Refrigerant Compliance: EPA and the Clean Air Act
Eighteen years ago, amendments to the Clean Air Act made refrigerant management an important operation for engineering and maintenance managers. To date, not all organizations have moved to comply with the regulations’ requirements.
Lack of compliance typically results from managers being unaware of the requirements or simply choosing to ignore them. Nonetheless, the U.S. Environmental Protection Agency (EPA) is enforcing the regulations by investigating reported leaks, conducting surprise inspections, and even offering rewards of up to $10,000 for information about unreported violations. Fines are substantial, and the EPA usually levies them on the building owner, even if a contractor committed the violation.
Even managers who have tried to comply with the regulations have found compliance is not a simple issue. The regulations are complex, and their interpretations can be contradictory. Upper management also might not fully understand the need for compliance and, therefore, provides insufficient support.
Compliance programs also might not be formal enough, resulting in unclear roles and responsibilities for those who have to carry them out. Finally, compliance programs might not include enough checks and balances to ensure technicians properly carry out the required procedures.