ACtion Magazine - Napa Special Edition - June 2017 - 5

Regulating recharge
Steve Schaeber

ummertime is here, and that means many shops
are feeling the full heat of A/C season. With
temperatures rising, customers are seeking cool
rides, and to help them out (and keep their profits up), many shops are offering A/C System
Top-Off Service. But in some parts of the U.S. that simple
refill may not be legal (and if it is, it may be against your
shop's policy for ethical reasons). How then should you
handle a customer who asks for it?

mission Regulation Number 15 (5 CCR 1001-19), which
requires mobile A/C system leak testing in that state. Several other localities have issued the same laws, making it
important for each shop and technician to know those laws
applicable to where they live and work.
This myriad of regulations stems from the early days of
the CFC phase out (around 1990) when the revised Clean
Air Act was passed, partially because some communities
didn't think existing rules went far enough. However,
most areas of the U.S. simply follow the current federal
program (Title 40 CFR, Part 82).

The U.S. Environmental Protection Agency (EPA) regulates mobile A/C system service, basically by requiring
technicians to become Section 609
Certified and to use equipment and
So what about that customer
methods that meet certain standards.
who insists they need a recharge,
But one thing it doesn't require is
even though you're sure their A/C
...unless that system has system has a leak (including the
leak repair, which may seem counterintuitive for the nation's top environno detectable leaks really small ones)? We asked a few
mental agency. There are, however,
MACS member shops, and the conseveral state and local laws that do
sensus was pretty much the same
require leak repair prior to rechargacross the board. Each response
ing, which is something you should
said it's against their shop's policy
research in your area.
to recharge a leaking system (for
ethical reasons; all MVAC refrigerants are ozone depleters
MACS knows about a few such laws, although cer- and / or they contribute to global warming), and indicated
tainly not all of them. In California, for example, the Bay they educate their customers as to why it's such a poor serArea Air Quality Management District (which includes vice practice. In most cases, customers seem to agree and
several counties surrounding San Francisco) adopted Rule reschedule service when their finances allow.
7 of Regulation 12 on June 17, 1992. Section 301 states:
No person shall add refrigerant to any motor vehicle air
MACS has always recommended that finding and fixconditioning system unless that system has no detectable ing the leak(s) is the best solution for the customer and
leaks. It further requires a visual inspection followed by the environment. What's the policy at your shop? How do
the use of an electronic leak detector (which meets SAE your local laws compare? Send an e-mail to steve@macsw.
Standards). Other California AQMDs have passed similar org or visit our website www.macsw.org to let us know! ❆
regulations.

In 2014 the Wisconsin Legislature passed AB 695, a law
that repealed their state's licensing requirement for mobile
A/C technicians, instead requiring them to become Section
609 certified through an EPA approved agency (such as
MACS). But this bill did not change Wisconsin's existing
leak repair law. The topping off of leaky systems is still
prohibited under ATCP 136.20 (as is knowingly or negligently releasing refrigerant into the environment). Similar
legislation exists in Colorado's Air Quality Control Com-

Steve Schaeber
Manager of Service Training
You can reach Steve at
steve@macsw.org

Spring 2017 * ACTION/NAPA

http://www.macsw.org

Table of Contents for the Digital Edition of ACtion Magazine - Napa Special Edition - June 2017