Checklists: Motor Vehicle Air Conditioners Information Shop Tour Stop #1
|The following questions and cash loan today guidance are taken from the Consolidated Screening Checklist for Automotive Repair Facilities Guidebook.
A ‘√’ next to a response in the guide indicates that is the preferred response in terms of environmental compliance. If you select a response without a ‘√’, you may still be in compliance; however, you should verify that you are in compliance by contacting the appropriate federal or state regulatory agency and discussing your activity with them. MOTOR VEHICLE AIR CONDITIONERSDoes the facility employ trained and EPA certified technicians?
Technicians that service motor vehicle air-conditioning units must be properly trained and EPA Section 609 certified. Each technician must have his or her own certification. Certificates must be kept at the place of business.
Does the facility remove all refrigerant from the MVAC prior to maintenance activities?
Before the technician can begin repairing the MVAC unit, all of the refrigerant in the unit must be removed and collected with the use of EPA-certified refrigerant recovery/recycling equipment.
Has the facility ensured that its CFCs are purchased legally?
Investigating the source of R-12 and the chain of ownership is the facility’s responsibility! The automotive shop owner or manager should know the source of the purchased CFCs. Before buying CFCs, the owner or manager should ask the seller for documents of prior ownership of the product and a laboratory analysis of the quality.
If the material is imported, a facility should know when, where, and from whom it was imported. The shop manager should check the containers when they arrive. Illegally imported refrigerant is sometimes packaged in wrong size containers or fixed with improper valves. Remember, if a facility purchases or possesses CFCs that entered the United States illegally, the U.S. Customs Service can confiscate the product. Other potential consequences for purchasing or possessing illegal CFCs include becoming the subject of an investigation by the Customs Service, EPA, and the Internal Revenue Service (IRS). The IRS reviews the incident to determine if there is a failure to pay the tax that is assessed on legally imported CFCs.
Warning: If a facility knowingly buys or possesses CFCs smuggled into the United States, it is committing a punishable, criminal offense and could face severe penalties.
Does the facility service and/or retrofit Motor Vehicle Air Conditioning (MVAC) with alternative refrigerants?
Alternative refrigerants may include, but are not limited to: Hot Shot, Freezone, HFC-134a, etc.
If “yes” to previous question, are the alternative refrigerants approved under the Significant New Alternatives Policy (SNAP)?
In 1994, EPA established the SNAP Program to review alternatives to ozone-depleting substances like CFC-12. Under the authority of the 1990 Clean Air Act, EPA examines new substitutes for their ozone-depleting, global warming, flammability, and toxicity characteristics. EPA has determined that several refrigerants are acceptable for use as CFC-12 replacements in motor vehicle air conditioning systems, subject to certain use conditions. A regularly updated list of SNAP-approved MVAC refrigerants is available at www.epa.gov/ozone/snap/refrigerants/lists/mvacs.html.
If “yes” to previous question, does the facility have recovery/recycling equipment certified for each particular refrigerant removed from the MVAC unit?
When retrofitting, does the facility:
Remove all R-12?
Install unique service fittings?
Affix permanent labels?
Install barrier hoses (required for R-22 blends)?
Install compressor shut-off switches?
|Source: U.S. EPA Office of Enforcement and Compliance Assurance, EPA 305-B-03-004, October 2003. Click here to send questions or comments to CCAR®.|