Section 609 Refrigerant Technician Certification Policy

Policy requiring or supporting EPA Section 609 certification for service-bay technicians who service motor vehicle air conditioning (MVAC) systems and for employees who verify refrigerant sales eligibility.

Purpose

• This policy establishes requirements for EPA Section 609 certification for employees who perform service, repair, recovery, recycling, or related work on motor vehicle air conditioning (MVAC) systems, and for employees responsible for verifying refrigerant sales eligibility. The policy supports compliance with the federal Clean Air Act and EPA Section 609 technician certification requirements.

Scope

• This policy applies to all employees, temporary workers, contractors, and supervisors who: - Perform MVAC service or repair work in service bays or mobile service settings. - Recover, recycle, or handle refrigerant used in MVAC systems. - Verify technician certification before refrigerant sales are completed. - Supervise or approve work that requires Section 609 certification. California employees: this policy does not replace any additional state environmental, labor, or licensing requirements that may apply. Where state law imposes stricter requirements, the stricter rule controls.

Definitions

• - **MVAC**: Motor vehicle air conditioning systems in vehicles used for transportation. - **Section 609 certification**: EPA-approved certification required for technicians who service MVAC systems. - **Certified technician**: An individual who has completed EPA-approved training and passed the Section 609 certification test. - **Refrigerant sales verification**: The process of confirming that a purchaser is authorized to buy regulated refrigerant where certification is required. - **Policy holder**: The company department or manager responsible for administering this policy.

Policy Statement

• 1. Employees may not perform MVAC service, refrigerant recovery, or refrigerant-related work unless they hold valid Section 609 certification when certification is required by law or by company procedure. 2. Supervisors must ensure that only certified technicians are assigned to MVAC work that requires certification. 3. Employees responsible for refrigerant sales must verify certification or other required eligibility documentation before approving a sale. 4. Certification records must be maintained in a good-faith, documented manner and made available for internal compliance review. 5. No employee will be disciplined for reporting a good-faith concern that certification records are incomplete, inaccurate, or missing.

Procedure

• ### A. Hiring and assignment - Before assigning an employee to MVAC work, the hiring manager or service manager must confirm whether Section 609 certification is required for the role. - If certification is required, the employee must provide proof of current certification before independent MVAC work begins. ### B. Certification verification - Acceptable proof includes a certification card, certificate, or other EPA-approved documentation. - The supervisor or designated verifier must record the employee name, certification date, and verification date in the compliance file. ### C. Training and renewal support - Employees who are not yet certified may not perform unsupervised MVAC work. - The company may support training, testing, or reimbursement at its discretion, subject to budget and role requirements. ### D. Refrigerant sales controls - Before completing a refrigerant sale, the employee must verify purchaser eligibility according to company procedure and applicable EPA requirements. - If eligibility cannot be confirmed, the sale must be paused and escalated to the service manager or compliance contact. ### E. Recordkeeping - Certification records must be retained in the employee compliance file for the period required by law or company record retention rules. - Access to records must be limited to authorized personnel with a legitimate business need.

Roles & Responsibilities

• - **Employees / Technicians**: Maintain valid certification when required, provide proof upon request, and notify management if certification expires or is lost. - **Service Managers**: Verify certification before assigning MVAC work and ensure only qualified employees are scheduled for covered tasks. - **Parts / Sales Staff**: Confirm refrigerant sales eligibility before completing transactions. - **HR / Compliance**: Maintain records, support policy acknowledgements, and coordinate audits or corrective actions. - **Policy holder**: Owns the policy, approves updates, and ensures implementation across affected locations.

Compliance, Corrective Action, and Discipline

• Failure to comply with this policy may result in corrective action up to and including removal from MVAC duties, retraining, a documented warning, placement on a PIP where performance issues are involved, or termination of employment, depending on the severity of the violation and applicable law. If a certification lapse is identified, the employee may be temporarily removed from covered duties until proof of certification is provided. Managers must consult HR or Compliance before issuing discipline to ensure consistent application and to avoid interference with protected concerted activity under NLRA Section 7 or any other protected rights.

Review and Revision

• This policy will be reviewed at least annually and updated as needed to reflect changes in EPA requirements, the Clean Air Act, company operations, or state-specific overlays. Any revisions must be approved by the policy holder and communicated to affected employees before the effective date of the change.