The DOT establishes the standards for refrigerant cylinder color coding, labelling, inspection intervals, relief and constraint requirements and the like. The ARI establishes purity standards for halocarbon refrigerants and mixes as well as connectivity and recovery and recycling, including recovery equipment. The EPA sets mainly guidelines if your refrigerant inventory and turnover are below certain limits but compliance requires the recording of the quantities of refrigerant contained in each circuit over a certain size or nominal containment as well as the risk assessment mainly in terms of off site risks associated with refrigerant storage over a certain threshold quantity for each refrigerant. OSHA is concerned with on site risks....So the first answer to your question on access would be: What group is equipped, trained and prepared to handle the refrigerants? Then, what group is actually going to do the work? and additionally, Who is responsible for the inventory and the corresponding records: because even if EPA does not have CERCLA type constraints on the purchase of refrigerant, continued consumption to them means unaddressed leakage which carries per-day fines in the high 4 and low 5 figures....Depending on the refrigerant, not the rate of leakage/ replenishment.

So just to get started a basic EPA review is required: Find and record the ODP and GWP for each refrigerant PARENT or mix component at least. Collect the SDS for each refrigerant and check the last 2 to 3 sections for SARA and CERCLA statements; : if those are benign in terms of requirements, and the Storage section does not indicate any special requirements, and the Disposal section can be easily sustained, you have a reasonably simple task. If any of those represent an upfront compliance nasty your task gets a whole lot more complicated.