Has anyone seen a definitive description of what is needed to be compliant as a seller of refrigerant ??
GM published GCUS-9-5237 back in December states, "effective January 1, 2018, a section 609 certification card will be required to sell R-12, R-134a, or R-1234yf cylinders of 2 pounds or more", And then, "GM Dealers will be required to keep records of certified technicians purchasing refrigerant."
We don't sell cylinders to anyone, all of our refrigerant use is done within the service department using our certified A/C machine, not over the counter in cylinders. Our technicians do not purchase the Freon, the customer does, but the tech uses the refrigerant when servicing or repairing the A/C system.
I found three documents online at the EPA website, but cannot share the URL on this forum. Here are the two document titles, which you should be able to google and read.
- Recordkeeping Requirements for Refrigerant Retailers
epa dot gov/section608/recordkeeping-requirements-refrigerant-retailers
- Overlap between Section 608 and Section 609
epa dot gov/section608/overlap-between-section-608-and-section-609
- 608 fact sheet distributors and wholesalers
epa dot gov/sites/production/files/2016-09/documents/608_fact_sheet_distributors_and_wholesalers_0 dot pdf
which states... "Starting January 1, 2018, refrigerant distributors and wholesalers must:
Only sell or distribute refrigerants containing CFCs, HCFCs, or HFCs to technicians certified underSections 608 or 609 of the Clean Air Act.
The EPA is allowing the continued sale of small cans (under two pounds) of R-134a to DIY-ersfor use in MVAC systems. Cans must be equipped with a self-sealing valve."
Everything I read seems very general and vague, and then becomes open to interpretation.
Looking to see what others are doing or planning to do...
~gt