Earlier this summer, the U.S. Environmental Protection Agency proposed regulations that would continue to expand its jurisdiction in the service, repair and maintenance of air conditioning and refrigeration equipment. Under Section 608 of the Clean Air Act, it is illegal to knowingly vent substitutes for chlorofluorocarbon (CFC) and hydrochlorofluorocarbon (HCFC) refrigerants while servicing a vehicle.

The new regulations would:

• exempt certain substitute refrigerants from the venting prohibition
• extend to hydrofluorocarbon (HFC) and perfluorocarbon (PFC) refrigerants the requirements currently in place for CFC and HCFC refrigerants, including required practices; certification programs for recovery/recycling equipment, reclaimers and technicians; a prohibition on the sale of refrigerants to anyone but certified technicians; leak repair requirements; and safe disposal requirements
• make minor changes to the required practices, recovery equipment standards and refrigerant purity standards for CFCs and HCFCs to accommodate the addition of HFC and PFC refrigerants
• lower the maximum allowable leak rates for comfort cooling chillers, commercial refrigeration and industrial process refrigeration. The new maximum allowable leak rates would apply to equipment containing CFCs, HCFCs, HFCs and PFCs.

The Automotive Service Association has had a very clear policy on refrigerants for some time. ASA recommends the use of HFC-134a for retrofitting of CFC-12 systems. ASA recommends the continued use of CFC-12 when servicing the customer's vehicle until cost and availability become prohibitive.

With regard to the current proposed regulations, ASA has submitted formal comments to EPA for review. ASA supports the proposed rules with additional suggestions. The sales restrictions and technician training extended to HFCs and PFCs are appropriate under the Clean Air Act. In 1994, EPA established the Significant New Alternatives Policy (SNAP) to review the alternatives to ozone-depleting CFC-12. ASA has been a supporter of the SNAP program; however, it is evident that the extensive testing and development efforts that went into the decision to use HFC-134a by automobile manufacturers indicate that it is the best alternative refrigerant at the current time.

Technician certification, sales restrictions, recycling and recovery equipment, leak repair requirements, and safe disposal requirements are all critical elements of any long-term successful refrigerant program. In particular, the technician certification program has worked well. ASA and the National Automobile Dealers Association (NADA) have suggested the same concept be used in controlling the sale of paint products to collision repairers.

EPA's proposed rule does not address the sale of retrofit kits directly to consumers. The retrofit kits provide no method for the consumer to safely recover any residual refrigerant in their vehicle system. It is feared that the consumer will vent this residual refrigerant directly to the atmosphere. Allowing only certified technicians to purchase refrigerants will greatly reduce or totally eliminate this possibility.

Consumers sometimes purchase these kits and only complete a portion of the retrofit before taking their vehicle to a service center for repair. There are cases where the consumer does not mention to the technician that they have attempted to retrofit the air conditioning system. This is a practice that clearly could lead to the contamination of the shop's very expensive refrigerant recovery equipment.

At ASA's 1998 Annual Convention, a top EPA refrigerant official briefed ASA members on EPA's efforts to regulate refrigerants. This exchange gave ASA members an opportunity to express their views and be a part of the development of federal regulations in lieu of always reacting to existing regulations.

ASA's policy has been to work with agencies as early as possible to ensure that independent repairers are protected and enhanced by federal and state regulations. Although this is not always possible, it certainly benefits ASA members if it can be achieved. Participation in state advisory committees, federal advisory committees and agency working groups allow repairers to voice concerns early and assist regulators in better understanding our industry.

Bob Redding is the Automotive Service Association's Washington, D.C., representative. He is a member of several federal and state advisory committees involved in the automotive industry. For more information about the legislative activities of ASA, visit www.TakingTheHill.com.

RATE THIS ARTICLE What do you think of this article? Your input will help AutoInc. develop additional articles on this subject. Share your thoughts! Your name Your e-mail address

MOST ACCESSED ARTICLES Fuel Injection Service, Not Just Cleaning The Art of Extraction EGR Systems: Operation and Diagnosis Proactive Target Marketing:_Rethinking Your Business Strategy Engine Performance: HO2S Diagnostics MOST E-MAILED ARTICLES Developing Employee Potential How Critical Thinking Can Help Your Business How to Diagnose the Ford Glow Plug What to Look for When Shopping for the Right Shop Management Software Putting a Price Tag on Complaints

AutoInc. Web Site | ASA Web Site | EPA Expands Refrigerant Regulations | Caught Between the Past and the Future | Automated Estimating Systems Ease Body Shop Life Despite Problems | How Shops Compensate Technicians | Guest Editorial | Tech to Tech | Tech Tips | Shop Profile | Net Worth | Stat Corner | Chairman's Message