Refrigerant safety & compliance
Safe handling, venting rules, A2L refrigerants, reclaimed R-22 and hazardous-materials shipping.
The venting prohibition
Section 608(c) makes it unlawful to knowingly vent, release or dispose of refrigerant into the atmosphere during the maintenance, service, repair or disposal of appliances. That applies to HCFCs, HFCs and their substitutes. Recovery is not optional and the civil penalties are substantial.
Two narrow exceptions exist: de minimis releases associated with good-faith recovery attempts, and refrigerants that EPA has specifically exempted. Neither is a licence to open a system to atmosphere.
The AIM Act and the HFC phasedown
The American Innovation and Manufacturing Act directs EPA to cut US production and consumption of hydrofluorocarbons by 85% against a historical baseline, on a stepped schedule running to 2036. Practical consequences you will feel:
- High-GWP products get tighter and pricier. R-404A (GWP 3,922) is the clearest example — allocation-limited, and moving.
- New equipment has moved to A2L. New residential A/C and heat pumps are built for R-454B or R-32, which is why compatible A2L tools and procedures are essential.
- Reclaimed refrigerant matters more. Recovered and reclaimed product does not draw on the production allowance, so recovering properly is now commercially sensible as well as legally required.
A2L refrigerants and safe practice
R-32 and R-454B carry an ASHRAE 34 classification of A2L: lower toxicity, mildly flammable. They will not propagate a flame as readily as a hydrocarbon, but they will burn under the right conditions. Working with them requires:
- Recovery machines, gauges, vacuum pumps and leak detectors rated for flammable refrigerants.
- Ventilation at the work area and control of heat, sparks, static and open flame.
- Charging only into equipment nameplated for that specific A2L refrigerant.
- Storage of cylinders upright, secured, capped, away from heat and ignition sources.
Reclaimed R-22
Production and import of virgin HCFC-22 in the United States ended on 1 January 2020 under the Montreal Protocol phase-out schedule. Servicing existing equipment with recovered, recycled or reclaimed R-22 remains lawful. Our R-22 is reclaimed to AHRI 700 purity by a certified reclaimer, and the batch analysis ships with the cylinder.
Anyone offering “new” or “virgin” R-22 in the US today is selling you something that cannot legally be what it claims to be.
Hazardous materials transport
Refrigerant cylinders are DOT-regulated hazardous materials in transport. Every shipment leaves here packaged, marked, labelled and documented to 49 CFR by trained personnel. That is also why we ship ground only, never by air, and cannot deliver to PO boxes, APO/FPO addresses, or outside the contiguous United States.
Disclaimer
This page summarises federal requirements as we understand them in order to explain our own process. It is not legal advice, it is not exhaustive, and state and local requirements may add obligations on top. You are responsible for compliance in your own jurisdiction. Where this page and the regulation disagree, the regulation wins.
Primary sources worth bookmarking: 40 CFR Part 82 Subpart F (refrigerant management), 40 CFR 82 Subpart B (MVAC), EPA refrigerant-management guidance, and 49 CFR Parts 171–180 (hazardous materials transport).