Ozone Depleting Substances

Most facilities outsource the maintenance and servicing of their HVAC equipment. Nonetheless, it must be stressed that the ultimate responsibility for environmental compliance is the facility’s responsibility.

If a facility has chillers, or other equipment that contain listed ozone depleting Substances (ODS), commonly referred to as refrigerants, the facility is responsible for demonstrating compliance with the regulation by some recordkeeping and reporting. The requirements are more detailed and specific if the facility has any equipment containing ≥ 50 pounds of refrigerant.

Here is a brief questionnaire to determine inspection readiness:

• Does the facility have an inventory of all equipment containing ODS?
• Does the facility know if all the service technicians are certified?
• Does the facility receive renewed certifications of all service technicians?
• Is the refrigerant recovery equipment certified and registered with EPA?

If the facility has equipment containing ≥ 50 pounds of refrigerant per circuit:

• Does the facility calculate and keep record of the leak rate each time the equipment is serviced?
• Does the facility document initial and follow-up verification tests after each leak repair?

ODS regulations are complicated and are overlooked by many facilities.  If you have refrigerants at your facility, you must implement a compliance management plan to avoid potential Notice of Violation (NOV).

If you have questions regarding ODS regulations or want to develop a compliance management plan, call Sam Joshi at (215) 389-2811.