11.7 - Leak Repair Recordkeeping and Regulatory Reference

Module: Standalone Reference Appendices and Instructor Resources
Purpose: One consolidated reference for current Section 608 ozone-depleting-refrigerant leak-repair requirements, related recordkeeping, refrigerant retailer records, safe-disposal records, and the separate current AIM Act HFC/substitute leak-repair framework
Regulatory verification date: August 14, 2026
Primary current authorities: 40 CFR §§ 82.154-82.157 and 40 CFR § 84.106
Current eCFR status checked: Title 40 displayed as up to date through August 12, 2026
Critical source-control rule: Current Section 608 ODS leak repair and current AIM Act HFC/substitute leak repair are separate regulatory pathways. Do not combine their charge thresholds or applicability rules.

How to Use This Reference

When an appliance is leaking, do not begin by memorizing a percentage.

Use this sequence:

1. IDENTIFY THE REFRIGERANT.
2. IDENTIFY THE FULL CHARGE.
3. IDENTIFY THE APPLIANCE APPLICATION.
4. DETERMINE WHICH CURRENT FEDERAL LEAK-REPAIR PROGRAM APPLIES.
5. CALCULATE / EVALUATE THE LEAK RATE.
6. APPLY THE CORRECT TRIGGER RATE.
7. REPAIR OR FOLLOW THE APPLICABLE RETROFIT / RETIREMENT PATH.
8. COMPLETE REQUIRED VERIFICATION TESTS.
9. COMPLETE REQUIRED LEAK INSPECTIONS.
10. KEEP / PROVIDE THE REQUIRED RECORDS.
11. CHECK CHRONIC-LEAKER REPORTING.

The most important current distinction is:

SECTION 608 §82.157
→ qualifying ODS appliances
→ 50 lb or more full charge

versus:

AIM ACT §84.106
→ qualifying HFC / substitute appliances
→ 15 lb or more full charge
→ subject to stated exclusions
→ effective January 1, 2026

1. Current Section 608 Leak-Repair Applicability

1.1 What § 82.157 Currently Covers

Current 40 CFR § 82.157 applies to appliances with a full charge of:

50 lb OR MORE

of:

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

The section does not apply to appliances containing solely substitute refrigerants.

Applicability Table

High-Priority Precision

Older wording often says:

MORE THAN 50 lb

Current § 82.157 says:

50 lb OR MORE

For current regulatory precision:

50 lb
→ INCLUDED

2. Current Section 608 ODS Trigger Rates

For a qualifying § 82.157 appliance, the trigger rate depends on the application category.

2.1 Master Trigger-Rate Table

These leak rates are expressed as the percentage of the appliance’s full charge that would be lost over a 12-month leak-rate basis if the current loss rate continued.

Fast Memory Rule

30
20
10

in this order:

IPR
COMMERCIAL
COMFORT / OTHER

3. Historical 35% and 15% Values Are Obsolete

Older EPA 608 training materials often contain:

35%
35%
15%
15%

Those values are historical, not current § 82.157 trigger rates.

3.1 Historical Versus Current

Do Not Memorize

COMMERCIAL = 35%

for a current Section 608 question.

Use:

COMMERCIAL = 20%

Why Old Sources Can Be Wrong in Two Ways

An older source can be outdated because it:

1. Uses the former 35% / 15% trigger table.
2. Treats HFC-only appliances as if current § 82.157 leak repair still applies to them.

Current field compliance requires the correct 2026 program classification.

4. Leak Rate Is a Percentage of Full Charge

A trigger rate is not a fixed number of pounds.

Example:

20% leak rate

does not mean:

20 lb leaked

The number of pounds represented by 20% depends on the appliance’s full charge.

For a 500-lb appliance:

$$0.20\cdot 500\text{lb}=100\text{lb}$$

For a 1,000-lb appliance:

$$0.20\cdot 1000\text{lb}=200\text{lb}$$

The regulatory leak rate is evaluated using the prescribed calculation method, not simply by comparing pounds added with the numerical percentage.

5. When the Leak Rate Must Be Calculated

Under current § 82.157, the owner or operator must calculate the leak rate each time refrigerant is added to a covered appliance, except where the addition is:

• Immediately following a retrofit.
• Immediately following installation of a new appliance.
• A qualifying seasonal variance.

Persons adding or removing refrigerant must provide the owner or operator with the required service documentation after the service.

Technician Reminder

TECHNICIAN ADDS / REMOVES REFRIGERANT
→ DOCUMENTATION DUTY

OWNER / OPERATOR
→ LEAK-RATE CALCULATION AND COMPLIANCE DUTY

The regulation assigns responsibilities to both the service provider and the owner/operator.

6. Current Section 608 Corrective Action

When a qualifying ODS appliance exceeds the applicable current trigger rate, the owner or operator generally must:

REPAIR

or:

RETROFIT / RETIRE

under the applicable regulatory pathway.

6.1 Repair Deadline

The ordinary repair period is:

30 days

from when refrigerant is added to an appliance that exceeds the applicable leak rate.

If an industrial process shutdown is required:

120 days

is substituted for the ordinary 30-day period.

Allowed extensions exist under specified conditions. Do not assume an extension exists merely because a repair is inconvenient.

6.2 Certified-Technician Leak Inspection

When a covered appliance exceeds its trigger rate:

CERTIFIED TECHNICIAN
→ conducts leak inspection
→ identifies leak location

The technician selects method or methods appropriate to the appliance and inspects visible and accessible components subject to the rule’s stated accessibility and safety exceptions.

7. Initial Verification Test

A leak-location test and an initial verification test are not the same thing.

The leak-location inspection identifies where refrigerant is leaking.

The initial verification test confirms that the attempted repair has held.

7.1 Timing

Unless additional time is granted, the initial verification test must occur within the applicable:

30-day

or:

120-day IPR shutdown

repair period.

7.2 Repair Without Evacuation

If the repair can be completed without opening or evacuating the appliance:

REPAIR
→ INITIAL VERIFICATION
→ BEFORE ADDING ADDITIONAL REFRIGERANT

7.3 Repair Requiring Evacuation

If the appliance or isolated portion must be evacuated:

REPAIR
→ INITIAL VERIFICATION
→ BEFORE ADDING ANY REFRIGERANT

7.4 Failed Initial Test

If the initial verification test indicates the repair was unsuccessful, additional repairs and initial verification tests may be performed within the applicable repair period.

8. Follow-Up Verification Test

A current § 82.157 covered repair also requires a follow-up verification test.

8.1 Current Timing

The follow-up test must be performed within:

10 days

of:

• The successful initial verification test, or
• The appliance reaching normal operating characteristics and conditions when the appliance or isolated component was evacuated for the repair.

Critical Current Value

FOLLOW-UP VERIFICATION
→ 10 DAYS

Do not substitute an older or simplified 30-day statement for the current § 82.157 follow-up-test timing.

8.2 Purpose

The follow-up test demonstrates that the leak where the repair attempt was made remains repaired.

If testing at normal operating conditions is unsafe or otherwise impossible, the current rule provides the stated alternative where practicable.

9. Verification Sequence

Use this sequence:

LEAK-RATE EXCEEDANCE
→ LEAK INSPECTION
→ IDENTIFY LEAK
→ REPAIR
→ INITIAL VERIFICATION
→ RESTORE REFRIGERANT / OPERATING CONDITION AS APPLICABLE
→ FOLLOW-UP VERIFICATION

Do not confuse:

LEAK INSPECTION

with:

INITIAL VERIFICATION

or:

FOLLOW-UP VERIFICATION

They serve different functions.

10. Section 608 Leak-Inspection Frequency After Exceedance

After a covered appliance exceeds the applicable trigger rate, recurring leak inspections can be required.

10.1 Inspection Schedule

Qualifying automatic leak-detection systems can alter the ordinary inspection requirement for monitored portions when the regulatory conditions are satisfied.

Exam Trap

500 lb
→ changes LEAK-INSPECTION FREQUENCY

It does not change the current § 82.157 trigger percentage.

11. Chronic-Leaker Reporting Under Section 608

For a qualifying appliance within current § 82.157 applicability:

FULL CHARGE ≥50 lb

and:

CALENDAR-YEAR LOSS ≥125% OF FULL CHARGE

triggers chronic-leaker reporting.

The owner/operator must report to EPA:

BY MARCH 1
OF THE SUBSEQUENT YEAR

11.1 Memory Rule

125%
→ CHRONIC LEAKER

MARCH 1
→ REPORT DUE

Example

A qualifying ODS appliance has a full charge of 400 lb.

If total calendar-year loss is equivalent to:

$$1.25\cdot 400\text{lb}=500\text{lb}$$

or more, the 125% chronic-leaker reporting threshold is reached.

The report describes efforts to identify leaks and repair the appliance.

12. General Section 608 Record-Retention Rule

Records identified in current § 82.157(l) generally must be retained for at least:

3 YEARS

in paper or electronic format unless otherwise specified.

One major longer-duration category is the full-charge record, which is maintained until:

3 YEARS AFTER THE APPLIANCE IS RETIRED

13. Section 608 Full-Charge Records

For covered appliances with a full charge of 50 lb or more, owners/operators must determine and maintain full-charge information.

13.1 Required Full-Charge Information

Records include:

• Identification of the owner/operator.
• Address where the appliance is located.
• Full charge.
• Method used to determine full charge.
• If an established range is used, the range, midpoint, and method used to establish the range.
• Revisions to full charge.
• How revisions were determined.
• Dates of revisions.

13.2 Retention

These records are maintained until:

3 YEARS AFTER APPLIANCE RETIREMENT

14. Section 608 Maintenance, Service, Repair, and Disposal Records

For each applicable maintenance, service, repair, or disposal event on a covered 50-lb-or-more appliance, the owner/operator must maintain the required record.

14.1 Record Fields

The record includes, when applicable:

• Appliance identity and location.
• Date of maintenance, service, repair, or disposal.
• Part or parts being worked on.
• Type of work performed.
• Name of the person performing the work.
• Amount and type of refrigerant added.
• For disposal, amount and type of refrigerant removed.
• Full charge.
• Leak rate.
• Method used to determine the leak rate.

The leak-rate fields do not apply in the same way to disposal, immediately following retrofit, new-appliance installation, or qualifying seasonal variance.

14.2 Technician Documentation Duty

When the work is performed by someone other than the owner/operator:

SERVICE PROVIDER
→ must provide required service documentation
→ to OWNER / OPERATOR

This is a major practical recordkeeping responsibility for contractors and technicians.

15. Section 608 Leak-Inspection Records

Leak-inspection records include:

• Inspection date.
• Method or methods used.
• Location of each identified leak.
• Certification that all visible and accessible parts required by the rule were inspected.

Technicians conducting the leak inspection must provide the required documentation to the owner/operator after the service.

16. Automatic Leak-Detection Records

Where a qualifying automatic leak-detection system is used under § 82.157, records include items such as:

• System installation.
• Annual audit/calibration.
• Dates on which the monitoring system identified a leak.
• Leak location.

Automatic leak detection does not erase recordkeeping duties.

If only part of the appliance is monitored, unmonitored portions remain subject to the applicable inspection requirements.

17. Verification-Test Records

Owners/operators must maintain records of all required initial and follow-up verification tests.

17.1 Required Information

Records include:

• Appliance location.
• Date or dates of verification tests.
• Location of repaired leak or leaks tested.
• Type of verification test used.
• Results of the test.

Technicians performing the tests must provide this documentation to the owner/operator after the service.

18. Other Section 608 Leak-Repair Record Categories

Current § 82.157 includes additional recordkeeping categories.

Unless otherwise specified, the general retention requirement is at least three years.

19. Retrofit or Retirement Path

Instead of repairing an appliance under the ordinary pathway, an owner/operator can elect to retrofit or retire it under the applicable current rule.

A retrofit/retirement plan is generally required within:

30 days

of the triggering condition.

The plan generally contains:

• Appliance identification and location.
• Current refrigerant and full charge.
• New refrigerant/full charge if retrofitted.
• Conversion procedure if retrofitted.
• Disposition plan for recovered refrigerant.
• Appliance disposition plan if retired.
• Schedule for completion.

The normal schedule may not exceed:

1 YEAR

subject to applicable extension provisions.

This appendix is a quick reference. Use the current regulation for unusual extension or relief cases.

20. Refrigerant Retailer Records

Leak-repair records are not the only important Section 608 records.

Current § 82.154(c) also requires records for applicable refrigerant sales.

20.1 Retailer Invoice Fields

For applicable sales/distribution of class I, class II, or non-exempt substitute refrigerant, the seller must keep invoices showing:

• Purchaser name.
• Date of sale.
• Quantity of refrigerant purchased.

Certain exempt substitutes and qualifying small MVAC cans are excepted from this invoice provision.

20.2 Employer-Purchase Documentation

When the buyer relies on the fact that the buyer employs a certified technician:

SELLER
→ keeps documentation
→ showing qualifying certified-technician employment

20.3 Retention Period

Applicable retailer sales records must be kept for:

3 YEARS

Retailer Memory Rule

NAME
DATE
QUANTITY
→ 3 YEARS

21. Used-Refrigerant Sale Reminder

Recordkeeping questions can appear near refrigerant-sales questions.

Current Section 608 generally prohibits sale/distribution of used class I, class II, or non-exempt substitute refrigerant for use as refrigerant unless an applicable exception applies, such as:

RECLAIMED BY EPA-CERTIFIED RECLAIMER

or another specifically permitted pathway.

Do not confuse:

RECOVERED

with:

RECLAIMED

when ownership and resale change.

See 11.11 - Safe Disposal and Refrigerant Transfer Reference.md for the detailed transfer/reclamation reference.

22. Disposal Records for Appliances With More Than 5 and Less Than 50 Pounds

A separate current recordkeeping provision appears in § 82.156(a)(3).

It applies to technicians evacuating refrigerant for purposes of disposal from appliances covered by § 82.156(a) with a full charge:

MORE THAN 5 lb
AND
LESS THAN 50 lb

22.1 Required Technician Records

The technician must keep records documenting for three years:

1. For each appliance:

   • Company name.
   • Appliance location.
   • Date of recovery.
   • Type of refrigerant recovered.

2. For each calendar month:

   • Total quantity of refrigerant recovered, by refrigerant type, from disposed appliances.

3. For refrigerant transferred:

   • Quantity by refrigerant type transferred for reclamation and/or destruction.
   • Person to whom it was transferred.
   • Date of transfer.

Exact Boundary

>5 lb
AND
<50 lb

means:

• Exactly 5 lb is outside this stated range.
• Exactly 50 lb is outside this stated range.

Do not rewrite the rule as:

5 to 50 lb

23. Safe-Disposal Records for Small Appliances, MVACs, and MVAC-Like Appliances

Current § 82.155 establishes a different safe-disposal record pathway for the final processor of:

• Small appliances.
• MVACs.
• MVAC-like appliances.

The final processor must either recover remaining refrigerant or verify prior recovery using the permitted signed-statement/contract approach.

23.1 Signed Prior-Recovery Statement

If a signed statement is used, it must include:

• Name of the person who recovered the refrigerant.
• Address of the person who recovered the refrigerant.
• Date the refrigerant was recovered.

23.2 Contract Pathway

A qualifying contract between the supplier and final processor can state that the supplier will recover remaining refrigerant before delivery or verify that refrigerant was already properly recovered before receipt.

23.3 Leaked-Out Statement

If all refrigerant leaked out before delivery, the final processor must obtain the required signed statement.

“Leaked out” means loss caused by:

• System failure.
• Accident.
• Other unavoidable occurrence.

It does not include losses caused by:

• Negligence.
• Deliberate acts.
• Cutting refrigerant lines to empty the appliance.

23.4 Final-Processor Record Retention

The final processor must keep the signed statements/contracts:

ON SITE

in hard-copy or electronic form for:

3 YEARS

Important Distinction

§82.156(a)(3)
→ technician disposal records
→ >5 and <50 lb appliances covered by paragraph (a)

versus:

§82.155
→ final processor
→ small appliance / MVAC / MVAC-like
→ signed statement / contract
→ 3 years

These are different recordkeeping pathways.

24. Recordkeeping Master Table

25. Separate Current AIM Act Leak-Repair Framework

Current HFC/substitute leak repair is not restored to § 82.157.

Instead, beginning:

JANUARY 1, 2026

current 40 CFR § 84.106 establishes a separate leak-repair program for qualifying refrigerant-containing appliances.

26. AIM Act Applicability

Current § 84.106 generally applies to a refrigerant-containing appliance with a full charge of:

15 lb OR MORE

where the refrigerant contains:

1. A regulated substance under the AIM Act, or
2. A substitute for a regulated substance with a GWP greater than 53, based on the Part 84 table used by the rule.

26.1 Explicit Exclusions

The current § 84.106 leak-repair requirements do not apply to:

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

Current Program Decision

ODS-ONLY APPLIANCE
→ evaluate §82.157

QUALIFYING HFC / SUBSTITUTE APPLIANCE
→ evaluate §84.106

TYPICAL RESIDENTIAL / LIGHT-COMMERCIAL A/C OR HEAT PUMP
→ §84.106 exclusion may apply

This classification does not remove other Section 608 duties such as certification, venting prohibition, recovery, evacuation, and safe disposal where applicable.

27. AIM Act Trigger Rates

The current § 84.106 trigger rates are:

The percentages are similar to current § 82.157 values.

The applicability thresholds are not.

Memory Comparison

SECTION 608 ODS
→ ≥50 lb

AIM HFC / SUBSTITUTE
→ ≥15 lb

28. AIM Repair and Verification Timing

For a covered § 84.106 appliance that exceeds the applicable leak rate:

• Repair generally occurs within 30 days.
• If an industrial process shutdown is required, the ordinary period becomes 120 days.
• A certified technician conducts the leak inspection.
• Covered repairs require initial and follow-up verification tests.

28.1 AIM Follow-Up Verification

The current AIM follow-up verification timing is also:

10 DAYS

from:

• Successful initial verification, or
• The appliance reaching normal operating characteristics and conditions after an evacuated repair.

Do not assume a different follow-up interval simply because the AIM Act is a separate program.

29. AIM Leak-Inspection Frequency

For covered § 84.106 appliances that exceed the trigger rate:

Qualifying automatic leak-detection systems can modify ordinary inspection requirements for monitored portions under the current Part 84 requirements.

30. AIM Chronic-Leaker Reporting

For a qualifying § 84.106 appliance:

FULL CHARGE ≥15 lb

and:

CALENDAR-YEAR LOSS ≥125%

triggers a chronic-leaker report to EPA by:

MARCH 1
OF THE SUBSEQUENT YEAR

This looks similar to the Section 608 ODS chronic-leaker rule, but the underlying applicability threshold differs.

Side-by-Side

31. AIM Recordkeeping

Current § 84.106 records are generally retained for at least:

3 YEARS

unless otherwise specified.

31.1 AIM Full-Charge Records

Owners/operators must determine full charge for covered refrigerant-containing appliances with:

15 lb OR MORE

and maintain required information.

For appliances installed on or after January 1, 2026, the record also includes the installation date.

Full-charge records are maintained until:

3 YEARS AFTER APPLIANCE RETIREMENT

31.2 AIM Service Records

For each applicable installation, service, repair, or disposal event, records include:

• Appliance identity and location.
• Date.
• Part or parts involved.
• Type of work.
• Person performing the work.
• Amount and type of refrigerant added or removed.
• Full charge.
• Leak rate and calculation method where applicable.

If work is done by someone other than the owner/operator, the service provider must supply the specified documentation to the owner/operator.

31.3 Additional AIM Record Categories

Current § 84.106 also includes records for:

• Changes in leak-rate calculation methodology after qualifying ownership/acquisition changes.
• Leak inspections.
• Automatic leak-detection systems.
• Initial and follow-up verification tests.
• Retrofit/retirement plans.
• Extension requests.
• Mothballing.
• Purged-refrigerant destruction.
• Seasonal variance.
• EPA reports and responses.

32. Section 608 ODS Versus AIM HFC Quick Comparison

Most Important Difference

The trigger percentages are similar.

The coverage threshold and refrigerant scope are different.

33. Practical 2026 Decision Examples

Example 1 - Large R-22 Supermarket System

Given:

• Refrigerant: R-22.
• Full charge: 600 lb.
• Application: commercial refrigeration.

Current analysis:

R-22
→ class II ODS

600 lb
→ ≥50 lb

Therefore:

§82.157 APPLIES

Commercial trigger:

20%

Because charge is ≥500 lb and the appliance has exceeded the trigger:

quarterly leak-inspection schedule

applies under the stated conditions.

Example 2 - Large HFC Supermarket System

Given:

• HFC-containing refrigerant.
• Full charge: 600 lb.
• Commercial refrigeration.

Current analysis:

HFC-only
→ §82.157 leak repair does not apply

Then:

evaluate §84.106

If the refrigerant meets the Part 84 coverage criterion:

600 lb ≥15 lb
→ commercial refrigeration
→ 20% trigger

Example 3 - Residential R-410A Split System

Given:

• R-410A.
• Full charge: 18 lb.
• Residential split A/C.

Current analysis:

HFC-only
→ not §82.157

The charge is above 15 lb, but a typical appliance in the residential/light-commercial A/C and heat-pump subsector is excluded from current §84.106 leak repair.

This does not remove:

• Section 608 technician-certification requirements.
• Venting prohibition.
• Recovery requirements.
• Evacuation requirements.
• Safe-disposal requirements.

It only changes which leak-repair program applies.

Example 4 - 50-lb R-22 Comfort-Cooling Appliance

Given:

• R-22.
• Exactly 50 lb full charge.
• Comfort cooling.

Current analysis:

50 lb
→ meets §82.157 threshold

Trigger:

10%

Do not exclude the appliance because an older source says “more than 50 lb.”

Example 5 - 400-lb R-22 Commercial Appliance Losing 125% in a Year

Current chronic-leaker threshold:

$$1.25\cdot 400\text{lb}=500\text{lb}$$

If calendar-year loss reaches 500 lb or more:

CHRONIC-LEAKER REPORT
→ due March 1 of following year

Example 6 - Technician Disposes of a 20-lb Covered Stationary Appliance

The appliance falls within:

>5 lb
AND
<50 lb

for the §82.156(a)(3) disposal-record range if the appliance is within paragraph (a)’s scope.

The technician keeps the required recovery/transfer records for:

3 YEARS

This is not the same as §82.157 large-ODS leak-repair recordkeeping.

Example 7 - Refrigerant Wholesaler Sale

A wholesaler sells regulated refrigerant to a certified technician.

The applicable sales invoice record includes:

PURCHASER NAME
DATE OF SALE
QUANTITY PURCHASED

Retention:

3 YEARS

Example 8 - Final Processor Receives Household Refrigerators

The final processor relies on prior recovery.

The permitted signed statement includes:

NAME
ADDRESS
DATE OF RECOVERY

of the person who recovered the refrigerant.

The final processor keeps the statement/contract on site for:

3 YEARS

34. Recordkeeping Responsibility Map

OWNER / OPERATOR
→ full charge
→ leak-rate calculations
→ service history
→ leak inspections
→ verification tests
→ retrofit / retirement
→ reports

TECHNICIAN / SERVICE PROVIDER
→ provides required service documentation
→ provides leak-inspection documentation
→ provides verification-test documentation
→ keeps specific disposal records where §82.156(a)(3) applies

REFRIGERANT SELLER / DISTRIBUTOR
→ sales invoices
→ qualifying certified-employee proof
→ 3-year retention

FINAL PROCESSOR
→ prior-recovery statements / contracts
→ on-site retention for 3 years

35. High-Priority Numbers

36. Common Mistakes and Confusing Points

Mistake 1 - Using 35% and 15% as Current Trigger Rates

Those are historical values.

Use current:

30% / 20% / 10%

Mistake 2 - Saying “More Than 50 Pounds”

Current §82.157 applicability is:

50 lb OR MORE

Exactly 50 lb is included.

Mistake 3 - Applying §82.157 to Every HFC Appliance

Current §82.157 does not apply to appliances containing solely substitute refrigerants.

Evaluate the separate current AIM Act framework.

Mistake 4 - Assuming Every 15-lb HFC Appliance Is Covered by AIM Leak Repair

Current §84.106 contains exclusions, including the residential/light-commercial A/C and heat-pump subsector.

Check the application.

Mistake 5 - Treating a 20% Trigger as 20 Pounds

The trigger is a percentage of the appliance’s full charge over the regulatory leak-rate basis.

Mistake 6 - Confusing Leak Inspection With Verification Test

LEAK INSPECTION
→ finds the leak

VERIFICATION TEST
→ confirms the repair

Mistake 7 - Forgetting the Follow-Up Test

Covered repair:

INITIAL
+
FOLLOW-UP

Both are required.

Mistake 8 - Using 30 Days for the Follow-Up Verification Test

The current follow-up interval under the stated §82.157 and §84.106 conditions is:

10 DAYS

Mistake 9 - Assuming Every Record Is Kept Only Three Years From Creation

Full-charge records have a longer lifecycle:

until 3 years after appliance retirement

Mistake 10 - Assuming the Owner/Operator Creates Every Service Record Alone

Technicians/service providers have explicit documentation duties and must provide specified service, inspection, and verification information to the owner/operator.

Mistake 11 - Confusing Retailer Records With Appliance Service Records

Retailer invoices focus on:

purchaser
date
quantity

They are not leak-inspection records.

Mistake 12 - Calling the Disposal Record Range “5 to 50 lb”

The current §82.156(a)(3) wording is:

MORE THAN 5
AND
LESS THAN 50

The endpoints are excluded.

Mistake 13 - Using a Sticker as the Safe-Disposal Verification

A sticker alone is not the federal signed-statement/contract pathway required when the final processor relies on prior recovery.

Mistake 14 - Treating Deliberate Line Cutting as “Leaked Out”

The leaked-out provision is for system failure, accident, or other unavoidable occurrence, not deliberate or negligent release.

37. EPA 608 Exam Focus

For current Section 608 preparation, know:

§82.157
→ ODS
→ ≥50 lb

IPR 30%
COMMERCIAL 20%
COMFORT / OTHER 10%

REPAIR
→ 30 days

IPR SHUTDOWN
→ 120 days

INITIAL + FOLLOW-UP VERIFICATION

FOLLOW-UP
→ 10 days

CHRONIC
→ 125%
→ MARCH 1

GENERAL RECORD RETENTION
→ 3 years

35% / 15%
→ HISTORICAL
→ DO NOT USE AS CURRENT

For current field compliance, also know:

AIM §84.106
→ qualifying HFC / substitute
→ ≥15 lb
→ effective Jan. 1, 2026
→ check exclusions

38. Final Decision Checklist

Before applying a leak-repair number, verify:

• Refrigerant identified.
• ODS versus HFC/substitute determined.
• Full charge determined.
• Exactly 50 lb treated correctly under §82.157.
• Exactly 15 lb treated correctly under §84.106.
• Appliance application identified.
• Residential/light-commercial AIM exclusion checked.
• Current trigger rate selected.
• Leak inspection performed by qualified/certified technician where required.
• Repair deadline identified.
• Initial verification completed.
• Follow-up verification completed within current timing.
• Required recurring inspection schedule identified.
• Chronic-leaker threshold checked.
• Required service records completed.
• Technician documentation provided to owner/operator.
• Retailer records handled separately.
• Disposal records handled under the correct pathway.
• Historical 35%/15% values rejected for current compliance.
• Current eCFR checked if a real field decision depends on the rule.

39. Cross-Reference Guide

References

Current Section 608 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 § 82.155 - Safe Disposal of Appliances, accessed August 14, 2026.
   https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.155

3. 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

4. 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

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

6. U.S. Environmental Protection Agency, Recordkeeping Requirements for Refrigerant Retailers, current project verification August 14, 2026.
   https://www.epa.gov/section608/recordkeeping-requirements-refrigerant-retailers

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

8. U.S. Environmental Protection Agency, Stationary Refrigeration Safe Disposal Requirements, current project verification August 14, 2026.
   https://www.epa.gov/section608/stationary-refrigeration-safe-disposal-requirements

Current AIM Act Source

9. Electronic Code of Federal Regulations, 40 CFR § 84.106 - Leak Repair, effective current requirements beginning January 1, 2026 and accessed August 14, 2026.
   https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-C/section-84.106

Course Cross-References

10. 2.6 - Refrigerant Sales Restrictions

11. 2.7 - Enforcement Recordkeeping and Professional Responsibility

12. 2.8 - Current and Historical Regulation Comparison

13. 6.9 - Safe Disposal Requirements

14. 8.5 - Leak Repair Requirements and Current Regulatory Updates

15. 10.2 - High-Priority Numbers and Thresholds

16. 11.6 - Master Recovery and Evacuation Tables