A/C - Servicing & Recycling Regulations
REF. NO. MBNA 83/45TO: OUR MERCEDES-BENZ PASSENGER CAR DEALERS
DATE: November 1992
SUBJECT:
A/C SERVICING AND RECYCLING REGULATIONS
This Service Information contains important regulatory information concerning the servicing and recycling of A/C Systems. These new regulations are a result of the "Clean Air Act" amendments of 1990.
Dealers are urged to obtain a copy of the complete EPA (Environmental Protection Agency) regulations regarding servicing and recycling automobile A/C systems. The EPA has set up a hotline to answer any questions, 1-800-296-1996.
Topics covered in this S.I. are
^ Technician Certification (required as of January 1, 1992)
^ Dealership Certification (required by January 1, 1993)
^ EPA Approved A/C Servicing/Recycling Equipment for CFC-12 Service Work
^ Sale of Refrigerant
^ Preemption of State Laws
^ Future Requirements
Technician Certification
As of January 1, 1992, technicians performing A/C service work must be trained and certified under an EPA approved technician certification program and properly use EPA approved equipment.
Technician certificates received prior to September 1990 are no longer valid and the technician must be recertified.
The EPA has approved the following three national certification programs:
the Mobile Air Conditioning Society (MACS)
the international Mobile Air Conditioning Association (IMACA),
and the National Institute for Automotive Service Excellence (ASE).
State certification programs in Florida, Wisconsin and California (the South Coast Air Quality Management District) are presently being reviewed for EPA certification.
Dealership Certification
All dealerships/service centers performing A/C service/repair work are required to certify to the EPA, prior to January 1, 1993, that they have acquired and are properly using EPA approved equipment. The name and address of the dealership/service center, the make, model, year and serial number of the equipment and the owner's or authorized user's signature is required on the certification form. A copy of the certification form is shown.
The dealership must maintain records for a period of three years showing that all technicians authorized to use the equipment have been certified.
One year extensions were granted to small dealerships who certified themselves to the EPA before January 1, 1992. Any dealership that was not granted this extension must meet the above certification requirements.
EPA Approved A/C Servicing/Recycling Equipment for CFC-12 Service Work
The EPA allows two types of equipment to be used:
^ Recovery/recycle
The EPA has already developed a standard for this equipment. The CFC-12 is recovered and recycled within the unit, according to SAE standards.
^ Recovery only
The EPA is presently working on standards for this type of equipment. The CFC-12 is recovered but must be sent out to a separate reclamation facility or recycled on-site by other approved equipment. In order to use recovery only equipment, the dealership must maintain records for three years indicating the name and address of the reclamation center where the CFC-12 was sent. The use of several recovery only units combined with one recycling unit is permissible as long as all machines are owned by the same individual.
CFC-12 which is recycled by a reclamation center or by a separate recycling unit owned by a second party, must be cleaned to a higher standard than the SAE standard required for recovery/recycle equipment. This measure is intended to reduce the possibility of cross-contamination of automobile and stationary refrigerant. The standards on recovery only equipment will be published shortly by the EPA, for further information contact the EPA directly (see 800 telephone number shown).
Any previously purchased UL (Underwriters Laboratories) approved equipment (Design certified to meet SAE Standards) is also considered EPA approved. The EPA will consider non-UL approved equipment on a model-by-model basis; if the equipment is substantially similar in design and performance to currently certified and approved equipment, then that model will be considered approved by the EPA.
NOTE:
See MBNA Standard Equipment Program for Recovery/Recycle and Recovery Only equipment.
Sale of Refrigerant
Effective November 15, 1992, containers of refrigerant smaller than 20 lbs. may only be sold to certified technicians.
A sign must be posted wherever refrigerant is sold stating the above requirement (see illustration shown). The seller of the refrigerant must verify that the purchaser is an EPA certified A/C technician (presentation of technician certification is usually sufficient).
If the purchaser is purchasing the small container of refrigerant for resale, the purchaser must provide the seller with a Statement of Resale (see illustration shown.) which the seller must keep on file for three years.
Preemption of State laws
The EPA regulations do not supersede existing State laws or regulations. In states and localities with existing A/C recycling or certification laws/regulations, dealerships must comply with both EPA and State/local requirements.
Certification according to each jurisdiction must also be done separately; State certification does not exempt EPA certification and vice-versa.
State and local technician certification programs will also satisfy EPA certification requirements once the State programs receive EPA approval (see Technician Certification(not shown)). Please contact the EPA directly for further information.
Future Requirements
As of November 15, 1995, refrigerant R-134a will be subject to EPA regulations and must be recycled. Dealership recertification for approved R-134a equipment may be required along with technician recertification.
Under separate EPA regulations to be published later, the EPA may require:
^ automobile dismantlers and junkyards to recover remaining refrigerant from junked/scrapped vehicles,
^ may restrict the sale of CFC blends, and
^ may extend refrigerant recycling requirements to buses and off-road vehicles.
As new information concerning the subject of CFC recovery/recycling becomes available, an update to this service information will be made available.