The regulations do not ask who your contractor is. They ask:
Can the owner prove compliance for this piece of equipment, for this service event, at this point in time?”
FMHero is designed to answer that question — automatically — by capturing equipment data, refrigerant movement, service activity, and compliance outcomes in a single, defensible system of record.
This paper explains the process owners must follow, with inline regulatory citations, and shows where FMHero directly supports each obligation.
How to Read This Guide
This guide is organized around what equipment owners actually do:
Own equipment
Service equipment
Respond to leaks
Fix problems (or decide not to)
Prove what happened later
Regulations are cited inline, but they are intentionally secondary to the compliance process.
Remember – This is a guide, not legal advice. Rules change and can be subject to legal interpretation and case law. EPA regulations are the minimum standard – many states have far more restrictive regulations.
Understanding the Regulatory Landscape
Equipment Owners and Operators along with the contractors they work with, as well as the supporting wholesale distributors, refrigerant reclaimers, equipment and scrap recyclers, and all others who participate in the industry are subject to federal, and often state, refrigerant management regulations.
This white paper will focus on the federal regulations under Title VI of the Clean Air Act, specifically through Section 608 and the AIM Act provisions.
From an equipment owner and service provider perspective these two regulations are very similar as the changes brought through the AIM Act dovetail and extend what was previously addressed in 608 through the regulations.
STEP 1
What Do I Need to Know About Each Piece of Equipment?
The Owner’s First Obligation: Equipment Awareness
For stationary refrigerant-containing appliances, the owner or operator must know and maintain, at a minimum:
Equipment location (address of the site the equipment is located)
Equipment identity (typically Make/Model/Serial but can include unit identifiers such as “Rack A” or “RTU 1” as well; identification must be unique to that piece of equipment)
Refrigerant type
Full refrigerant charge
How the full charge was determined
Installation date
Any subsequent revisions to the full charge and why the adjustment was made
Regulatory class (comfort cooling, commercial refrigeration, industrial process, other)
Operational status (operational, shutdown, mothballed, etc)
This obligation exists before any leak occurs and before any service is performed.
HELPFUL HINT A unit, system or piece of equipment is an “Appliance” (40 CFR 82.152 “Appliance”) by definition and each independent circuit in a multi-circuit unit is also considered its own “appliance”.
REGULATORY BASIS:
Owners must determine and maintain full charge and identifying information for appliances ≥15 lb under AIM (40 CFR §84.106(l) (1))
Parallel recordkeeping exists under Section 608 for appliances ≥50 lb (40 CFR §82.157(l))
Both regulations apply with equal penalties for non-compliance (see section 11).
HOW FMHERO HELPS
Centralized equipment registry
Full charge tracking with method attribution
Immutable equipment history
STEP 2
What Applies Every Time My Equipment Is Serviced?
NOTE: Before diving into service requirements, owners must first determine which regulations apply to each appliance based on refrigerant type and total charge. See Step 3 for applicability thresholds. The following steps are required on ALL regulated equipment service events regardless of size or refrigerant type.
Service Documentation
Technicians are required to provide equipment owners basic information:
Technician performing the work
Location of equipment (address)
Date of work performed (service / install / repair / disposal)
Part(s) installed, serviced, repaired or disposed of
Amount of refrigerant added or removed
Leak(s) inspected, repaired or re-inspected (see step 3 for applicability detail)
All technicians servicing covered equipment must hold valid EPA Section 608 certification to ensure the service on their equipment begins with a compliant technician. While the certification obligation rests on the technician, many owners verify certification as part of their contractor qualification process.
Every time refrigerant is added to an appliance, the owner must:
Obtain service documentation
Determine whether a leak rate calculation is required
Retain records of refrigerant quantities and dates
REGULATORY BASIS: Leak rate must be calculated each time refrigerant is added unless an exception applies 40 CFR §84.106(b); 40 CFR §82.157(b)
UNIVERSAL RULE:
Refrigerant Recovery Triggers Accountability
Every time refrigerant is removed from an appliance, the owner must:
Obtain service documentation
Ensure technician and recovery equipment are certified
Document final disposition of refrigerant. (stored onsite or a documented transfer to a reclaimer or contractor solely for the purposes of being reclaimed or destroyed)
When refrigerant is fully removed from a system (for decommissioning, major repair, or storage), owners must still document the removal event, quantities recovered, and final disposition of the refrigerant. The absence of refrigerant does not eliminate recordkeeping obligations for the removal event itself.
HOW FMHERO HELPS
Realtime Service Event tracking directly from the technicians in the field
Service-event-based compliance logic
Technician certification tracking
Automatic exception handling and documentation access
Full traceability and history for all refrigerant movement
STEP 3
Does This Equipment Trigger Leak Rules?
Determining Applicability Is a Size + Refrigerant Question
Any regulated appliance that loses 125% or more of the full charge in a calendar year requires self-reporting to the EPA by March 1 of the subsequent year. (15+ lbs HFC / 50+ lbs ODS).
There are no exceptions.
This 125% threshold is based on total refrigerant loss during the calendar year, not the calculated leak rate. This means losses accumulate even after a successful repair process the leak rate to 0%.
Scenarios that could apply:
Copper thieves cause a 100% loss on a system that had previously leaked 25% that year (even if that system had already been repaired and the leak rate legally “reset” to 0%)
A previously leaky system was repaired, subsequently had a catastrophic failure of a pressure relief and lost 100% of its charge
An on-site fire caused catastrophic loss of all equipment — any regulated equipment with leaks greater than 25% that year prior to the fire must be reported
An alternative to immediate repair is mothballing — temporarily taking equipment out of service. Mothballing stops the repair clock but comes with specific requirements:
The appliance or affectioned isolated section / component must be evacuated to at least atmospheric pressure
The owner must document the date of mothballing
The appliance cannot be returned to service until all identified leaks are repaired
Mothballed appliances are not subject to the repair timeline while mothballed
