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11.12 - Current Versus Historical Rules

Module: Standalone Reference Appendices and Instructor Resources
Purpose: Prevent students from memorizing obsolete EPA Section 608 values, superseded regulatory treatment, old organization names, historical penalty amounts, outdated provider procedures, or old refrigerant-safety classifications as though they were current
Current regulatory verification date: August 14, 2026
Provider-policy verification date: August 14, 2026
Safety-standard verification date: August 14, 2026
Primary controlling authorities: Current 40 CFR Parts 19, 82, and 84; current U.S. EPA Section 608 guidance; current ANSI/ASHRAE Standard 34 information and published addenda; current EPA-approved testing-provider instructions where explicitly identified
Core rule: Historical information can still appear in legitimate old study material and even in current regulations when a historical standard or date-conditioned rule remains relevant. Always determine whether a value is obsolete, historical but still referenced, current date-conditioned, current federal, or provider-specific.

How to Use This Reference

When an older EPA 608 source gives a number, standard, rule, or procedure that conflicts with newer course material, do not automatically choose the older or newer statement.

Use this sequence:

1. IDENTIFY THE TOPIC.
2. IDENTIFY THE DATE / ERA OF THE OLD STATEMENT.
3. DETERMINE WHETHER THE OLD VALUE WAS SUPERSEDED.
4. CHECK THE CURRENT eCFR OR CURRENT OFFICIAL SOURCE.
5. CHECK WHETHER A HISTORICAL DATE-CONDITIONED RULE STILL REMAINS IN FORCE.
6. SEPARATE FEDERAL RULES FROM PROVIDER-SPECIFIC PROCEDURES.
7. RECORD THE CURRENT VERIFICATION DATE.

The most important decision is:

OLD
≠
AUTOMATICALLY WRONG

but also:

OLD STUDY GUIDE
≠
CURRENT AUTHORITY

A historical value may be:

  • Fully obsolete.
  • Still relevant only to older equipment.
  • Still correctly named because the historical standard retains its original designation.
  • Superseded by a newer federal rule.
  • Replaced by a separate regulatory program.
  • A provider policy that has changed without any change to federal law.

1. Status Labels Used in This Appendix

StatusMeaningHow to Treat It
CURRENT FEDERAL RULEPresent controlling federal regulationUse for current compliance and current-rule exam questions
CURRENT DATE-CONDITIONED RULECurrent regulation still uses different requirements based on an older manufacture/import dateUse the value that matches the stated condition
HISTORICAL / SUPERSEDEDWas valid in an earlier period but is no longer the current ruleLearn only to recognize and reject it in current-rule questions
HISTORICAL NAME STILL CORRECTOld organization/standard name remains the proper name of a historical standard incorporated by regulationKeep the original designation
CURRENT SEPARATE PROGRAMA newer rule applies through another regulatory part rather than through old Section 608 wordingDo not merge the two programs
PROVIDER-SPECIFICTesting procedure established by an EPA-approved certification providerVerify with that provider at test time
CURRENT STANDARD / CONTINUOUS MAINTENANCETechnical safety classification is maintained by a standards organization and can change through new editions/addendaVerify current edition and addenda

2. Master Current-Versus-Historical Comparison Table

Every row below states the historical wording or value, the current wording or value, why the difference matters, and the controlling source.

TopicHistorical Wording / ValueCurrent Wording / ValueWhy the Difference MattersControlling Source
Section 608 leak-rate thresholdsCommercial refrigeration 35%; IPR 35%; comfort cooling/other 15%For qualifying §82.157 ODS appliances with 50 lb or more: commercial 20%, IPR 30%, comfort cooling/other 10%Using 35%/15% can cause a current-rule question or compliance decision to be wrong40 CFR §82.157; current EPA leak-repair guidance
HFC leak repair under Section 608The 2016 rule extended §82.157 leak-repair requirements to substitute refrigerants/HFCsSince April 10, 2020, §82.157 applies only to qualifying appliances containing class I/class II ODS or ODS-containing blends; substitute-only appliances are excludedAn old 2017-2019 source can incorrectly make a technician apply §82.157 to an HFC-only appliance40 CFR §82.157(a); EPA regulatory updates
Current HFC leak repairOlder material may contain no separate AIM Act leak-repair program40 CFR §84.106, effective Jan. 1, 2026, covers qualifying appliances with 15 lb or more of regulated HFC or qualifying substitute refrigerant, subject to exclusionsCurrent HFC field compliance can require leak repair even though §82.157 no longer covers HFC-only appliances40 CFR §84.106
Refrigerant sales restrictionOlder material may say federal sales restrictions apply only to CFC/HCFC/ODS refrigerantsBeginning Jan. 1, 2018, sales restrictions extend to non-exempt substitutes such as common HFCs, with stated exceptions such as qualifying small MVAC cansOld sales guidance can wrongly imply anyone may buy stationary HFC refrigerant40 CFR §82.154(c); current EPA Refrigerant Sales Restriction
Recovery equipment, 1993-2003May be described simply as “ARI recovery equipment”Equipment manufactured/imported Nov. 15, 1993 through Sept. 21, 2003 uses Appendix B1 based on ARI Standard 740-1993Historical standard name and manufacture/import period must be matched correctly40 CFR §82.158(d)(1)
Recovery equipment, 2003-2016Older material may reference ARI 740-1995 without explaining the date rangeEquipment manufactured/imported Sept. 22, 2003 through Dec. 31, 2016 uses Appendix B2 based on ARI Standard 740-1995Prevents use of the wrong recovery-machine standard40 CFR §82.158(d)(2)
Recovery equipment, 2017 and laterOlder sources cannot include modern flammable-refrigerant certification pathsEquipment manufactured/imported Jan. 1, 2017 and later uses Appendix B3 for nonflammable refrigerants and Appendix B4 for flammable refrigerants, based on AHRI Standard 740-2016 as incorporatedModern refrigerant safety class can affect recovery-equipment suitability40 CFR §82.158(d)(3); Appendices B3/B4
ARI versus AHRIHistorical standards are named ARI 740-1993 and ARI 740-1995Current organization name is AHRI; current incorporated 2016 standard is AHRI 740-2016Historical standards must not be retroactively renamed “AHRI 740-1993/1995”40 CFR §82.158; AHRI current organization/standards information
Civil penalty figureOlder sources may state $25,000, $27,500, $32,500, or $37,500 per dayPenalty maximums are inflation-adjusted and enforcement-path-specific. Current 40 CFR §19.4 lists $124,426 for CAA §113(b) judicial civil penalties and separate current administrative limitsThere is no safe timeless statement that “the Section 608 fine is $37,500/day”40 CFR §19.4
Leak-repair recordkeeping locationOlder regulatory material may direct users to former §82.166 or earlier record structuresCurrent §82.157 contains the current ODS leak-repair recordkeeping/reporting provisions; many records are kept at least 3 yearsOld section numbers can send students to historical text rather than current requirements40 CFR §82.157(l)-(m)
Disposal technician recordsSome summaries say “5 to 50 lb”Current §82.156(a)(3) exact range is more than 5 lb and less than 50 lb, retained 3 yearsExactly 5 lb and exactly 50 lb are outside this specific range40 CFR §82.156(a)(3)
Evacuation table date columnsOlder material may call one column “old” and imply it is obsoleteCurrent Table 1 still contains pre-Nov. 15, 1993 and on/after-Nov. 15, 1993 recovery-equipment columnsThe pre-1993 column is a current date-conditioned rule, not an obsolete table40 CFR §82.156(a), Table 1
What the 1993 evacuation date meansStudents may assume it is the appliance manufacture dateIt is the recovery/recycling equipment manufacture or import date used by the applicable ruleSelecting the column from appliance age produces the wrong endpoint40 CFR §§82.156, 82.158
Testing formatOlder sources emphasize in-person or mail-in/paper testingEPA-approved programs may offer remote/online testing; current EPA list identifies SkillCat as online testing onlyDelivery method is provider-specific and can change without changing EPA technical contentEPA approved certification-program list; provider instructions
SkillCat Universal procedureOlder screenshots/blogs can show different timing, pricing, attempts, or scoring languageCurrent public information describes 100 questions, 2 hours, closed book, proctored; provider pages should be rechecked at test timeProvider rules change more often than federal regulationsCurrent SkillCat instructions; EPA provider approval list
SkillCat passing wordingOlder/current pages can use different phrasingCurrent public SkillCat material is not perfectly consistent between “70%” wording and “18 of 25 in each section” wordingThe candidate should follow the current in-app exam agreement rather than memorize a screenshotCurrent SkillCat instructions
Safety classificationOlder charts can show R-32, R-143a, and R-1234yf as A2, and R-717 as B2ASHRAE’s 2L subclass changed these to A2L and B2L classifications; current published baseline is ANSI/ASHRAE Standard 34-2024 plus current addendaOld safety groups can lead to incorrect flammability/tool/procedure assumptionsANSI/ASHRAE Standard 34-2024 and current addenda
ASHRAE safety-reference editionOlder training may use Standard 34-2010, 2013, 2016, 2019, or 2022The current published edition is Standard 34-2024, maintained through addenda; the list includes addenda through June 30, 2026Refrigerant designations and safety data are continuously maintainedASHRAE Standard 34 resources/addenda

3. Leak-Rate Thresholds

3.1 Historical Values

Older EPA 608 material can legitimately contain the former trigger rates:

INDUSTRIAL PROCESS REFRIGERATION
→ 35%
COMMERCIAL REFRIGERATION
→ 35%
COMFORT COOLING
→ 15%
OTHER COVERED APPLIANCES
→ 15%

These values were once valid.

They are not the current §82.157 trigger rates.

Historical status

35% / 35% / 15% / 15%
→ HISTORICAL / SUPERSEDED

Why it matters: An older exam-preparation source can have a perfectly authentic historical answer key and still be wrong for a current-rule question.

Current controlling source: 40 CFR §82.157.


3.2 Current Section 608 ODS Values

Current §82.157 applies to appliances with:

50 lb OR MORE

of:

  • Class I refrigerant.
  • Class II refrigerant.
  • A blend containing class I or class II refrigerant.

Current trigger rates:

Appliance CategoryCurrent Trigger Rate
Industrial process refrigeration30%
Commercial refrigeration20%
Comfort cooling10%
Other covered appliances10%

Current memory pattern

30
20
10

for:

IPR
COMMERCIAL
COMFORT / OTHER

Why it matters: Current trigger rates and current ODS applicability must be learned together. A student who remembers only 20% without remembering the ODS/50-lb context can still answer incorrectly.

Current controlling source: 40 CFR §82.157(a), (c).


4. HFC Leak-Repair Treatment Changed More Than Once

This is one of the most important historical/current distinctions in the entire course.

4.1 2016 Rule Era

EPA’s 2016 refrigerant-management rule extended many Section 608 requirements to substitute refrigerants and extended the appliance leak-repair provisions to qualifying substitute-refrigerant appliances.

A source from the late 2010s can therefore state that:

§82.157 LEAK REPAIR
→ HFC / SUBSTITUTE APPLIANCES

and have been accurate for that regulatory period.

Status

HISTORICAL FOR CURRENT 2026 USE

4.2 April 10, 2020 Change

Current §82.157 states that, as of:

APRIL 10, 2020

the section applies only to appliances with:

50 lb OR MORE

of class I/class II refrigerant or a blend containing class I/class II refrigerant.

It explicitly excludes appliances containing solely substitute refrigerants.

Therefore:

HFC-ONLY APPLIANCE
→ NOT CURRENT §82.157 LEAK-REPAIR APPLICABILITY

Why it matters: A 2017-2019 source and a current source can disagree because the rule actually changed.

Current controlling source: 40 CFR §82.157(a).


4.3 Other Section 608 HFC Requirements Did Not Disappear

The 2020 leak-repair change did not mean:

HFC
→ NO SECTION 608 REQUIREMENTS

Current Section 608 still includes important requirements affecting non-exempt substitutes, including relevant:

  • Technician certification.
  • Sales restriction.
  • Recovery/service practices.
  • Recovery-equipment requirements.
  • Venting prohibition.
  • Safe disposal.
  • Reclamation/used-refrigerant transfer rules.

Exam trap

Incorrect:

EPA REMOVED HFCs FROM §82.157
→ HFCs ARE UNREGULATED UNDER SECTION 608

Correct:

§82.157 LEAK-REPAIR APPLICABILITY CHANGED
→ OTHER SECTION 608 REQUIREMENTS REMAIN

Current controlling sources: 40 CFR Part 82, Subpart F; current EPA Section 608 guidance.


5. Current AIM Act HFC Leak Repair

Beginning:

JANUARY 1, 2026

a separate current program under:

40 CFR §84.106

applies to qualifying refrigerant-containing appliances.

5.1 Current Applicability

The current rule generally applies at:

15 lb OR MORE

full charge where the refrigerant contains:

  • A regulated substance under Part 84, or
  • A substitute for a regulated substance with GWP greater than 53 using the Part 84 table specified by the rule.

Important exclusions include:

  • Appliances containing solely an ozone-depleting substance.
  • Appliances in the residential and light commercial air-conditioning and heat-pump subsector.

5.2 Current AIM Trigger Rates

Appliance CategoryCurrent §84.106 Trigger
Industrial process refrigeration30%
Commercial refrigeration20%
Comfort cooling10%
Refrigerated transport10%
Other covered appliances10%

Critical Comparison

SECTION 608 §82.157
→ qualifying ODS
→ ≥50 lb
AIM §84.106
→ qualifying HFC / substitute
→ ≥15 lb
→ stated exclusions

Why it matters: The percentages look similar, but the refrigerant scope and full-charge thresholds are different.

Current controlling source: 40 CFR §84.106.


6. Refrigerant Sales Restrictions

6.1 Historical Simplification

Older sources may state:

REFRIGERANT SALES RESTRICTION
→ CFCs / HCFCs / ODS ONLY

That no longer describes the complete current federal stationary-refrigerant sales restriction.

Historical status

INCOMPLETE / OUTDATED FOR CURRENT USE

6.2 Current Rule

Beginning:

JANUARY 1, 2018

the sales restriction extended to non-exempt substitute refrigerants, including common HFC refrigerants.

Current EPA guidance states that Section 608 certified technicians or qualifying employers may purchase refrigerant for stationary refrigeration/A/C use, subject to the regulatory exceptions.

Small MVAC Can Exception

Qualifying small cans of substitute refrigerant for MVAC service can be sold to uncertified persons when the federal conditions are met, including:

2 lb OR LESS

and the required container/fitting features.

Do not generalize that exception to stationary HVAC refrigerant cylinders.

Why it matters: A homeowner or uncertified worker cannot assume that HFC refrigerant for stationary equipment is unrestricted merely because HFCs do not deplete ozone.

Current controlling source: 40 CFR §82.154(c); EPA Refrigerant Sales Restriction.


7. Recovery-Equipment Standards

Recovery-equipment rules are a strong example of a historical date becoming part of the current rule.

7.1 Current Regulatory Timeline

For recovery/recycling equipment used with appliances other than small appliances, MVACs, and MVAC-like appliances:

Recovery-Equipment Manufacture / Import DateCurrent Regulatory TreatmentStatus
Before Nov. 15, 1993Legacy performance qualification under §82.158(c)Current date-conditioned rule
Nov. 15, 1993 through Sept. 21, 2003Appendix B1, based on ARI 740-1993Historical standard still correctly referenced by current regulation
Sept. 22, 2003 through Dec. 31, 2016Appendix B2, based on ARI 740-1995Historical standard still correctly referenced by current regulation
Jan. 1, 2017 and later, nonflammable refrigerantsAppendix B3, based on AHRI 740-2016Current newer-equipment pathway
Jan. 1, 2017 and later, flammable refrigerantsAppendix B4, using the current incorporated flammable-refrigerant pathwayCurrent newer-equipment pathway

Why the Date Matters

The relevant date is the date the recovery/recycling equipment was:

MANUFACTURED OR IMPORTED

It is not:

  • Appliance manufacture date.
  • Technician certification date.
  • Service date.
  • Date the technician bought the machine.

Current controlling source: 40 CFR §82.158.


7.2 Older Recovery Equipment Is Not Automatically Illegal

Incorrect:

PRE-2017 RECOVERY MACHINE
→ AUTOMATICALLY ILLEGAL

Correct:

CHECK THE MACHINE'S
DATE-BASED REGULATORY PATHWAY
+
CERTIFICATION / PERFORMANCE
+
REFRIGERANT COMPATIBILITY
+
CONDITION
+
INTENDED APPLIANCE CATEGORY

A historical standard can remain legally relevant because the current regulation uses it to classify equipment from an earlier manufacture/import period.


7.3 Former Equipment-Acquisition Filing

Older Section 608 material can discuss an owner/service-entity certification to EPA stating that recovery/recycling equipment had been acquired.

Current EPA recovery-equipment guidance states that persons servicing stationary A/C and refrigeration equipment are no longer required to make that former equipment-acquisition certification to EPA.

This does not remove the requirement to use compliant recovery/recycling equipment.

Comparison

FORMER EQUIPMENT-ACQUISITION CERTIFICATION FILING
→ NO LONGER REQUIRED

but:

RECOVERY EQUIPMENT
→ STILL MUST MEET APPLICABLE REQUIREMENTS

Current controlling source: EPA Refrigerant Recovery and Recycling Equipment Certification; 40 CFR §82.158.


8. ARI Versus AHRI Terminology

8.1 Historical Organization Name

Historical recovery-equipment standards correctly include:

ARI STANDARD 740-1993

and:

ARI STANDARD 740-1995

Do not rewrite them as:

AHRI 740-1993
AHRI 740-1995

8.2 Current Organization Name

The current organization is:

AHRI
→ Air-Conditioning, Heating, and Refrigeration Institute

Current §82.158/Appendix B3 uses:

AHRI STANDARD 740-2016

Correct Naming Rule

HISTORICAL STANDARD
→ KEEP HISTORICAL NAME
CURRENT ORGANIZATION
→ AHRI

Why It Matters

Seeing the word:

ARI

inside the current eCFR does not prove the regulation is outdated.

The current regulation may be accurately referring to a historical incorporated standard.

Controlling sources: 40 CFR §82.158; Appendix B3; current AHRI organization/standards information.


9. Civil Penalty Values

Penalty numbers are among the least safe EPA 608 facts to memorize from an old book.

9.1 Historical Figures

Older Clean Air Act/EPA training material may list maximum civil penalties such as:

$25,000 per day
$27,500 per day
$32,500 per day
$37,500 per day

These values correspond to earlier statutory/inflation-adjusted periods.

The current eCFR still displays those historical amounts in its historical penalty table.

Status

HISTORICAL
→ DO NOT TEACH AS A TIMELESS CURRENT MAXIMUM

9.2 Current Penalty Structure

Current 40 CFR §19.4 uses inflation-adjusted penalty amounts and distinguishes the statutory enforcement pathway.

Current Table 1 lists the following Clean Air Act amounts:

42 U.S.C. §7413(b)
→ $124,426

for the current judicial civil-penalty maximum applicable under the table’s stated timing conditions.

The same table separately lists:

42 U.S.C. §7413(d)(1)
→ $59,114 / $472,901

for the current administrative penalty per-day / total structure under that statutory provision.

It also lists a separate current field-citation amount under §7413(d)(3).

Critical Wording

Do not teach:

"THE SECTION 608 FINE IS $124,426 PER DAY"

as a universal statement.

Teach:

Clean Air Act civil monetary penalties are inflation-adjusted and depend on the applicable statutory/enforcement pathway. Always verify the current 40 CFR §19.4 table.

Why It Matters

A technically old exam source can have a penalty amount that was correct when published but is no longer the current maximum.

Current controlling source: 40 CFR Part 19, especially §19.4.


10. Recordkeeping Changes

Recordkeeping rules have changed in scope and organization over time.

10.1 Leak-Repair Records

Older material can direct the student to:

§82.166

for leak-repair records or contain older pre-2019 regulatory organization.

Current ODS leak-repair recordkeeping is in:

§82.157(l)

with reporting provisions in the current section.

Many current records are kept for at least:

3 YEARS

unless a different duration is specified.

Full-charge records are maintained until:

3 YEARS AFTER APPLIANCE RETIREMENT

Why It Matters

An old section citation can be as misleading as an old numerical value.

Current controlling source: 40 CFR §82.157(l)-(m).


10.2 Disposal Records

Some summaries use shorthand:

5-50 lb

Current §82.156(a)(3) is more precise:

MORE THAN 5 lb
AND
LESS THAN 50 lb

for the technician disposal-recovery records covered by that paragraph.

Retention:

3 YEARS

Boundary Check

EXACTLY 5 lb
→ NOT IN THIS SPECIFIC RANGE
EXACTLY 50 lb
→ NOT IN THIS SPECIFIC RANGE

Why it matters: A shorthand summary can silently change the endpoints.

Current controlling source: 40 CFR §82.156(a)(3).


10.3 Refrigerant Retailer Records

Current retailer records for applicable refrigerant sales include:

PURCHASER NAME
DATE OF SALE
QUANTITY PURCHASED

with the applicable records retained:

3 YEARS

An old source that describes sales restrictions only for ODS may also contain outdated retailer-record scope.

Current controlling source: 40 CFR §82.154(c); current EPA retailer guidance.


11. Evacuation Tables: Historical Dates That Are Still Current

The current Table 1 of §82.156 includes two recovery-equipment date columns:

MANUFACTURED / IMPORTED
BEFORE NOV. 15, 1993

and:

MANUFACTURED / IMPORTED
ON OR AFTER NOV. 15, 1993

These are not “old table versus new table.”

They are two columns in the current table.

11.1 Current Table 1 Summary

ApplianceFull ChargePre-Nov. 15, 1993 EquipmentOn/After-Nov. 15, 1993 Equipment
Very high pressureAny0 in. Hg vacuum0 in. Hg vacuum
High pressure<200 lb0 in. Hg vacuum0 in. Hg vacuum
High pressure≥200 lb4 in. Hg vacuum10 in. Hg vacuum
Medium pressure<200 lb4 in. Hg vacuum10 in. Hg vacuum
Medium pressure≥200 lb4 in. Hg vacuum15 in. Hg vacuum
Low pressureAny25 mm Hg absolute25 mm Hg absolute

Important Status

PRE-1993 COLUMN
→ CURRENT DATE-CONDITIONED RULE

not:

PRE-1993 COLUMN
→ OBSOLETE

Why it matters: A “historical versus current” appendix must not accidentally delete a historical date condition that remains part of current law.

Current controlling source: 40 CFR §82.156(a), Table 1.


12. Type I Recovery Date Condition

The same principle applies to small-appliance recovery.

Current §82.156(b) retains:

RECOVERY EQUIPMENT
MANUFACTURED BEFORE NOV. 15, 1993
→ 80%

and for equipment manufactured on/after that date:

FUNCTIONING COMPRESSOR
→ 90%
NONFUNCTIONING COMPRESSOR
→ 80%

with the current alternative:

4 in. Hg vacuum

Historical-versus-current lesson

The date is old.

The rule is current.

Current controlling source: 40 CFR §82.156(b).


13. Testing-Provider Procedures

Federal EPA test requirements and provider-specific testing procedures must be kept separate.

13.1 Federal Baseline

Current federal rules require:

  • EPA-approved certifying program.
  • At least 25 Core questions and at least 25 questions from each relevant technical group.
  • Universal coverage of Core + Type I + Type II + Type III.
  • Proctored Core when it is to count toward Universal certification.

EPA maintains the current list of approved certifying programs.

Current EPA-approved-provider example

EPA’s current certification-program list identifies SkillCat as:

SKILLCAT EPA CERTIFICATION
→ EPA-APPROVED
→ ONLINE TESTING ONLY

Current controlling source: 40 CFR §82.161 and Appendix D; EPA Certification Programs for Section 608 Technicians.


13.2 Why Older Testing Instructions Can Be Obsolete

Older sources may emphasize:

  • Paper exams.
  • In-person exams only.
  • Mail-in Type I testing.
  • Old provider fees.
  • Old time limits.
  • Old retake policies.
  • Old proctoring methods.

Current EPA recognizes approved programs that offer:

REMOTE / ONLINE TESTING

Therefore:

TEST DELIVERY METHOD
→ CAN CHANGE
WITHOUT CHANGING EPA 608 TECHNICAL KNOWLEDGE

14. Current SkillCat Procedure Snapshot

The following is a provider-specific snapshot, not a federal regulation.

14.1 Current Published Structure

ExaminationCurrent Published StructureTime LimitBook / Proctoring Status
Type I25 Core + 25 Type I = 50 questions1 hourOpen book; non-proctored
Type II25 Core + 25 Type II = 50 questions1 hourClosed book; proctored
Type III25 Core + 25 Type III = 50 questions1 hourClosed book; proctored
Universal25 Core + 25 Type I + 25 Type II + 25 Type III = 100 questions2 hoursClosed book; proctored

Current SkillCat 2026 material also describes:

4 ATTEMPTS

and a:

4-HOUR WAIT

after a failed attempt before retesting under the provider’s current procedure.

These are:

PROVIDER-SPECIFIC

not universal federal Section 608 rules.


14.2 Passing-Score Wording Requires Reverification

Current SkillCat public material uses wording that is not perfectly consistent.

Current pages include language such as:

70%

and other current guidance states:

18 CORRECT OUT OF 25
IN EACH REQUIRED SECTION

Since:

the verbal percentage and integer question count should not be casually treated as mathematically identical.

Course Rule

At the time of the official exam, follow the scoring requirement and exam agreement displayed in the current SkillCat application.

Do not rely on:

  • An old screenshot.
  • An old course note.
  • A blog post that conflicts with the actual exam agreement.
  • A historical provider policy.

Why It Matters

Provider procedures can change rapidly and are not the controlling source for federal technical regulations.

Controlling source for provider procedure: Current SkillCat application/help materials.


15. Project Readiness Target Is Not a Historical Federal Rule

The course uses a preparation target of:

22 / 25

in each section on two separate closed-book cumulative attempts, with no unresolved high-priority errors.

That is:

This is:

PROJECT READINESS STANDARD

not:

EPA PASSING RULE

and not:

PROVIDER PASSING RULE

Do not confuse an intentionally conservative course target with a legal examination requirement.


16. Refrigerant Safety-Classification Updates

Refrigerant safety classifications are maintained by ASHRAE Standard 34.

Older charts can be outdated even when the refrigerant designation has not changed.

16.1 Historical Class 2 to 2L Change

ASHRAE Addendum h to Standard 34-2010 changed the flammability classification for:

  • R-32.
  • R-143a.
  • R-717.
  • R-1234yf.

from Class 2 to the newer:

2L

subclass based on the applicable burning-velocity criterion.

Important Examples

RefrigerantOlder Classification Seen in Legacy SourcesUpdated 2L Classification
R-32A2A2L
R-143aA2A2L
R-1234yfA2A2L
R-717 ammoniaB2B2L

Why It Matters

An old chart that says:

R-32 = A2

can cause incorrect assumptions about:

  • Tool compatibility.
  • Ignition control.
  • Safety training.
  • Current equipment standards.

16.2 Current Standard Baseline

ASHRAE’s current published edition is:

ANSI/ASHRAE STANDARD 34-2024

It supersedes Standard 34-2022.

ASHRAE maintains Standard 34 on continuous maintenance.

The current addenda page lists Standard 34-2024 addenda through:

JUNE 30, 2026

including addenda published on that date.

Current Rule for Field Reference

CURRENT STANDARD 34
+
CURRENT PUBLISHED ADDENDA
→ CONTROLS SAFETY-CLASSIFICATION REFERENCE

not:

OLD REFRIGERANT CHART
→ CONTROLS FOREVER

Controlling source: ANSI/ASHRAE Standard 34-2024 and current ASHRAE addenda.


17. Timeline of High-Priority Changes

Date / PeriodChangeCurrent Study Meaning
Before Nov. 15, 1993Legacy recovery-equipment performance categoryStill relevant as a current date-conditioned equipment/evacuation rule
Nov. 15, 1993Major recovery-equipment/service-practice dividing dateDo not confuse with appliance manufacture date
Sept. 22, 2003Later recovery-equipment certification period beginsARI 740-1995 / Appendix B2 period
2011 eraASHRAE 2L subclass applied to R-32, R-143a, R-717, R-1234yf through Standard 34 addendumReject old A2/B2 charts for these refrigerants
2016 ruleEPA updated Section 608; lower leak rates and broader substitute-refrigerant provisionsImportant historical starting point for later 2018/2020 changes
Jan. 1, 2017Newer recovery equipment enters B3/B4 AHRI 740-2016 pathwaysDistinguish nonflammable/flammable recovery equipment
Jan. 1, 2018Sales restrictions and technician-certification requirements extended to many substitutes/HFCsOld “HFC sales unrestricted” teaching is obsolete
Jan. 1, 2019Current reorganized §82.157 framework becomes applicableCurrent ODS leak repair/records centered in §82.157
Apr. 10, 2020§82.157 leak-repair applicability to substitute-only appliances rescindedCurrent §82.157 is ODS-focused
2024ANSI/ASHRAE Standard 34-2024 publishedCurrent safety-reference baseline
Jan. 8, 2025Current EPA penalty inflation table became operative for relevant post-2015 violations assessed on/after that dateDo not memorize old $37,500 maximum
Jan. 1, 2026AIM Act §84.106 leak-repair requirements become applicableSeparate current HFC/substitute leak-repair pathway
June 30, 2026Current Standard 34-2024 addenda page includes addenda published through this dateVerify current safety data rather than old tables

18. Historical Value Trap Table

If an Older Source Says…Current Response
Commercial refrigeration leak rate = 35%Historical. Current §82.157 ODS commercial trigger = 20%
IPR leak rate = 35%Historical. Current §82.157 ODS IPR trigger = 30%
Comfort cooling leak rate = 15%Historical. Current §82.157 ODS comfort trigger = 10%
Section 608 leak repair applies to HFC-only appliancesWas true under the post-2016/pre-2020 treatment; current §82.157 excludes substitute-only appliances
HFC leak repair is gone completelyWrong for 2026. Check separate current AIM §84.106
Refrigerant sales restrictions apply only to CFC/HCFC refrigerantsOutdated. Non-exempt substitutes/HFCs have been included since Jan. 1, 2018, subject to exceptions
Penalty = $37,500/dayHistorical amount. Check current §19.4 and applicable enforcement pathway
“AHRI 740-1993”Wrong designation. The historical standard is ARI 740-1993
“AHRI 740-1995”Wrong designation. The historical standard is ARI 740-1995
“ARI 740-2016”Wrong current-era designation. Current incorporated name is AHRI 740-2016
Pre-1993 Table 1 values are obsoleteWrong. They remain current date-conditioned values for qualifying older recovery equipment
Table 1 date means appliance manufacture dateWrong. It is the recovery/recycling-equipment date condition
Low-pressure endpoint = “25 in. Hg vacuum”Wrong. Current Table 1 uses 25 mm Hg absolute
Disposal records apply from “5 through 50 lb”Wrong endpoints. Current specific range is >5 and <50 lb
R-32 = A2Historical safety classification; current reference uses A2L
R-1234yf = A2Historical safety classification; current reference uses A2L
R-717 = B2Historical safety classification; current reference uses B2L
EPA 608 tests must always be in personOutdated. EPA-approved remote/online programs exist
Universal exam provider procedure never changesWrong. Provider timing/proctoring/attempt/scoring rules must be checked at test time

19. Values That Look Historical but Must Not Be Deleted

Some old dates are embedded in the current rule.

Do not mark the following as obsolete merely because they refer to the 1990s or 2000s:

19.1 November 15, 1993

Still used in current:

  • Table 1 evacuation columns.
  • Small-appliance recovery pathways.
  • Recovery-equipment certification structure.

19.2 ARI 740-1993

Still correctly referenced in current §82.158 for the applicable recovery-equipment period.

19.3 ARI 740-1995

Still correctly referenced in current §82.158 for the applicable later equipment period.

General Lesson

HISTORICAL DATE
+
CURRENT REGULATION REFERENCES IT
→ CURRENT DATE-CONDITIONED RULE

This is different from:

HISTORICAL VALUE
+
CURRENT REGULATION REPLACED IT
→ OBSOLETE

20. Values That Should Be Treated as Obsolete for Current-Rule Questions

Unless a question explicitly asks for historical information, reject:

35%
→ current commercial/IPR leak rate
15%
→ current comfort-cooling leak rate
$37,500/day
→ timeless current EPA Section 608 penalty
HFC-only appliance
→ current §82.157 leak-repair applicability
R-32 = A2
R-1234yf = A2
R-717 = B2

Do not “average” old and new values.

Do not select an old value merely because it appears in several older books.


21. Proposed Rules Are Not Current Rules

A proposed rule can appear newer than the current eCFR.

That does not make it controlling.

For this course:

FINAL CURRENT eCFR
→ CONTROLS CURRENT FEDERAL RULE

unless the user is specifically studying a proposed future change.

Rule

PROPOSAL
≠
FINAL RULE

If a current EPA proposal would alter a requirement:

  1. Label it proposed.
  2. Keep the current final rule as the current answer.
  3. Recheck after publication of any final rule.
  4. Update the course only when the controlling requirement changes.

22. Current Source Hierarchy

For a current regulatory question, use this hierarchy.

22.1 Federal Requirement

CURRENT eCFR
→ PRIMARY CONTROLLING TEXT

then:

CURRENT EPA IMPLEMENTATION / GUIDANCE
→ EXPLANATION / APPLICATION

22.2 Safety Classification

CURRENT ANSI/ASHRAE STANDARD 34
+
CURRENT PUBLISHED ADDENDA

22.3 Examination Delivery

CURRENT EPA APPROVED-PROVIDER STATUS
+
CURRENT PROVIDER EXAM AGREEMENT / INSTRUCTIONS

22.4 Old Study Material

TOPIC FREQUENCY / HISTORICAL CONTEXT / PRACTICE STYLE

not:

CONTROLLING CURRENT REGULATION

23. Current-Rule Verification Worksheet

Use this worksheet whenever an old and new source disagree.

## Current-versus-Historical Verification Record

- **Topic:**
- **Historical source date:**
- **Historical wording/value:**
- **Was it valid when published?** Yes / No / Unclear
- **Current eCFR section:**
- **Current wording/value:**
- **Current EPA guidance checked:**
- **Separate AIM Act rule relevant?** Yes / No
- **Provider-specific rather than federal?** Yes / No
- **Safety-standard/addendum check needed?** Yes / No
- **Historical value still current under a date condition?** Yes / No
- **Why the difference matters:**
- **Controlling source:**
- **Verification date:**
- **Course files that must be updated:**

24. Exam Strategy for Historical/Current Questions

When a question includes:

CURRENT
TODAY
UNDER CURRENT EPA RULES

use current verified values.

When a question explicitly says:

HISTORICALLY
BEFORE [DATE]
EQUIPMENT MANUFACTURED BEFORE [DATE]

use the corresponding historical/date-conditioned rule.

Key clue

"MANUFACTURED BEFORE NOVEMBER 15, 1993"

is not asking for an obsolete answer.

It is selecting a current date-conditioned requirement.


25. Common Mistakes and Confusing Points

Mistake 1 - Treating Every Old Number as Wrong

Some current rules still depend on historical equipment dates.


Mistake 2 - Treating Every Published Book as Current Authority

Publication date alone does not guarantee current regulatory accuracy.


Mistake 3 - Memorizing 35% / 15%

Those are historical leak-rate values.


Mistake 4 - Applying 30% / 20% / 10% Without Checking Refrigerant Scope

Section 608 §82.157 and AIM §84.106 can use similar percentages but have different applicability thresholds and refrigerant scope.


Mistake 5 - Saying “HFC Leak Repair Was Repealed”

The accurate current statement is:

§82.157 HFC/SUBSTITUTE-ONLY LEAK REPAIR
→ RESCINDED EFFECTIVE APR. 10, 2020

but:

AIM §84.106
→ SEPARATE CURRENT HFC/SUBSTITUTE LEAK REPAIR
→ EFFECTIVE JAN. 1, 2026

Mistake 6 - Calling ARI an Error Everywhere

ARI is correct when naming historical ARI standards.


Mistake 7 - Renaming ARI 740-1995 as AHRI 740-1995

Do not rename a historical standard retroactively.


Mistake 8 - Teaching One Current Penalty Number as Universal

Current penalties depend on statutory/enforcement path and inflation adjustment.


Mistake 9 - Treating Provider Procedures as Federal Law

A provider can change:

  • Time limits.
  • Attempts.
  • Waiting period.
  • Device requirements.
  • Proctoring workflow.
  • Pricing.
  • Review process.

without changing §82.156 or §82.157.


Mistake 10 - Assuming Online Testing Is Invalid

EPA’s current approved-provider list includes online/remote testing programs.


Mistake 11 - Using an Old Refrigerant Safety Chart

Current Standard 34 and current addenda control the safety-classification reference.


Mistake 12 - Calling A2L “A2”

That can be a historical classification and is not the current reference for refrigerants such as R-32 and R-1234yf.


Mistake 13 - Calling the Pre-1993 Evacuation Column Obsolete

It remains in the current Table 1.


Mistake 14 - Using “5 to 50 lb” as Exact Regulatory Language

The current disposal-record range is:

>5 lb
AND
<50 lb

26. Quick “Use or Reject” Table

StatementCurrent Study Decision
Commercial leak rate = 35%Reject as current; label historical
Commercial §82.157 ODS leak rate = 20%Use current
IPR §82.157 ODS leak rate = 30%Use current
Comfort/other §82.157 ODS leak rate = 10%Use current
§82.157 covers HFC-only refrigerantReject as current
§84.106 can cover qualifying HFC appliance ≥15 lbUse current
HFC sales are unrestrictedReject
ARI 740-1995Use when historical equipment period requires it
AHRI 740-2016Use for current incorporated newer-equipment pathway
$37,500/day is the current universal maximumReject
Current CAA §113(b) §19.4 figure = $124,426Use only with enforcement-context caveat
Pre-1993 Table 1 columnUse when condition matches
25 mm Hg absolute for low-pressure Table 1Use current
R-32 A2Reject as current safety classification
R-32 A2LUse current reference
R-717 B2LUse current reference
EPA requires every exam in personReject
SkillCat current provider instructions can changeUse as provider-policy principle

27. Current Verification Checklist Before Teaching

Before each course offering:

  • Open current 40 CFR Part 82, Subpart F.
  • Recheck §82.154 sales restrictions.
  • Recheck §82.156 evacuation/service-practice requirements.
  • Recheck §82.157 ODS leak-repair applicability and rates.
  • Recheck §82.158 recovery-equipment standards.
  • Recheck §82.161 technician certification.
  • Recheck current 40 CFR §19.4 penalty table.
  • Recheck current 40 CFR Part 84, Subpart C.
  • Recheck §84.106 AIM leak-repair scope.
  • Recheck current EPA Section 608 provider list.
  • Recheck the selected provider’s examination agreement/instructions.
  • Recheck current ANSI/ASHRAE Standard 34 edition.
  • Recheck Standard 34 addenda.
  • Search course files for obsolete 35%.
  • Search course files for obsolete 15% leak-rate use.
  • Search course files for $37,500.
  • Search course files for inappropriate AHRI 740-1995.
  • Search course files for old A2 classifications that should now be A2L.
  • Confirm pre-1993 values are not incorrectly deleted where current regulation still uses them.
  • Update verification dates.
  • Update affected practice questions and answer keys.
  • Update CHANGELOG.md.

The complete maintenance procedure is in:

11.15 - Regulatory Verification and Update Procedure.md


28. EPA 608 Exam Focus

For current Universal preparation, remember:

35 / 35 / 15 / 15
→ HISTORICAL LEAK RATES
30 / 20 / 10
→ CURRENT §82.157 ODS LEAK-RATE PATTERN
§82.157
→ ≥50 lb
→ ODS
AIM §84.106
→ ≥15 lb
→ qualifying HFC / substitute
→ Jan. 1, 2026
→ check exclusions
JAN. 1, 2018
→ SALES / CERTIFICATION EXPANSION TO MANY SUBSTITUTES
APR. 10, 2020
→ §82.157 SUBSTITUTE-ONLY LEAK REPAIR ENDS
NOV. 15, 1993
→ OLD DATE
→ STILL PART OF CURRENT RECOVERY / EVACUATION RULES
ARI 740-1993
ARI 740-1995
→ HISTORICAL NAMES STILL CORRECT
AHRI 740-2016
→ NEWER EQUIPMENT STANDARD NAME
$37,500
→ HISTORICAL PENALTY FIGURE
CURRENT PENALTY
→ CHECK §19.4
→ ENFORCEMENT-PATH SPECIFIC
A2L / B2L
→ CURRENT SAFETY-CLASSIFICATION CONCEPTS
PROVIDER PROCEDURE
→ VERIFY AT TEST TIME

29. Cross-Reference Guide

NeedCourse Reference
Earlier detailed current/historical regulatory instruction2.8 - Current and Historical Regulation Comparison.md
Universal high-priority numbers10.2 - High-Priority Numbers and Thresholds.md
Refrigerant environmental families11.3 - Refrigerant Family and Environmental Comparison.md
Pressure and safety classification11.4 - Refrigerant Pressure and Safety Classification Reference.md
Recovery and evacuation tables11.6 - Master Recovery and Evacuation Tables.md
Leak repair and recordkeeping11.7 - Leak Repair Recordkeeping and Regulatory Reference.md
Recovery equipment standards/tools11.8 - Recovery Equipment Cylinder and Tool Reference.md
Safety checklist11.10 - Master Safety Checklist.md
Safe disposal and refrigerant transfer11.11 - Safe Disposal and Refrigerant Transfer Reference.md
Regulatory update workflow11.15 - Regulatory Verification and Update Procedure.md

References

Current Federal Regulatory Sources

  1. Electronic Code of Federal Regulations, 40 CFR § 82.154 - Prohibitions, accessed August 14, 2026.
    https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.154

  2. Electronic Code of Federal Regulations, 40 CFR § 82.156 - Proper Evacuation of Refrigerant from Appliances, accessed August 14, 2026.
    https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.156

  3. Electronic Code of Federal Regulations, 40 CFR § 82.157 - Appliance Maintenance and Leak Repair, accessed August 14, 2026.
    https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.157

  4. Electronic Code of Federal Regulations, 40 CFR § 82.158 - Standards for Recovery and/or Recycling Equipment, accessed August 14, 2026.
    https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.158

  5. Electronic Code of Federal Regulations, 40 CFR § 82.161 - Technician Certification, accessed August 14, 2026.
    https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.161

  6. Electronic Code of Federal Regulations, Appendix D to 40 CFR Part 82, Subpart F - Standards for Becoming a Certifying Program for Technicians, accessed August 14, 2026.
    https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/appendix-Appendix%20D%20to%20Subpart%20F%20of%20Part%2082

  7. Electronic Code of Federal Regulations, 40 CFR § 84.106 - Leak Repair, accessed August 14, 2026.
    https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-C/section-84.106

  8. Electronic Code of Federal Regulations, 40 CFR § 19.4 - Statutory Civil Monetary Penalties, accessed August 14, 2026.
    https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-19/section-19.4

Current EPA Sources

  1. U.S. Environmental Protection Agency, Regulatory Updates: Section 608 Refrigerant Management Regulations, accessed August 14, 2026.
    https://www.epa.gov/section608/regulatory-updates-section-608-refrigerant-management-regulations

  2. U.S. Environmental Protection Agency, Stationary Refrigeration Leak Repair Requirements, accessed August 14, 2026.
    https://www.epa.gov/section608/stationary-refrigeration-leak-repair-requirements

  3. U.S. Environmental Protection Agency, Refrigerant Sales Restriction, last updated March 23, 2026; accessed August 14, 2026.
    https://www.epa.gov/section608/refrigerant-sales-restriction

  4. U.S. Environmental Protection Agency, Refrigerant Recovery and Recycling Equipment Certification, last updated July 6, 2026; accessed August 14, 2026.
    https://www.epa.gov/section608/refrigerant-recovery-and-recycling-equipment-certification

  5. U.S. Environmental Protection Agency, Certification Programs for Section 608 Technicians, accessed August 14, 2026.
    https://www.epa.gov/section608/certification-programs-section-608-technicians

  6. U.S. Environmental Protection Agency, Section 608 Technician Certification Requirements, last updated July 15, 2026; accessed August 14, 2026.
    https://www.epa.gov/section608/section-608-technician-certification-requirements

  7. U.S. Environmental Protection Agency, Recordkeeping and Reporting Requirements for Stationary Refrigeration, accessed August 14, 2026.
    https://www.epa.gov/section608/recordkeeping-and-reporting-requirements-stationary-refrigeration

Current Safety-Classification Sources

  1. ASHRAE, Refrigeration Resources - Standard 34-2024, accessed August 14, 2026.
    https://www.ashrae.org/technical-resources/bookstore/ashrae-refrigeration-resources

  2. ASHRAE, Standards Addenda - ANSI/ASHRAE Standard 34-2024, accessed August 14, 2026.
    https://www.ashrae.org/technical-resources/standards-and-guidelines/standards-addenda

  3. ASHRAE, ANSI/ASHRAE Addendum h to Standard 34-2010, historical 2L-classification source, accessed August 14, 2026.
    https://www.ashrae.org/file%20library/technical%20resources/standards%20and%20guidelines/standards%20addenda/34_2010_efgh_forposting.pdf

Provider-Specific Sources

  1. SkillCat, EPA 608 Certification Study Guide 2026, accessed August 14, 2026.
    https://www.skillcatapp.com/post/epa-608-certification-study-guide-1

  2. SkillCat, EPA 608 Practice Test 2026: Core & Types I-III Guide, accessed August 14, 2026.
    https://www.skillcatapp.com/post/epa-608-practice-test-guide-core-type-i-ii-iii

  3. SkillCat, How to Prepare for the EPA 608 Proctored Exam, accessed August 14, 2026.
    https://www.skillcatapp.com/post/how-to-prepare-for-the-epa-608-proctored-exam

Provider-specific sources are included only for examination-delivery procedures. They do not control federal Section 608 technical requirements.

Course Cross-References

  1. 2.8 - Current and Historical Regulation Comparison

  2. 10.2 - High-Priority Numbers and Thresholds

  3. 11.4 - Refrigerant Pressure and Safety Classification Reference

  4. 11.6 - Master Recovery and Evacuation Tables

  5. 11.7 - Leak Repair Recordkeeping and Regulatory Reference

  6. 11.11 - Safe Disposal and Refrigerant Transfer Reference