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Motor vehicle A/C servicing requirements, safety concerns

June 6, 2014
Now that summer has begun and the temperature outside begins to rise, it’s a good time to review the dealership’s Motor Vehicle Air Conditioners (MVAC) requirements.
The handling and recycling of refrigerants used in motor vehicle air-conditioning systems is regulated by the Environmental Protection Agency under Section 609 of the Clean Air Act.  The Air Protection Branch of the EPA historically has been very strict with its enforcement. The Clean Air Act often has some of the heaviest fines, so this is not something to ignore.
Equipment Requirements
• Ensure that the dealership is using only EPA Certified Refrigerant Handling Equipment.
• Ensure that the EPA has been notified that the dealership is performing MVAC work by sending in the MVAC Refrigerant Recovery/Recycling Equipment Form.
• Keep a copy of the completed form sent in, along with the delivery receipt, for proof that the dealership notified the EPA about the MVAC work.
Technician Requirements
• Ensure that all technicians doing MVAC work have passed an EPA-approved certification program. ASE and MACS are the most commonly used online training programs, but there are others available; ensure that it was one of the EPA-Approved Technician Certification Programs. 
• Keep copies of all the technicians’ certification cards on file. Any technicians unable to locate their certification cards will need to obtain a copy from the program they used.  Do not allow technicians to perform any MVAC work until they have provided a certification proof.  The fines for uncertified techs doing MVAC work usually are $15,000 per technician, per work order.
• Do not purge this file after technicians have departed the dealership. The EPA requests proof of technician certification for previously performed work. 
Additional Recordkeeping Requirements
• Service shops must maintain records of the name and address of any facility where refrigerant is sent.
• If refrigerant is recovered and sent to a reclamation facility, the name and address of that facility must be kept on file.
Safety Concerns
A new concern related to MVAC work has been the recent appearance of counterfeit R-134a refrigerant cylinders that are being sold in the U.S.  Many of these are contaminated with R-40 gas (Methyl Chloride), which will mimic pure R-134a at a much reduced cost. Systems that have been contaminated will pose a major safety issue to those working on them, as R-40 gas is flammable, toxic, and often chemically reactive.   
More than 10,000 counterfeit cylinders already have been seized worldwide and counterfeit refrigerants can make automotive AC systems unserviceable due to safety concerns such as a potential fire or explosion. The industry currently is working on, but has not determined, the best service procedures to be used in these cases. The best precautions to employ currently would be to check the freon cylinders for signs that may indicate it could be counterfeit:
• Many counterfeits are illegally labeled with common brand names, but these counterfeit labels often are easy to detect by common spelling errors.
• Many of the seized counterfeit Freon cylinders do not state that the product is 100 percent R134a.
• R-134a refrigerant sold at below market value price is a good indicator that it may be counterfeit.
This article is provided by KPA, a CATA allied member that provides environment and safety services for auto dealers. Direct additional questions to KPA at or (800) 853-9659.