Ozone Depleting Substances (ODS)
If you have refrigerants (R-12, R-22, etc.) at your facility, you may be at risk of non-compliance with 40 CFR 82 (Protection of Stratospheric Ozone).
Many state and local regulatory agencies do not enforce ODS regulations or even inspect for compliance during their visits. That leaves the enforcement of the regulations to the Environmental Protections Agency (EPA).
If you have chillers, or other equipment’s that contain more than 50 pounds of refrigerant per circuit, you are responsible to calculate leak rate, document leak repair methods, document leak detection methods, and notify EPA if leaks are not repaired in a timely manner.
For all refrigerant containing equipment, you are responsible for preventing negligent venting into the atmosphere.
If you answer “no” to any of the following questions, you may need assistance with your ODS regulatory compliance.
- Do you know if all your technicians are properly certified?
- Do you know if your equipment repair vendor utilizes properly certified technicians?
- Do you have an inventory of all equipment containing ODS?
- Do you or the refrigerant technician calculate leak rate every time equipment containing 50 lbs. or more refrigerant per circuit is serviced?
- Do you know if initial and follow-up verification tests are done after each leak repair?
- Is your refrigerant recovery equipment certified?
ODS regulations are complicated and are overlooked by many facilities. Since, ODS regulations are not actively enforced by state and local agencies, you may need to be proactive to avoid non-compliance.
- Overview of Industrial Stormwater Permit Regulations
- 8 points to remember regarding SPCC Plans (& recommendations)
- Nine Steps to Environmental, Health & Safety (EHS) Excellence
- 12 common RCRA violations and how to avoid them
- Community-Right-To-Know (CRTK) Primer
- Stormwater Sampling Primer
- Lockout/Tagout: (#4 on OSHA’s Top 10 list of most-cited violations)
- OSHA General Duty Clause for employers & employees
- OSHA Frequently Cited Violations for: Control of Hazardous Energy (lockout/tagout)
- A check-list to assess if your facility is in compliance with federal refrigerant regulations (40 CFR 82, Subpart F).
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