Based on back and forth discussions in a number of threads about R-410A (and out of date information from DuPont etc.). I called the New York EPA office and asked for clarification about HFC's in general and R-410A specifically.
While R-410A is classified as an HFC which is neither a Class I (CFC) or a Class II (HCFC) and has a Zero ODP it is nonetheless considered a refrigerant.
Because it is both a refrigerant in general and a replacement for a refrigerant the EPA has well documented rules that substances used as refrigerants and replacement refrigerants DO require EPA certification to be worked on.
Yes, according to the EPA it is not illegal for a non-certified individual to purchase a R-410A pre-charged system and do a partial install the equipment but only a certified individual can open the service valves and complete the installation. This is of course aside from any common sense or warranty related discussions.
The EPA expects that in the future ODP issues and EPA will probably also encompass GWP issues in at some point in the future in regard to definitions and regulation.
For What its Worth.
While R-410A is classified as an HFC which is neither a Class I (CFC) or a Class II (HCFC) and has a Zero ODP it is nonetheless considered a refrigerant.
Because it is both a refrigerant in general and a replacement for a refrigerant the EPA has well documented rules that substances used as refrigerants and replacement refrigerants DO require EPA certification to be worked on.
Yes, according to the EPA it is not illegal for a non-certified individual to purchase a R-410A pre-charged system and do a partial install the equipment but only a certified individual can open the service valves and complete the installation. This is of course aside from any common sense or warranty related discussions.
The EPA expects that in the future ODP issues and EPA will probably also encompass GWP issues in at some point in the future in regard to definitions and regulation.
For What its Worth.
