EH&S From Experience: HFC Refrigerants

In the latest issue of Hixson’s EH&S From Experience newsletter, we noted that as of January 1, 2026, 40 CFR Part 84 requires Hydrofluorocarbons (HFCs) listed under Appendix A to be phased down due to their global warming potential.

This does not limit use of existing equipment: It phases out future use of HFC on the list by prohibiting manufacture of new equipment using the regulated HFCs. However, there are some requirements for the use of the existing equipment. Per 84.106(c) (Leak Repair), appliances containing 15 lbs. or more of the listed HFCs require the following actions as of 1/1/26:

• Use a certified technician.
• Leak repair is needed for:
  • a 30% leak rate for industrial process refrigeration appliances
  • a 10% leak rate for comfort cooling appliances
  • a 20% leak rate for commercial refrigeration appliances
• Repair within 30 days (120 days if an industrial process shutdown is required).
• Verification test on each repair must be within 30 days (120 days if industrial shutdown).
• Follow-up verification test must be performed within 10 days of initial verification test.
• Extension of repair deadline under certain circumstances (84.106(f)).
• Leak inspection (84.106(g)).
• Retrofit or retirement plans within 30 days (84.106(h)).
• Extension of the one-year retrofit or retirement schedule (84.106(i)).
• Reporting must be submitted electronically using the Agency’s reporting platform (84.106(m))
• Recordkeeping of all records for at least three years (84.106(l)) – rule is specific that the owner/operator must keep records.

These actions are similar to that required of Chlorofluorocarbons (CFCs) and Hydrochlorofluorocarbons (HCFCs) under Part 82 of the standard.

For more information on these requirements, contact Hixson.