Summary of Comments on EPA’s Proposed Revisions to the Refrigerant Management Program under Section 608 of the Clean Air Act - November 5, 2018

Oct 4, 2026

Summary of Comments on EPA’s proposed revisions to the Refrigerant Management Program under Section 608(c) of the Clean Air Act, dated November 5, 2018. The Environmental Protection Network (EPN) argues the reversal is arbitrary and contrary to statutory intent without scientific support. Key objections include undermining prior policy, causing industry confusion, ignoring HFC climate science tied to the Kigali Amendment, and flawed economic modeling that overstates repair frequency and costs. EPN urges EPA to withdraw the proposal.

LanguageEnglish

CategoryHealthcare

FormatPDF

Pages1

Reading Time3 min

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On October 1, 2018 proposal

Proposal is contrary to statutory language/intent

Proposal arbitrarily reverses prior policy without a clear rationale

Proposal creates industry confusion

Proposal ignores science on HFCs

Economic analysis is flawed

E N V I R O N M E N T A L P R O T E C T I O N N E T W O R K Summary of Comments on EPA’s Proposed Revisions to the Refrigerant Management Program under Section 608 of the Clean Air Act November 5, 2018 On October 1, 2018, the EPA proposed a revision to the Refrigerant Management Program under Section 608(c) of the Clean Air Act, which would relieve businesses from having to conduct leak inspections, repair leaks, and keep records for refrigeration and air conditioning equipment containing Hydrofluorocarbons (HFCs) or any other refrigerant that is a substitute for an ozone-depleting substance (ODS) . Members of the Environmental Protection Network ( EPN), an organization comprised of over 350 EPA alumni volunteering their time to protect the integrity of US EPA, human health and the environment, believe that this reversal in long-standing agency policy appears to be arbitrary, contrary to statutory intent and without scientific basis, increasing environmental threats, while creating confusion and ultimately additional liabilities and costs to industry and to society that the agency has not accounted for. 1. Proposal is Contrary to Statutory Language/Intent Section 608(c) of the Clean Air Act (“the Act”) prohibits the knowing venting, release or disposal of ODS refrigerants and their substitutes in the course of maintaining, servicing, repairing, or disposing of appliances or industrial process refrigeration. 2. Proposal Arbitrarily Reverses Prior Policy Without a Clear Rationale While the agency reasonably asserts its authority to revisit existing regulations and interpretations, EPA fails to provide a clear explanation why it is reversing prior rulemakings and long-established policy. 3. Proposal Creates Industry Confusion With the October 2018 proposal, the agency has suddenly and without clear rationale created uncertainty about how refrigerants should be managed across the industry. Businesses and individual technicians who have previously been equipped and trained to monitor and repair refrigerant leaks would now be let off the hook for HFC, HFO, and hydrocarbon-based equipment. 4. Proposal Ignores Science on HFCs For over a decade, culminating in the 2016 Kigali Amendment to the Montreal Protocol, the United States under multiple Administrations advocated for a global phasedown of HFCs because of their immediate threat to the earth’s climate system. 5. Economic Analysis is Flawed EPA claims that the proposal would save $39 million per year, but the logic underlying EPA’s modeling is flawed. EPA is assuming that leaky equipment would require repairs each year, resulting in ongoing costs over an indefinite period. In reality, repairing a leaky refrigeration or air conditioning appliance, or a refrigeration system, when done properly, should be done once or at most infrequently. For all of these reason, EPN believes that EPA should withdraw their proposed revision to the Refrigerant Management Program under Section 608(c) of the Clean Air Act. Read EPN’s Full Public Comments: [https://www.environmentalprotectionnetwork.org/hfc-comments/](https://www.environmentalprotectionnetwork.org/hfc-comments/) For more information, contact EPN by email at info@environmentalprotectionnetwork.org or call 202-656-6229. Media inquiries can be directed to press@environmentalprotectionnetwork.org or 202-656-6229.

FAQs

What change did EPA propose on October 1, 2018 under Section 608(c)?

EPA proposed revising the Refrigerant Management Program so businesses would not have to conduct leak inspections, repair leaks, and keep records for refrigeration and air conditioning equipment containing HFCs or other refrigerants that replace ozone-depleting substances.

Why does EPN argue the proposal conflicts with the Clean Air Act?

EPN states that Section 608(c) prohibits the knowing venting, release, or disposal of ODS refrigerants and their substitutes during maintenance, servicing, repairing, or disposing of appliances or industrial refrigeration processes.

What economic and scientific concerns does EPN raise?

EPN claims EPA’s $39 million per-year savings are based on flawed modeling that assumes frequent repairs over an indefinite period. It also argues EPA ignores science on HFCs, referencing the 2016 Kigali Amendment and a long-standing push for a phasedown due to climate threats.

Oct 4, 2026

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