It has never been more challenging to meet the numerous and varied requirements of refrigerant compliance. Downsizing and doing more with less is the new normal. So how do facility owners and environmental managers ensure they are in full compliance with refrigerant regulations?
Locus Technologies is committed to supporting your compliance efforts related to EPA’s Refrigerant Regulations and we have compiled the following questions to help you assess your level of preparedness.
TOP 10 QUESTIONS EVERY ENVIRONMENTAL AIR MANAGER SHOULD CONSIDER:
- Is your Title V Air Permit impacted by Title VI refrigerant regulations?
- How do you handle deviation reporting related to refrigerant leaks and leak repairs?
- Has your organization prepared and budgeted for the HFC phase-down?
- Can you quantify your current refrigerant usage and project future needs?
- 5. Has your operation identified which systems contain high GWP refrigerants?
- 6. How will your operations be affected by the new repair requirements for high-GWP systems with 15 or more pounds?
- Do you have a designated refrigerant manager or management team for your organization?
- Have they been provided with current training on the regulations, new refrigerants, and industry changes?
- Are your policies, procedures, and work instructions updated to include the new regulations, refrigerants and phase-outs?
- Is a refrigerant recordkeeping system in place and can your organization produce 3 to 5 years of refrigerant-specific service records, leak rate calculations, leak repairs, verification tests, leak inspections, conversions, and disposals?
Did your responses instill confidence or uncertainty in your refrigerant management plan? That sentiment could be an indication of your organization’s risk level. Now is the time to get expert assistance with your plan, because the consequences of non-compliance are significant. For example:
– EPA civil penalties (fines) for non-compliance can reach into the hundreds of thousands to millions of dollars.
– Supplemental Environmental Projects (SEPs) can be tens of millions of dollars.
– Title V Air Permits can be suspended or revoked.
– Criminal jail sentences for knowing and willful violations of the regulations affect technicians as well as facility owners and managers.
Locus Technologies’ in-house subject matter experts pioneered refrigerant management software and services in the CFC phase-out era in the 1990s. Their HVAC backgrounds combine with EPA regulatory expertise to provide unique insight for our customers. Locus stands ready to support your efforts with browser-based cloud software that is mobile-friendly and flexible to meet your needs today and in the future.
Locus is the only self-funded water, air, soil, biological, energy, and waste EHS and ESG reporting software company that is still owned and managed by its founder. The brightest minds in environmental science, embodied carbon, CO2 emissions, refrigerants, and PFAS hang their hats at Locus, and they’ve helped us to become a market leader in compliance and ESG reporting software. Every client-facing employee at Locus has an advanced degree in science or professional EHS experience, and they incubate new ideas every day – such as how machine learning, AI, blockchain, and the Internet of Things will up the ante for EHS, ESG reporting software, and sustainability.
