depending on the size of the organization, Facilities Managers may find themselves dealing with refrigerant issues every single day. 

Regulatory Compliance 

As we have discussed in this guide, regulatory compliance is one of the most important aspects of refrigerant management. As the regulatory landscape continues to increase in complexity, facility managers must navigate a maze of rules that govern every aspect of their HVAC/R systems. 

The challenges of regulatory compliance include: 

• understanding regulatory changes that accompany new and updated laws
• ensuring compliance with both federal and state-based rules
• correctly tracking every part of the refrigerant management process
• providing regular training to all employees
• choosing the appropriate software for your needs
• investing in effective HVAC/R equipment
• tracking every leak, repair, service event, purchase, and disposal 
• centralizing workflows for multi-site operations

Companies often struggle with a paper-heavy documentation process where personnel typically only check records quarterly, leading to gaps of up to 90 days between reviews. This can result in dangerous reliance on individuals’ memory for compliance obligations. T

The lack of standardized reporting formats creates confusion, while thousands of pages of regulations burden system owners. With increased enforcement actions, audits, and fines, companies must track installed inventory, refrigerant not in systems, and gas handled by third parties, along with maintaining detailed appliance-specific information and leak rates.

Technical Challenges 

When it comes to refrigerant tracking, technology can be your best friend–or your biggest foe. It all depends on whether or not your technology is functioning well or if you are dealing with broken parts and flawed systems. 

Managing a refrigeration system requires sophisticated technical expertise and constant attention to system performance. One of the biggest potential problems is leak detection, as even tiny, almost undetectable leaks can result in major refrigerant loss over time. 

A modern HVAC/R system may have hundreds of potential leak points. If you are responsible for multiple facilities, each with its own system, you may be responsible for thousands of potential leak points. Identifying the exact location of a leak requires specialized equipment and expertise. 

HVAC/R technicians must: 

• accurately track refrigerant additions and removals
• Work in challenging conditions
• understand multiple system types
• properly handle refrigerant

Finding qualified technicians is another challenge! Experienced, qualified technicians can be scarce, and it is not an option to go with anyone who is underqualified or unlicensed. 

Administrative Workload

Refrigerant management involves a lot of administrative oversight, especially for organizations with multiple locations and systems. 

Thankfully, we’ve moved past the days of error-prone paper systems for work orders. Digitization hasn’t been easy, though. Some companies have pieced together digital tools designed for other purposes, while others have chosen legacy management platforms that haven’t kept up with a changing industry. 

The administrative tasks associated with refrigerant management include: 

• Tracking work orders
• Recording service events
• Documenting refrigerant usage, leak rates, etc
• Maintaining accurate historical records
• Submitting compliance forms 
• Performing audits 
• Generating enterprise-wide reports
• Conducting licensing checks for contractors and technicians
• Monitoring technician performance 

The challenge of good documentation is that it must be both comprehensive and accessible. Records need to be easily accessible from anywhere, and they must alleviate–rather than contribute to–the administrative workload of your refrigerant management team. 

Operational Challenges

Let’s consider the day-to-day operational challenges of managing an organization’s HVAC/R systems. How do you make sure that your systems operate with peak efficiency? After all, you need to avoid downtime while coordinating maintenance teams, facility operations, and business needs. 

The pressure to keep your systems running can make it difficult to take the necessary time for thorough maintenance and repair procedures. 

Consider these operational challenges: 

• Staying on top of preventative maintenance
• Coordinating technician schedules 
• Making sure that everyone has the required training and certification requirements
• Aligning the right technicians with the right tasks
• Eliminating energy inefficiencies that increase your operational expenses

Corporate Social Responsibility (CSR)

As awareness of the impact of refrigerant emissions grows, ethical businesses must balance their operation needs with their obligations to environmental responsibility. Specifically, organizations must adhere to the standards of Corporate Social Responsibility (CSR).

CSR is a self-regulating business model that promotes accountability to multiple groups: the company itself, the stakeholders, and the public. CSR prompts businesses to engage in high standards of corporate citizenship. Although profits are at the heart of any business’s operations, CSR emphasizes the importance of societal good and environmental protection. 

Refrigerant management is an essential part of CSR. Managing high Global Warming Potential (GWP) and ozone-depleting substances requires a strong commitment to environmental ethics. 

This may involve: 

• Going above and beyond compliance requirements 
• Transitioning to the lowest possible levels of GWP substances
• Investing in state-of-the-art HVAC/R systems to prevent even the smallest of refrigerant leaks
• Investigating solutions that lower expenses while still maintaining full compliance
• Communicating your refrigerant management decisions to stakeholders and the public alike

Cost Management

It is a constant balancing act to manage environmental responsibility, compliance, and costs.  Refrigerant costs continue to rise, as do maintenance and repair expenses. Whether you hire contractors or employ full-time technicians, costs are also increasing in those areas. 

While you may be able to count on accurate projections for other aspects of your business, refrigerant costs can be quite unpredictable. Emergency repairs can be particularly expensive, requiring overtime labor costs and expedited delivery of essential parts. 

Compliance programs, training and certification requirements, and preventive measures all contribute to the overall financial burden of refrigerant management. It’s all a balancing act! 

Investing in new technologies and equipment can lead to long-term savings through improved refrigerant management, but they require significant upfront capital. Businesses of all sizes must carefully evaluate the ROI for these expenditures, all while ensuring they maintain compliance and meet their environmental goals.

Are there things organizations can do now to improve Refrigerant Management?

Despite all of these challenges, there are things that organizations can do today to improve their refrigerant management protocols. 

Choosing Fexa Trakref is the single best way to improve refrigerant management in your facilities. The Fexa Trakref system is designed to address the unique challenges of refrigerant management to keep your costs low, even as you are fully compliant with all regulations. 

Today’s single and multi-site organizations can take several proactive steps to enhance their refrigerant management practices, addressing both immediate challenges and future compliance needs. 

Here are some of the most important things Fexa Trakref can do for you. 

Move from paper-based to digital systems that can:

• Track refrigerant inventory
• Monitor service activities
• Generate compliance reports
• Calculate leak rates

Implement basic asset management principles:

• Tag all assets systematically
• Treat cylinders as trackable assets
• Engage vendors in data entry
• Digitize data promptly
• Review and verify records regularly

Focus on compliance fundamentals:

• Track installed inventory
• Monitor refrigerant not in systems
• Document third-party handling
• Maintain appliance-specific records
• Record leak rates

How can Fexa Trakref help?

The environmental and regulatory landscape of refrigerant management is not going to stop changing. We will learn more about the environmental impact of refrigerant options, and new technologies will emerge to make a positive impact on climate change. 

The challenges facing today’s businesses are significant. However, our planet’s future is at stake. 

Legacy refrigerant tracking platforms haven’t successfully made the jump to a fully digitized and responsive infrastructure. By embracing new technologies, you can do more than just meet your regulatory obligations; you can also demonstrate your commitment to environmental stewardship. 

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