How to connect EPA Section 608, AIM Act, and Operations Into a Single System?
Ever wonder why Industry Refrigerant Policies Fail?
There are as many as 19 regulations that impact refrigerant buying, and although regulations like EPA Section 608 (established 30 years ago) were originally established to address ozone-depleting substances and protect the ozone layer, they have been responding to environmental threats highlighted by international agreements like the Montreal Protocol.
Over time, these regulations have evolved to also address the impact of refrigerants on climate change (aka Non-Financial Data reporting under ESG Scope 1) and extend to the AIM Act and the phase-down of high-GWP substances.
Most recently, the EPA finalized updates to Section 608, with the EPA’s Office and its Stratospheric Protection Division playing a central role in developing and enforcing these federal regulations.
But that doesn’t tell the whole story.
The Regulatory-Operational Reality: Nothing Lives in a Vacuum
Here’s what makes refrigerant management uniquely complex: regulatory compliance, procurement decisions, and facilities operations don’t exist in separate silos. They’re interconnected systems that must be aligned.
Consider what happens when you buy new HVAC equipment:
Regulatory Impact
The AIM Act mandates GWP limits and reclaimed refrigerant percentages that vary by equipment type and date.
California’s regulations add stricter timelines.
EPA Section 608 governs leak repair and reporting, while the EPA’s alternatives policy further guides refrigerant selection and procurement by restricting high-GWP options and encouraging the adoption of environmentally friendly alternatives.
📌 Organizations must ensure their procedures comply with all applicable federal and local regulations to maintain audit-ready compliance.
Procurement Impact
Your purchase order must document GWP compliance before signing. Your supplier must guarantee reclaimed refrigerant availability.
Your asset data must be entered into the compliance system within 30 days.
Operations Impact
Your technicians must track every refrigerant transaction.
Your leak detection schedule must meet state-specific timelines, and you must also consider local regulations that may affect repair timelines and compliance obligations. Your payment system must enforce data entry compliance.
Also, operations are impacted by shortages, allowable use, and equipment installations funded through capex.
📌 Miss any one of these connections, and the entire system fails.
Align your teams today.
You can have a perfect procurement policy, but if operations can’t track the assets, you’re non-compliant. You can have excellent technicians, but if procurement introduces non-compliant equipment, they inherit a crisis.
This is why industry policies from respected organizations create confusion. They address decarbonization goals, mention regulations, and suggest procurement standards, but they rarely explain how these three domains must be blended and aligned into a single operational system.
Industry policies from respected organizations like the Sustainable Purchasing Leadership Council continue to emerge and they’re essential.
These frameworks establish why refrigerant management matters, provide regulatory context, and build the case for investment.
But here’s the challenge these organizations rarely acknowledge: one-size-fits-all policies create confusion precisely because they come from respected sources.
When the SPLC or similar groups publish guidance, facilities teams treat it as gospel, then struggle to implement it because the guidance doesn’t account for internal distinctions:
- A 10-location grocery chain has a different operational maturity than a 2,000-location retailer.
- A university with in-house facilities staff operates differently from a hospital system using third-party contractors.
- California operations face different timelines than federal-only compliance states.
The result?
Well-intentioned policies sit on shared drives, referenced in sustainability reports but disconnected from daily operations.
Not because they’re wrong—but because they stop at the 50,000-foot level and never help you translate universal guidance into procedures that fit your operational reality.
This article is a buyer’s guide: how to take industry policies and develop internal procedures that blend regulatory requirements, procurement controls, and operational capabilities into a single, aligned system.
The goal is to help you become a better refrigerant buyer by building compliance-by-design—audit-ready frameworks that transform prescriptive guidance into operational systems with real accountability, data integrity, and asset visibility.
Starting Point: Why SPLC Guidance Is Essential (But Insufficient)
The Sustainable Purchasing Leadership Council’s refrigerant guidance recently published a buyer’s guide, and it is a great place to begin.
Their work attempts to synthesize complex regulatory frameworks, establish the business case for refrigerant management, and provide the vocabulary needed to discuss this issue with leadership.
But it falls short of being usable and relevant when deploying the plan into your company.
The SPLC framework is foundational. But not operational.
Their guidance tells you what to do: track refrigerant transactions, repair leaks promptly, and buy low-GWP equipment. This works brilliantly for building consensus and justifying the budget.
But when facilities teams try to implement these policies, confusion sets in. Not because the guidance is wrong, but because it’s written for everyone, which means it’s written for no one’s specific operational reality.
The One-Size-Fits-All Problem
Respected organizations like SPLC face an impossible task: provide guidance that works for:
- 5-location businesses and 500-location enterprises
- Organizations with mature compliance systems and those starting from zero
- In-house facilities teams and outsourced service contractors
- Federal-only compliance states and California’s stricter timelines
The result is necessarily generic.
The SPLC tells you to “assign responsibility for refrigerant tracking”, but it can’t tell you whether that responsibility should sit with your Facilities Director, your EHS Manager, your Sustainability Team, or a third-party contractor.
It depends entirely on your organizational structure, which is different from everyone else’s.
This creates a paradox: the more respected the source, the more organizations assume the guidance is sufficient—and the more confused they become when implementation fails.
The Missing Layer: Regulatory-Operational Alignment
Industry policies typically address three domains separately:
- Decarbonization Goals: “Reduce HFC emissions to meet Scope 1 targets.”
- Regulatory Requirements: “Comply with EPA Section 608, AIM Act, state regulations.”
- Procurement Guidance: “Buy low-GWP equipment and use reclaimed refrigerant.”
But they rarely explain how these domains must operate as a blended, aligned system. In practice:
Regulations affect buying
AIM Act GWP limits determine which equipment you can purchase, and technology transitions mandated by EPA Section 608 and related rules drive procurement decisions toward lower-GWP alternatives.
Sector-based restrictions and the significant new alternatives policy further shape procurement decisions and technology transitions by specifying allowable refrigerants and phasing out high-GWP options in certain industry segments.
Reclaimed refrigerant mandates affect supplier relationships and pricing.
Buying affects operations
Every purchase order creates a 10-15-year operational compliance obligation. Equipment choices determine leak detection schedules, repair timelines, and reporting requirements.
Operations affect decarbonization
Your technicians’ data capture rate directly determines whether you can calculate emissions accurately. Your leak repair timeline determines whether you meet Scope 1 reduction targets.
These don’t live in a vacuum.
A procurement policy that says “buy low-GWP equipment” is meaningless if your operations team doesn’t know how to verify GWP compliance at delivery.
A sustainability goal to “reduce Scope 1 emissions 20% by 2030” is aspirational fiction if your compliance system can’t measure current leak rates.
Translation Framework: From Industry Policy to Aligned Internal Procedures
Here’s how to use SPLC-type guidance effectively. For streamlined refrigerant management and compliance, consider using tools like Tag Wizard.
Step 1: Accept it as the “what” and “why”
- Use it to build leadership buy-in
- Reference it in sustainability reports and compliance documentation
- Treat it as the regulatory and climate context
Step 2: Conduct your operational diagnosis across all three domains
- Regulatory Baseline
What are your federal, state, and local compliance obligations? Which timelines are strictest? - Procurement Reality
What’s your present success rate for verifying GWP compliance before purchase? Can your suppliers guarantee reclaimed refrigerant availability? - Operations Capability
What percentage of refrigerant transactions are captured within 48 hours? What’s your leak repair timeline success rate?
Step 3: Build procedures that blend all three into a single system
- Define roles based on your org chart, not generic titles
- Create workflows that connect purchasing to asset registration to service tracking
- Establish enforcement mechanisms that span procurement (PO approval), operations (payment suspension), and compliance (automated flagging)
- Monitor for other adjustments to regulatory requirements, such as amendments to emission limits or compliance measures under the AIM Act and Clean Air Act, as these may impact your compliance obligations and operational procedures.
The sections that follow show you exactly how to do this for three critical areas: asset auditing, procurement verification, and leak repair accountability—with each section demonstrating how regulatory requirements, purchasing decisions, and operational capabilities must align.
Asset Auditing: Where Regulations, Buying History, and Operations Collide
The EPA historically focused on systems ≥50 lbs. The SPLC correctly notes this misses smaller units.
But this generic warning fails to capture the regulatory expansion underway (now including comfort cooling appliances such as chillers and split systems within the ≥15 lbs threshold, as well as industrial process refrigeration equipment and refrigeration systems used in convenience stores), broadening the range of assets now subject to regulatory tracking.
More importantly, it doesn’t force organizations to investigate their current asset visibility across the entire buying-to-operations lifecycle.
📌 Don’t let regulatory shifts catch you off guard.
The Blended Reality: How Regulations Changed What You Need to Know About What You Bought
Regulatory Shift
The threshold dropped from ≥50 lbs to ≥15 lbs for HFCs with GWP>53 (effective 2024). This isn’t just a number change—it’s a fundamental expansion of compliance scope.
Buying Impact
Every mini-split, server room AC unit, and small refrigeration case purchased in the last 5-10 years suddenly matters for compliance—even though nobody tracked them at purchase because they were below the old 50 lb threshold.
Operations Impact
Your facilities team must now conduct a physical audit across all departments (IT, Operations, Kitchens) to register systems that were never documented when purchased.
Refrigerated transport units should also be included in compliance tracking and asset audits, as they play a critical role in cold chain management and are subject to EPA Section 608 requirements.
As part of compliance tracking, it is also critical to document all appliance repair activities, including leak identification, repair actions, and follow-up testing, to meet EPA Section 608 requirements.
This creates an immediate operational crisis because the buying decisions were made years ago by people who no longer work there.
These three domains are inseparable.
You can’t audit what you don’t know you bought. You can’t track what operations were never recorded.
You can’t comply with regulations that apply retroactively to purchasing decisions made before the rules changed.
The Dictate vs. The Investigation
| SPLC Guidance (The “What”) | Internal Compliance (The “How”) | The Investigative Question: What’s Your Present State Across All Three Domains? |
|---|---|---|
| HFC emissions are typically from large cooling units. Inventories often overlook emissions from smaller cooling units. | The policy now applies to HVAC/refrigeration systems starting at 15 lbs—a significant expansion from the legacy 50 lbs. Minimizing releases of refrigerants is now a key operational and regulatory goal, making robust leak detection and tracking essential for compliance and sustainability. | Regulatory: Which systems in your portfolio now require tracking that didn’t before? Buying: Who purchased these systems, and was refrigerant charge documented at installation? Operations: How many 15-50 lb assets do you currently have documented in your compliance system? If the answer is “we don’t know,” what is preventing you from knowing—lack of centralized asset data, departmental silos, or missing purchase records? |
| Assign responsibility for refrigerant inventory and tracking. | All refrigerant transactions must be recorded in Regulatory Compliance Software within 48 hours. No invoices processed unless entries are complete and verified. | Regulatory: What are the reporting requirements for your jurisdiction? Buying: When new equipment is purchased, who is responsible for entering asset data into the compliance system—procurement, the installer, or facilities? Operations: Pull 90 days of service invoices. What percentage were entered into your compliance system within 48 hours? What percentage were entered at all? If you’re below 80% compliance, your policy is aspirational fiction. The real question is: What is breaking—field technician behavior, lack of mobile data entry tools, or absence of invoice-payment enforcement? |
The Systemic Failure Hiding in Plain Sight
The goal is no longer a simple inventory: it’s systemized, auditable digital tracking that connects every purchase decision to operational compliance requirements.
This ensures that all information submitted for EPA Section 608 compliance (such as documentation of leak repairs, the process of removing refrigerant during repairs or equipment retirement, retrofit or retirement plans, and requests for extensions) is accurate and complete, supporting regulatory adherence and traceability.
Procurement Verification: Where Regulations Transform Every Purchase Into a Long-Term Operational Obligation
The SPLC advises: “Set clear energy efficiency minimums and refrigerant GWP limits” and “Mandate reclaimed refrigerant.”
Sound advice, but only useful if the organization understands that every equipment purchase creates a 10-15 year compliance obligation that operations must execute, including tracking delivery time to ensure timely asset registration and ongoing regulatory compliance.
These requirements are part of broader efforts by agencies like the EPA to regulate hydrofluorocarbons under legislation such as the AIM Act, aiming to reduce the environmental impact of HFCs.
The real question isn’t “Should we have these standards?”
It’s “Can we prove our buying decisions align with regulatory requirements, and do our operations have the capability to manage what we just purchased?”
The Blended Reality: How AIM Act Regulations Changed What It Means to Buy Refrigeration Equipment
We have to shift from statements like” Track every refrigerant transaction” to something like: “How do we track?
Is our system of accounting built to track this? What if we haven’t been?
I work with a lot of CMMS tools, and recently I was working on a policy plan for a decent-sized company.
The policy was to track all refrigerants. When I queried their CMMS system, I found that it did not even require assets to be recorded when getting paid.
However, the company policy was to “No Invoice Paid without an Asset” (yet in more than 500 invoices, not one asset was listed), so the challenge at this company wasn’t the new policy of tracking refrigerators, but instead enforcing the existing policy.
When it comes to developing Regulatory Requirements, ask: (before creating a policy)
- What are the GWP limits mandated by the AIM Act for each equipment type and date? Are we aware that limits are ≤750 for HVAC and ≤150 for self-contained refrigeration as of January 1, 2025?
- How are we preparing to meet the reclaimed refrigerant mandates requiring ≥85% reclaimed content for new systems starting in 2025 and the mandatory use of reclaimed refrigerant for all HFC servicing by 2028?
- Are we fully informed about California’s stricter requirements and timelines, and how do they affect our compliance obligations?
- What is our process for notifying the EPA in cases of non-compliance or when required reporting thresholds are met?
- How does the SNAP rule influence our standards for refrigerant use and equipment compliance?
Buying Impact
When placing purchase orders, what are you doing presently:
- Do we require documented GWP certification before approving any purchase order?
- Can our suppliers guarantee the availability of reclaimed refrigerant for the initial charge?
- Are installers contractually obligated to register assets in our compliance system within 30 days of installation?
Operations Impact
When we buy new equipment, do our bid specs define the compliance journey?
- If we want to track every refrigerant transaction for the life of the equipment (10-15 years), what are we doing today, who is responsible, and what does our track record look like?
- How are we ensuring compliance with state-specific leak repair timelines? Who oversees this process?
- What steps do we take to verify reclaimed refrigerant purity on every service call, and how is this documented?
- How do we calculate and report annualized leak rates? Who owns this responsibility?
→ Learn more about double materiality and its implications for refrigerant risk and compliance.
📌 Buy the wrong equipment today, and operations will inherit a compliance crisis for the next decade.
How are we preventing non-compliant refrigerants at the buying stage, given that GWP compliance can’t be retrofitted after installation?
The Dictate vs. The Investigation
| SPLC Guidance (The “What”) | Internal Compliance (The “How”) | The Investigative Question: What’s Your Present State Across All Three Domains? |
|---|---|---|
| Mandate energy-efficient equipment that uses low-GWP refrigerant. | New system designs must adhere to strict GWP limits (≤750 for HVAC, ≤150 for Self-Contained Equipment). Compliance deadlines began January 1, 2025. | Regulatory: What are the specific GWP limits for each equipment category you purchase? Do state regulations impose stricter limits? Buying: Pull all equipment purchase orders from Q1 2025. What percentage included documented GWP certification before the PO was signed? If the answer is “we don’t verify this at the procurement stage,” then every equipment purchase is introducing unquantified compliance risk. Operations: When equipment is delivered, who verifies that the installed system matches the certified specification? Who enters asset data into your compliance platform within 30 days? |
| Opt for reclaimed refrigerant when servicing. | All new/expanded systems must use reclaimed refrigerant at ≥85% reclaimed, ≤15% virgin. Mandatory use for servicing HFC systems begins January 1, 2028. | Regulatory: What are the reclaimed refrigerant requirements for your equipment types and timelines? Buying: Call your top 3 refrigerant suppliers today. Can they guarantee ≥85% reclaimed content with AHRI 700 purity certification and provide digital documentation? If not, you’re 36 months from a mandatory requirement with no guaranteed supply chain. Operations: Can your technicians verify reclaimed content percentage on delivery? Do they have the tools to test purity? Is this verification recorded in your compliance system, and are you properly handling any confidential business information included in supplier guarantees or compliance submissions to ensure regulatory requirements are met? |
The Procurement Accountability Vacuum
Here’s what most organizations discover when they conduct this cross-domain investigation: procurement, regulations, and operations are completely disconnected.
A policy says “Buy low-GWP equipment.” But when you audit actual purchases:
Regulatory Verification Gap
- What percentage of purchases included verification that the equipment meets not just federal GWP limits, but also state-specific requirements?
- For California locations, are stricter timelines and thresholds documented in the purchase specification?
- When submitting documentation or compliance notifications to EPA, ensure you include the appropriate mail code as part of the official address for proper processing.
GWP Certification Gap
- Pull 12 months of equipment purchase orders. What percentage included a documented GWP certification attached to the PO before it was signed?
- For most organizations, the answer is 0-20%. Why? Because the Mechanical Engineer specifies equipment based on cooling capacity and energy efficiency, GWP is an afterthought. Procurement processes payment with no verification mechanism. The contractor installs whatever they ordered.
- Nobody is contractually obligated to verify and document GWP compliance before the PO is signed. The policy exists, but the verification workflow doesn’t connect buying to regulatory requirements.
Reclaimed Refrigerant Supply Chain Fragility
- The ≥85% reclaimed mandate for new systems started in 2025. The mandatory use for servicing starts in 2028. But here’s the investigation question: Can your current supplier network actually deliver this?
- Call them today. Ask for:
- Current inventory of ≥85% reclaimed HFC refrigerants,
- AHRI 700 purity certification for reclaimed stock,
- Digital chain-of-custody proving reclaimed content percentage
- If fewer than 2 of your 3 suppliers can provide this documentation, you have a supply chain crisis. The regulations are here. Your suppliers aren’t ready. Your operations can’t execute service calls without a compliant refrigerant.
Asset Registration Lag (The Operations Handoff Failure):
- Of equipment purchased in the last 12 months, what percentage was entered into your Digital Compliance Platform within 30 days of activation?
- If the answer is below 70%, you’re accumulating “ghost assets”—systems operating without compliance tracking, leak rate monitoring, or service documentation.
- Why does this happen? Because procurement thinks their job ends at purchase. The installer thinks asset registration is “someone else’s problem.” Operations doesn’t know the asset exists until the first service call—often 12-24 months later.
The Blended Solution: Procurement verification works only when you connect three processes:
- Regulatory Pre-Qualification: Before any equipment RFP, document federal and state GWP requirements, reclaimed refrigerant mandates, and reporting obligations
- Buying Enforcement: Make GWP certification and supplier reclaimed refrigerant capability verification prerequisites for PO approval—not optional attachments
- Operations Handoff Protocol: Contractually require installers to register assets in your compliance system within 30 days, with payment withheld until complete
A third area that must be addressed is ongoing compliance monitoring—ensuring that after procurement and asset registration, continuous tracking and reporting of refrigerant usage and leak rates is maintained to align with EPA Section 608 and other regulatory requirements.
This third area is often overlooked, but it is critical for closing the loop between regulatory, buying, and operational domains.
The inquisitive process forces procurement to recognize they’re not just buying a machine—they’re acquiring a long-term compliance obligation tied to the highly regulated HFC phasedown schedule.
And right now, most organizations are buying blind because they’ve never connected regulatory requirements to purchasing workflows to operational capabilities.
The Accountability Gap: The Tyranny of the Timeline
The SPLC advises: “Set leak prevention goals. Clearly articulate when leaky equipment should be repaired versus replaced.” This is the central weakness of generic guidance: it treats “repair” as a universal constant.
But repair isn’t a policy decision; it’s an operational capability question. Most organizations have no idea what their current performance looks like, or how well they are documenting and verifying repair efforts as required for EPA Section 608 compliance.
Under EPA Section 608 regulations, if an industrial process shutdown is necessary, repair deadlines may be extended (sometimes up to 120 days) to ensure safety and compliance during the shutdown period.
From Dictate to Investigation: The Dichotomy of Leak Repair in Industrial Process Refrigeration
Prescriptive guides can’t handle the complexity of regulatory timelines, especially across jurisdictions. But more critically, they can’t force you to confront your present-day operational reality.
Note: Official EPA Section 608 compliance documentation and correspondence may be directed to EPA offices located on Pennsylvania Avenue NW, so ensure your records and submissions are prepared for federal review.
Here’s what an investigative compliance framework must expose:
| Action/Threshold | EPA Section 608 (Federal) | California ARB (Stricter State) | The Investigative Question: What’s Your Present Rate? |
|---|---|---|---|
| Leak Repair Deadline | 30 days | 14 days | After the system returns to normal (no fixed limit) |
| Commercial Refrigeration Threshold | 20% Annualized Leak Rate | Internal policy: 15% Annual Leak Rate for systems ≥500 lbs | Investigation Required: How many systems currently exceed 15% annual leak rate? Of those, how many have documented investigation reports explaining root cause and remediation plans? If you set a 15% internal threshold but have no tracking system to flag exceedances automatically, the policy is performative theater. |
| Verification Test Follow-up | After system returns to normal (no fixed limit) | Within 14 days of initial repair | After the system returns to normal (no fixed limit) |
The Hidden Question: Who Is Responsible When the System Fails?
Every one of these thresholds assumes a level of operational maturity that most organizations simply don’t possess. The dictate says “repair within 14 days.” The investigation asks:
Data Capture
Do field technicians log leak detection and repair initiation dates in real-time, or do they submit paper tickets days later?
Dispatch Prioritization
When a California leak is detected, does your dispatch system automatically flag it as “14-day priority,” or does it enter the general work queue with 30-day federal repairs?
Parts Availability
If a repair is delayed due to parts, who is contractually obligated to document this in writing, and where is that documentation stored for EPA audit?
Verification Scheduling
After a repair, is the verification test auto-scheduled within the 14-day window, or is it left to manual follow-up that routinely fails?
Repairs and documentation must be performed by a certified technician to ensure compliance with EPA Section 608 requirements and proper refrigerant handling.
The brutal truth
Most organizations fail these investigations because they’ve never conducted them. They have a policy that says “comply with EPA 608 and state regulations,” but they have no diagnostic process to measure present-day performance against those standards.
This is why the investigative approach is non-negotiable. You can’t improve what you don’t measure, and you can’t comply with timelines you don’t track.
The Ultimate Lesson: Trading Dictates for Diagnostics
The failure of prescriptive “guides” is that they provide a destination (“Reduce Emissions”) but neglect to ask: “What mechanism ties that action to performance or payment?”
More critically, they don’t force organizations to measure their present-day success rate at executing the actions they claim to have adopted.
A policy that says “track all refrigerant transactions within 48 hours” is meaningless if your actual success rate is 35%.
A procurement standard that mandates “low-GWP equipment” is performative if nobody verifies GWP before purchase orders are signed.
📌 Policies only work if you can prove they’re being followed.
The internal compliance plan becomes the Inquisitorial Blueprint, not a list of aspirational goals, but a diagnostic framework designed to:
- Measure present-day operational performance against stated policies
- Expose the systemic failures preventing compliance (technology gaps, workflow breakdowns, accountability vacuums)
- Assign clear responsibility when failures occur, with consequences tied to payment and performance
Enforcement mechanisms and compliance requirements are grounded in the EPA’s final rule, which establishes the legally binding standards and procedures organizations must follow under Section 608 and related regulations.
The Refrigeration Institute plays a key role in establishing industry standards and supporting compliance efforts, particularly by advocating for best practices and safety protocols that align with evolving environmental regulations.
Generic guidance provides the Mission Statement.
A detailed, inquisitorial policy provides the Blueprint for Execution and defines where the buck stops—backed by data that proves whether you’re actually executing or just hoping.
The Three Questions That Replace Aspirational Policies
For genuine compliance and emissions reduction, organizations must stop asking “What do regulators want us to do?” and start asking three critical, self-examining questions—each tied to measurable present-day performance:
Recent EPA proposed rule changes, especially under Section 608 and the AIM Act, can significantly impact future compliance requirements, making it essential for organizations to stay informed and proactive.
The Compliance Question: Can we prove itand what’s our present success rate?
Challenge
A service ticket shows that the system received a partial charge.
Traditional Dictate
“All refrigerant additions must be tracked, and systems flagged for repair or replacement.”
Inquisitorial Investigation
For a comprehensive overview on regulatory compliance and sustainability regarding HVAC and refrigeration systems, read The Future of Owning & Operating Refrigeration Equipment.
- Present Performance Audit
Pull 12 months of service data. What percentage of systems that received refrigerant additions were flagged “Under Repair” in your compliance system within 48 hours?
If the answer is below 90%, you have a data capture problem—not a compliance problem. - Leak Rate Recalculation
Of systems that received multiple refrigerant additions within 12 months, what percentage triggered an automatic recalculation of annualized leak rate?
If your system doesn’t automatically flag this, every partial charge resets the compliance clock without anyone noticing—until the EPA audit. - Capital Planning Linkage
For systems exceeding leak rate thresholds, what percentage have documented capital plans showing either “Retrofit” or “Retirement” decisions?
In addition, EPA Section 608 requires the development and documentation of a retrofit or retirement plan for such systems, detailing equipment identification, refrigerant details, procedures, and completion schedules to ensure regulatory compliance.
If this number is below 50%, your organization is identifying problems but taking no action—accumulating regulatory liability with every service call.
The Enforcement Mechanism
“Is the system flagged ‘Under Repair,’ and has the owner/operator initiated a capital plan for ‘Retrofit or Retirement’?”
If a system receives any refrigerant addition within 12 months of a repair, the Digital Compliance Platform flags it, resetting the compliance clock and forcing mandatory re-assessment of CapEx vs. OpEx. But this only works if:
- Field data is captured in real-time (measured success rate: X%)
- Leak rates are auto-calculated (current automation level: Y%)
- Capital planning is triggered automatically (current linkage: Z%)
Without measuring X, Y, and Z, the policy is a wish, not a system.
The Operational Question: Who pays for the data gap, and what’s the present enforcement rate?
Challenge
The service vendor failed to enter repair details within 48 hours.
Traditional Dictate
“All service data must be entered within 48 hours of completion.”
Inquisitorial Investigation
- Facility Manager Accountability
When compliance data is finally entered (often weeks late), who certifies its accuracy?
What percentage of Facility Managers understand that their signature makes them personally accountable for potential $37,500 per day civil penalties under EPA 608?
Compliance documentation should also include a telephone number for the responsible party, as required for official contact and recordkeeping in EPA Section 608 reporting. - Present Compliance Rate
Pull 90 days of service invoices. What percentage had corresponding compliance system entries within 48 hours? What was the average lag time for the remainder?
If your compliance rate is 40%, the policy is being systematically ignored—and you’re paying invoices for undocumented work. - Payment Suspension Enforcement: Of service invoices that lacked timely compliance entries, what percentage had payment suspended until entries were complete?
If the answer is 0%, you have a policy with no teeth. Payment is your only leverage, and you’re not using it.
The Enforcement Mechanism
“Was payment immediately suspended?”
Furthermore, is the Facility Manager (required to certify the accuracy of digital documentation) trained to understand that their signature makes them accountable for potential $37,500 per day civil penalties?
This works only if:
- Invoice processing is linked to compliance system entries (current integration: X%)
- Payment suspension is automated when entries are missing (current automation: Y%)
- Facility Managers receive annual training on liability exposure (current training completion rate: Z%)
The Brutal Reality
Most organizations discover that:
- Payment and compliance systems are completely disconnected
- Finance processes invoices with no validation of compliance entries
- Facility Managers sign off on service reports without understanding they’re accepting legal liability
- Field technicians face no consequences for data entry failures because payment happens regardless
The operational question forces you to confront whether your accountability structure is real or imaginary.
The Procurement Question: How do we stop buying risk, and what’s our present verification rate?
Challenge
New refrigeration equipment is needed for an expansion.
Traditional Dictate
“All new equipment must meet low-GWP standards and use reclaimed refrigerant.”
Inquisitorial Investigation
- Pre-Purchase GWP Verification Rate
Pull 12 months of equipment purchase orders. What percentage included a documented GWP certification attached to the PO before it was signed?
If the answer is below 80%, procurement introduces long-term compliance risk with every purchase, and nobody catches it until after installation. - Reclaimed Refrigerant Supply Chain Reality
Contact your top 3 refrigerant suppliers. Can they provide today:- Current inventory of ≥85% reclaimed HFC refrigerants?
- AHRI 700 purity certification for reclaimed stock?
- Digital chain-of-custody proving reclaimed content percentage?
- Documentation verifying the use of reclaimed HFCs in new equipment and servicing, as required for compliance with EPA Section 608 and HFC phasedown regulations?
If fewer than 2 of your 3 suppliers can provide this documentation, you have a supply chain crisis 36 months before the 2028 mandatory compliance date.
The policy is aspirational; the supply chain is fictional.
- Asset Registration Lag
Of equipment purchased in the last 12 months, what percentage was entered into your Digital Compliance Platform within 30 days of activation?
If the answer is below 70%, you’re accumulating “ghost assets”—systems operating without compliance tracking, leak rate monitoring, or service documentation.
The Enforcement Mechanism
“Did the Mechanical Engineer certify that the new equipment meets our GWP threshold (≤150) before the purchase order was signed? Are we mandating ≥85% reclaimed refrigerant use for the initial charge?”
This ensures procurement stops introducing long-term compliance risk every time it buys a new asset. But it only works if:
- GWP certification is a required PO attachment (current enforcement rate: X%)
- Reclaimed refrigerant suppliers are pre-qualified with documented proof (current pre-qualification rate: Y%)
- Asset registration occurs within 30 days (current success rate: Z%)
The Procurement Reality Check
Most organizations discover:
- Mechanical Engineers specify equipment based on cooling capacity and energy efficiency—GWP is an afterthought, if considered at all
- Procurement has no mechanism to reject POs lacking GWP certification
- Reclaimed refrigerant supply chains are regional, fragmented, and cannot guarantee delivery at scale
- Asset registration happens only when the first service call occurs—often 12-24 months after installation
Every equipment purchase without upfront GWP verification and supply chain validation is a deferred compliance crisis. The procurement question forces you to stop deferring.
Environmental Considerations: The Overlooked Driver in Refrigerant Procurement
Refrigerant procurement used to be simple. Cost. Compatibility. Compliance. Three boxes to check. But the Environmental Protection Agency changed the game.
Hydrofluorocarbons (those potent greenhouse gases warming our planet) now drive every buying decision. Environmental impact isn’t optional anymore. It’s central.
The American Innovation and Manufacturing Act arrived in 2020. Everything shifted. The law demands less HFC production and consumption.
Every manufacturer rethinks their approach. Every operator recalibrates. The EPA’s implementation creates new rules, sector limits, and evolving standards.
Environmental stewardship stopped being a talking point. It became an essential business practice.
Alongside HFCs, the regulation of polyfluoroalkyl substances is also intensifying due to their environmental and health impacts, further shaping procurement and compliance strategies.
Smart procurement teams see the opportunity. The transition to next-generation refrigerant technologies is underway, replacing legacy systems with more efficient and sustainable solutions. The evaluation goes deeper now. Global warming potential matters.
Lifecycle impact counts. American innovation alignment drives decisions. Low-GWP alternatives aren’t just compliant: they’re strategic.
They protect operational continuity. They strengthen brand reputation. They future-proof assets against tighter regulations ahead. This transition isn’t a disruption. It’s an evolution toward smarter business.
Kigali Amendment and International Cooperation: The Global Context Shaping U.S. Refrigerant Policy
Refrigerant management in the United States follows a global blueprint. International agreements drive national regulations.
They set industry standards. The Kigali Amendment to the Montreal Protocol leads this charge; a unified commitment to address hydrofluorocarbons (HFCs) in your air conditioning, refrigeration, and heat pump systems.
The Kigali Amendment entered into force in 2019. It targets HFC production and consumption.
These potent greenhouse gases carry warming potential thousands of times greater than carbon dioxide.
The math is clear: developed countries, including the United States, will reduce HFC use by 85% by 2036.
This isn’t just diplomacy. It’s the foundation of the American Innovation and Manufacturing (AIM) Act and the EPA’s evolving framework.
Every decision you make about industrial process refrigeration, commercial refrigeration, and air conditioning now connects to this global mandate.
The phasedown schedule sets your tempo. It dictates available refrigerants. It prioritizes technologies.
It defines how quickly you transition to low global warming potential (low-GWP) alternatives.
The Montreal Protocol began by protecting the ozone layer from ozone-depleting substances. The Kigali Amendment expanded this mission.
Now it’s a central climate tool. The phasedown of hydrofluorocarbons HFCs means environmental protection and regulatory compliance move as one.
You must comply with federal and state rules. You must also anticipate future restrictions shaped by international cooperation.
Here’s what this means for your refrigeration systems, light commercial air conditioning, and heat pumps: stay ahead.
Adopt next-generation technologies. Maximize reclamation. Minimize releases of potent greenhouse gases.
The trajectory is set — high-GWP refrigerant production and consumption move strictly downward.
Align your procurement, operations, and compliance strategies with this reality. You’ll meet regulatory requirements and position yourself as a leader in climate-friendly alternatives and sustainable facility management.
Understanding these global drivers lets you anticipate regulatory changes. You can manage risk. You can make informed decisions that support operational excellence and environmental stewardship. The Kigali Amendment isn’t just an international treaty. It’s the foundation of American refrigerant management’s future. Your future.
From Aspiration to Audit
The SPLC’s guidance is a great starting place; it establishes the mission and regulatory framework.
But mission statements don’t create compliance. Diagnostic investigations that expose operational failures create compliance.
The shift from dictate to investigation is the difference between:
- Dictate: “Track all refrigerant transactions within 48 hours.”
Investigation
“What is our present success rate for 48-hour data capture, and what systemic failures are preventing us from achieving 90%+ compliance?”
By embedding specific, non-negotiable investigative questions into organizational DNA (backed by digital tracking (I highly suggest Trakref), financial controls, and clear accountability), you move beyond feel-good compliance toward auditable, verifiable climate action.
But it requires courage to conduct the investigation, because the answers are almost always uncomfortable:
- Asset inventories that are 40-60% complete
- Data capture rates below 50%
- Payment systems are completely disconnected from compliance verification
- Procurement processes that introduce risk with every purchase
The organizations that succeed aren’t the ones with the best-written policies. They’re the ones willing to measure their present-day failure rate, expose the systemic causes, and redesign workflows to close the gap.
The question isn’t “Do we have a policy?” The question is “Can we prove it’s working?”
