Recordkeeping Requirements for Refrigerant Retailers

Individuals or companies that sell refrigerants must comply with EPA recordkeeping requirements, this includes ozone-depleting refrigerant and non-ozone depleting alternatives such as HFCs. It is important to note that all records related to the sale of refrigerants must be kept for a minimum of three years.

Requirements for Sales of Large Cylinders to Service Technicians

• The seller must keep an invoice listing the name of purchaser, date of sale, and quantity of refrigerant purchased.
• The seller must either see a Section 608 or Section 609 technician certification card. [Note that Section 609 technicians may not purchase hydrochlorofluorocarbonhydrochlorofluorocarbonA compound consisting of hydrogen, chlorine, fluorine, and carbon. The HCFCs are one class of chemicals being used to replace the CFCs. They contain chlorine and thus deplete stratospheric ozone, but to a much lesser extent than CFCs. HCFCs have ozone depletion potentials (ODPs) ranging from 0.01 to 0.1. Production of HCFCs with the highest ODPs are being phased out first, followed by other HCFCs. A table of ozone-depleting substances (http://www.epa.gov/ozone/science/ods/classtwo.html) shows their ODPs, GWPs, and CAS numbers. HCFCs are numbered according to a standard scheme (http://www.epa.gov/ozone/geninfo/numbers.html). (HCFC)-22; also called R-22.]. If the buyer is uncertified, but is purchasing on behalf of a shop or other facility, the seller must see evidence that at least one technician at that shop is certified (such as a letter from the shop stating a particular technician is certified plus a copy of that technician’s certification card).
• The seller must keep a copy of the purchaser’s technician certification on file.
• The purchasing facility must notify the seller if a certified technician is no longer employed. The seller is then prohibited from selling refrigerant to the shop.

Requirements for Sales of Large Cylinders to Refrigerant Wholesalers

• The seller must have an invoice listing the name of purchaser, date of sale, and quantity of refrigerant purchased.
• The seller does not need to see a Section 608 or Section 609 technician certification card. However, it is a good idea to get a written statement certifying that the cylinders will be resold. The statement should include the name and business address of the wholesaler. Sellers of refrigerant are legally responsible for ensuring that their customers are allowed to purchase refrigerant.

Requirements for Sales of Containers of Ozone-Depleting Refrigerant Less than 20 Pounds to Refrigerant Wholesalers

• The seller must see the technician's Section 609 certification card. Only Section 609 certified technicians can purchase small cans of chlorofluorocarbonchlorofluorocarbonA compound consisting of chlorine, fluorine, and carbon. CFCs are very stable in the troposphere. They move to the stratosphere and are broken down by strong ultraviolet (UV) light, where they release chlorine atoms that then deplete the ozone layer. CFCs are commonly used as refrigerants, solvents, and foam blowing agents. The most common CFCs are CFC-11, CFC-12, CFC-113, CFC-114, and CFC-115. The ozone depletion potential (ODP) for each CFC is, respectively, 1, 1, 0.8, 1, and 0.6. A table of all ozone-depleting substances (http://www.epa.gov/ozone/science/ods/index.html) shows their ODPs, global warming potentials (GWPs), and CAS numbers. CFCs are numbered according to a standard scheme (http://www.epa.gov/ozone/geninfo/numbers.html). (CFC)-12 (also called R-12) or EPA-approved substitutes for MVACs containing an ozone-depleting substance.
• Section 608 certified technicians may not purchase these smaller containers for use as a refrigerant in motor vehicle air-conditioners.

Requirements for Sales of Containers of Ozone-Depleting Refrigerant (Less than 20 Pounds) to Refrigerant Wholesalers

• Sellers must obtain a written statement from the wholesaler that the smaller containers are for resale only. The statement must indicate the purchaser's name and business address.

Requirements for Sales of Small Cans of HFC-134a (2 Pounds or less)

• EPA is not restricting the sale of small cans of HFC-134a or other EPA-approved non-ozone depleting substitutes for MVACs. Such small cans must be manufactured with a unique fitting and a self-sealing valve to reduce emissions.