A check-list to assess if your facility is in compliance with federal refrigerant regulations (40 CFR 82, Subpart F).

Ozone Depleting Substances (ODS) Audit Checklist

General Recordkeeping Requirements

• Has the facility completed a ODS equipment inventory?
• Are copies of all service reports for any service, maintenance, repair, or disposal available for inspection?
• Are records indicating the amount of refrigerant added, recovered, or recycled available for inspection?
• Are records indicating the type of equipment used to recover or recycle refrigerants available for inspection?
• Are records of “comfort cooling refrigeration” initial and 30-day follow-up verification tests available for inspection?

Refrigerant Management

• Does the facility have a written Refrigerant Compliance Plan?
• Are leaks repaired within the 30 days allowed?
• Do service reports or work orders accurately detail leak repair activities?
• Has refrigerant compliance training for your technicians been conducted?
• Has a refrigerant inventory audit been conducted recently?
• Have initial leak verification tests been conducted and documented?
• Are equipment disposal records for equipment removed from the site available?
• Has a retrofit/replacement plan been written for systems that were not repaired within 30 days?

Service Technician

• Are all technicians certified to proper level?
• Are certification numbers on file?
• Are technicians documenting accidental refrigerant release incidents?
• Are contractors documenting refrigerant service work?
• Are contractor technician’s certifications on file?

Recovery Unit

• Are the serial numbers of recovery units on file and available?
• Is there a copy available of the recovery unit acquisition form that certifies to EPA that at least one recovery unit is on site?
• Has a leak-check of recovery units been conducted, documented?
• Are contractor recovery units EPA approved and are model and serial numbers on file?

Refrigerant Cylinders

• Are DOT 39 (disposable) cylinders being properly disposed of?
• Is there an accurate inventory of all recovery and virgin refrigerant cylinders with serial numbers or ID numbers?
• Are recovery cylinders correctly color-coded to ARI-K (gray with yellow top)?
• Are all recovery cylinders current with the 5-year re-testing date?
• Are all recovery cylinders properly labeled? Do they have a refrigerant specific tag/label and non-flammable gas tag/label attached?
• Are dedicated cylinders being used for each refrigerant type?

General Safety Issues

• Do technicians have access to MSDS?
• Have technicians received hazardous communication training for refrigerants and equipment room safety?
• Do technicians wear proper personal protective equipment?

If you have any questions contact Sam Joshi, P.E. at (215) 389-2811.