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  1. #1
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    Access to Refrigerant Tank Storage



    I am helping write some standard operating procedures on refrigerant management for a facility. There is a bit of an internal "debate" about access to the locked storage area where they keep the refrigerant cylinders.

    One side of the debate (the Refrigerant Coordinator) is that only the HVAC supervisors and security should have keys or card access to the storage area, such that when a refrigerant technician needs to get refrigerant, they have to go to an HVAC supervisor or security to be let into the storage area.

    The other side of the debate (the HVAC Superintendent) is that all of the certified refrigerant technicians can/should have card access to the storage area.

    (In the facility's policies, the Refrigerant Coordinator is the one responsible for refrigerants but he is a contractor. The HVAC Superintendent is an employee of the company. The Refrigerant Coordinator is writing the content of the procedures with me, so we are looking for some backup for his side of the debate.)

    My question: Is there anything in the regulations or industry best practice/standards about access to storage areas that might be helpful in this. The Refrigerant Coordinator and I are having a hard time finding anything specific. (And personally, I hate digging through EPA regs; they are much less user-friendly than OSHA regs.)

    thank you!!!
    Jody



  2. #2
    Join Date
    Dec 2007
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    Re: Access to Refrigerant Tank Storage

    Jody,
    Without knowing any of your regulations, it is, or will be necessary to account for ALL refrigerant for your site.
    So procedure & accountability required for that.
    Regular checks should probably be made of stock in/out & must add up.
    Weight out/in, technician, equipment it was added to, stock levels for re-order.
    At the same time if someone is given the responsibility of it, they would need to know all this anyway.
    A lot of trust is required if all techs can go in, if that is an issue, then tighter controls required.
    The superintendent has to follow same rules for accountability , but normally only used if supervisor not available out of courtesy.
    Superintendent should be last resort.
    Others may have accurate input on regs

  3. #3
    Join Date
    Mar 2009
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    Re: Access to Refrigerant Tank Storage

    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.

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