In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking about HVAC training for personnel detaching lines that contain R-134a. See what the experts had to say.
Q: Is HVAC training or other certification required for personnel detaching lines containing R-134a?
Complete Question: We use a certified HVAC vendor for all maintenance of HVAC systems within our equipment. On occasion, it is quicker to replace a unit rather than fix a down unit. Replacement requires disconnecting four lines with self-sealing couplings that contain R-134a. The self-sealing couplings have been known to fail. Is HVAC certification or other training required to disconnect these lines or can it be done by anyone?
Answer: Anyone detaching lines or hoses containing R-134a must be a certified technician.
Federal regulations under 40 CFR 82.152 define a “refrigerant” as “any substance, including blends and mixtures, consisting in part or whole of a class I or class II ozone-depleting substance or substitute that is used for heat transfer purposes and provides a cooling effect.” The regulations also state that examples of “substitute” refrigerants “include, but are not limited to hydrofluorocarbons, perfluorocarbons, hydrofluoroolefins, hydrofluoroethers, hydrocarbons, ammonia, carbon dioxide, and blends thereof.” R-134a is a hydrofluorocarbon, and is therefore considered a regulated refrigerant under 40 CFR 82.
40 CFR 82.152 also defines “technician” as any person who in the course of maintenance, service, repair, or disposal of an appliance could be reasonably expected to violate the integrity of the refrigerant circuit and therefore release refrigerants into the environment. Activities reasonably expected to violate the integrity of the refrigerant circuit include but are not limited to: Attaching or detaching hoses and gauges to and from the appliance; adding or removing refrigerant; adding or removing components; and cutting the refrigerant line. Activities such as painting the appliance, rewiring an external electrical circuit, replacing insulation on a length of pipe, or tightening nuts and bolts are not reasonably expected to violate the integrity of the refrigerant circuit.
So based on the actions described in the question submitted, anyone disconnecting the lines containing R-134a would be considered a technician violating the integrity of the refrigerant circuit.
Per 40 CFR 82.1619(a)(1), “Any person who could be reasonably expected to violate the integrity of the refrigerant circuit during the maintenance, service, repair, or disposal of appliances containing a class I or class II refrigerant or a non-exempt substitute refrigerant must pass a certification exam offered by an approved technician certification program.”
