Refrigerant Tracking

Section 608 (40 CFR Part 82, Subpart F) applies to appliances containing 50 or more pounds of Class I or Class II refrigerant (ODS). The AIM Act's HFC Management Rule (40 CFR Part 84, Subpart C) applies to appliances containing 15 or more pounds of regulated HFCs or substitutes with a GWP above 53. The AIM Act does not apply to residential and light commercial air conditioning and heat pump systems. The two regimes can apply to the same piece of equipment simultaneously: a large commercial chiller running R-410A, for example, is subject to both. The tracking requirements are parallel but not identical. FMHero's rules engine applies the correct requirements based on charge size and refrigerant type for every asset.

Under both Section 608 (40 CFR §82.157(m)) and AIM Act Subpart C (40 CFR §84.106(l)), refrigerant records must be retained for a minimum of three years. California, New York, New Jersey and Washington all have five year document retention requirements. The clock runs from the date of each record, not from the date of a compliance event. Additionally, baseline appliance data must be retained until three years, or five years respectively, after the equipment is retired.

The technician, the contractor and the equipment owner are all responsible and can be held accountable. The technician can be fined and lose their certification. The contractor can be fined and risks public exposure and brand damage. The equipment owner, who is responsible for maintaining complete refrigerant records, can be fined and, through a consent decree, be forced to limit new stores and new equipment installations to low GWP equipment, retrofit existing systems to meet lower GWP thresholds, and even retire the worst offenders.

This trifecta of accountability is one of the primary reasons integrated tracking platforms, where technician documentation flows directly to contractor and owner records, matter more than systems where documentation is handled separately.

The primary federal recordkeeping and leak repair thresholds apply to systems at 15 pounds (AIM/HFC) and 50 pounds (Section 608/ODS). Systems below those thresholds are still subject to Section 608 recovery, venting, and certification requirements. Some states have stricter requirements that extend tracking obligations to smaller systems. California, Washington, Colorado, New York, and New Jersey all have state-level refrigerant management programs with their own documentation requirements.

A leak loss rate (also called an annualized leak rate) is the percentage of an appliance's full refrigerant charge that has been added, expressed as an annual rate. EPA provides two approved calculation methods: the annualizing method and the rolling average method. Both methods are defined in 40 CFR §84.102 and 40 CFR §82.152. Several states also specify methods for calculating leak rates. The specific applicable leak rate threshold varies by appliance category and refrigerant type. FMHero calculates leak rates automatically for every tracked asset using EPA and state specific approved formulas.

Residential systems are exempt from the AIM Act's leak repair and recordkeeping requirements under 40 CFR §84.106(a)(3)(ii), and that exemption extends to light commercial air conditioning and heat pump systems. There is one important caveat: the EPA has not clearly defined "light commercial." Contractors who assume their work fits under that label, without a defensible basis for the call, are gambling. By the time that argument is being made through lawyers in front of the EPA, the financial fight is already lost, even if the legal one is eventually won. All refrigerant containing systems, including residential and light commercial, remain subject to Section 608 requirements for recovery, no vent, technician certification and many more regardless of the AIM Act exemption.