Refrigerant 101


In 1990, Congress amended the Clean Air Act (CAA) adding Title VI, Protection of Stratospheric Ozone, to protect the ozone layer.  The CAA prohibits knowingly venting or releasing ozone depleting and substitute refrigerants in the course of maintaining, servicing, repairing, or disposing of appliances or industrial process refrigeration.  Under the directive of the CAA, the Environmental Protection Agency (EPA) developed and implemented regulations under 40 CFR 82, Protection of Stratospheric Ozone.  The regulation consists of nine individual regulations, referred to as Subparts A – I.  Each subpart establishes requirements regarding a category related to ozone-depleting substances.  Three of the nine Subparts apply to the University.


Applicable Regulations

Federal EPA

Subpart B, Servicing of Motor Vehicle Air Conditioners (MVAC), which established requirements for servicing, maintenance, repair and disposal of air conditioners in MVAC or MVAC-like appliances; technician certification; small can sales restrictions; and other requirements for mobile air-conditioning systems.

Subpart F, Recycling and Emissions Reduction, which established requirements for reducing emissions of class I and class II refrigerants and their non-exempt substitutes to the lowest achievable level by maximizing the recapture and recycling of refrigerants during the maintenance, service, repair, and disposal of appliances; restricted the sale of refrigerants; technician certification; and other requirements for stationary refrigeration and air conditioning appliances and systems.

Subpart H, Halon Emissions Reduction, which banned the manufacture of halon blends; prohibited knowingly releasing halons during repair, testing, training, or equipment disposal; required technicians to provide emissions reduction training; and required proper disposal of halons and equipment containing halons.


State Energy and Environment Cabinet

Title V operating permit (link) issued to the main campus in Lexington contains requirements in Section G(8) to comply with Federal regulation subparts B and F.



The University has established contract requirements and Administrative Regulations (ARs) to implement Governing Regulations and provide for general administration and oversight.  ARs are official rules or directives that, among other things:

  1. Mandate requirements for members of the University community
  2. Ensure the consistent and equitable application of policies and procedures
  3. Enhance the University’s mission, reduce institutional risk, and/or promote operational efficiency
  4. Help achieve compliance with applicable federal or state law, local ordinance, or accrediting bodies

Administrative Regulation 6:3 specifically mandates compliance and assigns specific responsibilities associated with the implementation of the University’s health, safety, and environmental protection programs.

View the Official Policy: AR 6:3 Environmental Health and Safety [PDF]

Through AR 6:3 the University has established broad, yet comprehensive authority over its population of faculty, staff, and students regarding compliance with local, state, and federal environmental regulations including the Refrigerant Management Program requirements.


Refrigerant Categories

For the purposes of the RMP, an ozone-depleting substance (ODS) is a man-made substance shown to deplete stratospheric ozone consisting of compounds such as chlorofluorocarbons(CFCs), bromofluorocarbons (halons), methyl chloroform, carbon tetrachloride, methyl bromide, and hydrochlorofluorocarbons (HCFC).  ODS are further divided into two classes.  Class I compounds which includes CFCs, halons, and other ODSs that are the most threatening to the ozone layer. Class II compounds which include HCFCs are those substances that are known or reasonably anticipated to have harmful effects on the ozone layer.  A listing of Class I and II compounds are listed in Appendices A and B of 40 CFR 82, Subpart A, Production and Consumption Controls.      

Also in regards to the RMP, there are man-made compounds considered as acceptable ODS alternatives or substitutes.  Whether or not a compound qualifies as a substitute or is considered a non-exempt substitute depends on the industrial sector (e.g., refrigeration and air conditioning); the end user (e.g., chillers, refrigerators/freezers, HVAC, MVAC, water coolers); and the human health and environmental risks of the substitute compared to other substitutes for the end user.  The review and evaluation of substitute compounds (exempt or non-exempt) are regulated by the EPA Significant New Alternatives Policy (SNAP) Program.  Final determinations are published in 40 CFR 82, Subpart G, Significant New Alternatives Policy and since new substitutes are developed, Subpart G should be reviewed for substitute acceptability before converting or using new refrigerants