RMP: Service Technicians & Contractors
California law regulates the use of many newer refrigerants including R-404A, R-507A and many others due to their high-Global Warming Potential (high-GWP). Ozone depleting substances used as refrigerants such as CFC-11, CFC-12, HCFC-22 are also considered high-GWP and affected by the law.
The California Refrigerant Management Program (RMP) affects technicians and contractors who service refrigeration and air conditioning equipment using those high-GWP gases. California's required service practices for these refrigerants include having a current, valid U.S. EPA certificate, no venting, and using proper recovery and disposal procedures to prevent fugitive emissions.
Businesses with non-residential refrigeration systems have requirements that vary with the size of the largest system at each facility. Requirements include registration with the RMP, annual reporting of service events and refrigerant usage, and compliance with service practices such as conducting regular leak inspections, leak repair within 14 days of detection, and more.
Other technician resources
Technicians must have a valid U.S. EPA certification
Technicians must also work under a C-38 CSLB contractor's license
- California State Licensing Board (CSLB)
- How to apply for a CSLB contractor's license
- CSLB C38 Classification Definition (Refrigeration)
- CSLB C20 Classification Definition (HVAC)
Frequently Asked Questions:
Below are questions frequently asked by technicians about the RMP. If you have any additional questions that need to be answered, please contact Refrigerant Management Program Staff at firstname.lastname@example.org or by phone at (916) 324-2517.
What is an affected facility required to do?
Owners/operators of RMP-regulated facilities are subject to duties under the rule based on the size of the largest on-site system, including:
- Conduct periodic leak inspections;
- Promptly repair leaks;
- Keep records on-site of inspections, repairs, and high-GWP refrigerants purchased and shipped;
- Register any facility with a system containing over 50 pounds of high-GWP refrigerant;
- Report to CARB annually for any facility with a system containing 200 or more pounds of high-GWP refrigerant.
What equipment or appliances are subject to the rule?
It depends on if you are a facility owner or a service contractor/technician. The RMP required service practices (section 95390) apply to any person performing any installation, maintenance, service, repair, or disposal of a stationary appliance. “Appliance”, as defined in the rule, means any device which contains and uses a high-GWP refrigerant, including any air conditioner, refrigerator, chiller, freezer, or refrigeration system.
Facility owners or operators are subject to the rule if all of the following apply:
- If it is a non-residential facility;
- If the single largest refrigeration system in the facility has a refrigerant charge of more than 50 pounds; and
- If the system uses a high-GWP refrigerant.
The types of businesses that commonly use the applicable refrigeration systems include but are not limited to supermarkets, cold storage warehouses, food processing plants, and industries with process cooling operations.
What refrigerants are subject to the rule?
High-GWP refrigerants include all commonly used chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) with a global warming potential (GWP) greater than or equal to 150. The rule also includes all ozone-depleting refrigerants regardless of GWP regulated under Federal Rule 608. Refrigerants that are not covered under the new California rule include ammonia, carbon dioxide and HFC-152a, which has a GWP less than 150 and is also non-ozone-depleting.
If a facility uses a chiller with more than 50 pounds of high-GWP refrigerant for both air conditioning and process cooling, are they subject to the rule?
Yes. This facility will fall into the category of “Other refrigeration” and will be subject to the rule. “Other refrigeration” means any stationary, non-residential appliance that is used for an application other than industrial process refrigeration, commercial refrigeration, or air-conditioning, or is used for two or more applications including industrial process refrigeration, commercial refrigeration, or air-conditioning.
How do I determine the size category of a facility’s system?
Facilities with applicable refrigeration systems are categorized as:
- Small: Refrigeration systems using more than 50 pounds, but less than 200 pounds, of a high-GWP refrigerant.
- Medium: Refrigeration systems using more than 200 pounds or more, but less than 2,000 pounds, of a high-GWP refrigerant.
- Large: Refrigeration systems using 2,000 pounds or more of a high-GWP refrigerant.
Refrigeration systems with multiple circuits connected by a valve or conduit through which a refrigerant could flow, are considered a single system. As an example, if a refrigeration system with two circuits can be charged at a single point, and each circuit has a 150 pound normal operating charge, the total charge of that system would be considered a medium, 300-pound system. If a system has two, 150-pound charged circuits that are completely separate or isolated, then the system would be considered small.
Facilities with multiple refrigeration systems at the same site are categorized only by the single, largest system on site. For example, if a facility has one large and three medium systems, the facility would be categorized as large and the annual fee would be $370 and the facility owner/operator would be subject to the registration and reporting schedule for large refrigeration systems that begin in 2012.
When are leak inspections required?
Facility owner or operators are required to conduct leak inspections depending on the size of the refrigeration systems. Beginning 2011, monthly inspections for large systems (continuous monitoring is required beginning 2012), quarterly inspections for medium systems, and annual inspections for small systems. Adding refrigerant to a system, other than for seasonal adjustments and/or detection of visible oil residual would also require a leak inspection be conducted.
Large systems that do not operate year round or have major components outside the building are only subject to quarterly inspections.
Is there a specific method of leak detection required by the new rule?
For large systems that are intended to operate year round, automatic leak detection systems must be installed by January 1, 2012, and annually calibrated. Otherwise, portable leak detection devices, bubble tests or other approved methods can be used for medium and small systems. Portable devices should be calibrated to ensure they are functioning properly and sensitive enough to detect leaks.
For automatic leak detection systems, how many and where should monitors be installed?
There is no specific number of monitors that must be installed. This provides flexibility for the facility owner based on refrigeration system design and configuration. Sensors or intakes must be placed so that they will continuously monitor the refrigerant concentrations in air in proximity of the compressor, evaporator, condenser, and other areas with a high potential for a refrigerant leak. The intent of this requirement is to detect and repair leaks in a timely manner. For example, if all leak prone components are in one machine room then the sensors can be placed in one room. However, if refrigerant is distributed to several compressors and display cases throughout a facility, more sensors may be needed to effectively monitor any leaks.
When should a leak be repaired?
The new statewide rule is more stringent than Federal rule (section 608) and requires any amount of refrigerant leak from an affected refrigeration system to be repaired within 14 days of detection. Additional time may be allowed in certain conditions. Service technicians and contractors should not add refrigerant to any appliance with a known leak (regardless of size and including air conditioning systems).
Who can repair leaks?
Repairs can only be made by U.S. EPA certified technicians who also hold an active California contractors license in the C38 (Refrigeration). Exceptions for a California contractors license are included in section 95386(h) of the regulation.
What type of equipment must be used?
Service technicians and contractors must use certified refrigerant recovery or recycling equipment as specified by the certified refrigerant recovery or recycling equipment manufacturer, unless the manufacturer's specifications conflict with the procedures approved by the U.S. EPA or the Executive Officer for the certified refrigerant recovery or recycling equipment. A recovery attempt using certified refrigerant recovery or recycling equipment for that type of appliance must be used before opening the appliance to atmospheric conditions. Attempts to recover refrigerant must be made even if the person believes that all refrigerant has been removed or has previously leaked from the appliance. Refrigerant may be returned to the appliance from which it is recovered or to another appliance owned by the same person without being recycled or reclaimed. Service technicians and contractors must employ procedures for which the certified refrigerant recovery or recycling equipment was approved by the U.S. EPA.
What should I do with empty refrigerant cylinders?
Non-refillable refrigerant cylinders must be evacuated to a vacuum of 15 inches of mercury (relative to standard atmospheric pressure of 29.9 inches of mercury) before recycling or disposal.