Run: Refrigerant Sales – EPA 609/608 Certification Verification SOP

The Counter Associate asks the customer which refrigerant they wish to purchase and confirms the container size. - **EPA Section 609** covers **motor vehicle air conditioning (MVAC) refrigerants** (e.g., R-134a, R-1234yf) in containers **above 2 lbs**. - **EPA Section 608** covers **stationary refrigeration and A/C refrigerants** (e.g., R-410A, R-22, R-404A) in any quantity sold to end-users. If the refrigerant is sold in containers of **2 lbs or less** (small cans, consumer-grade), certification is **not required** — proceed to POS sale without further verification steps.

The Counter Associate politely informs the customer of the legal requirement and requests their EPA technician certification card: > *"Federal law requires us to verify your EPA technician certification before we can sell this refrigerant. May I please see your certification card?"* Acceptable credentials: - EPA Section 609 certification card (MVAC) - EPA Section 608 certification card (Type I, II, III, or Universal) If the customer does not have a physical card, ask if they have a digital copy or a certification number they can provide for lookup.

The Counter Associate examines the certification card and verifies ALL of the following fields are present and legible: 1. **Technician's full name** — matches the person standing at the counter 2. **Certification type** — Section 609 (MVAC) or Section 608 (Type I / II / III / Universal) 3. **Certifying organization name** — must be an EPA-approved testing organization (refer to the internal EPA-approved certifying organizations reference list) 4. **Certification number** — unique identifier printed on the card 5. **No expiration date required** — EPA 608/609 certifications do not expire; however, verify the card does not display an explicit expiration date that has passed Use a magnifying loupe if card text is small or worn. Compare the name on the card to a government-issued photo ID if any doubt exists about identity.

The Counter Associate evaluates the inspection results from Step 3 and determines the appropriate path.

The Counter Associate enters the following data fields into the refrigerant sales log (paper or electronic) **before** releasing the product: | Field | Required Entry | |---|---| | Transaction date | MM/DD/YYYY | | Customer full name | As printed on certification card | | Certification type | 609-MVAC / 608-Type I / 608-Type II / 608-Type III / 608-Universal | | Certification number | As printed on card | | Certifying organization | As printed on card | | Refrigerant type | e.g., R-134a, R-410A, R-22 | | Quantity sold | Weight (lbs) or number of cylinders | | Container size | e.g., 30 lb cylinder, 25 lb jug | | Counter Associate name/ID | Employee completing the transaction | > **Regulatory basis:** EPA requires retailers to maintain records of refrigerant sales for a minimum of **three (3) years** (40 CFR Part 82, Subpart F).

The Counter Associate performs a self-check by reading back each field in the log entry and confirming no field is blank or illegible. Checklist: - [ ] Transaction date entered - [ ] Customer name matches certification card exactly - [ ] Certification type recorded - [ ] Certification number recorded - [ ] Certifying organization recorded - [ ] Refrigerant type recorded - [ ] Quantity and container size recorded - [ ] Associate name/ID recorded If any field is missing, complete it before proceeding.

The Counter Associate: 1. Processes payment through the POS terminal. 2. Prints or emails the sales receipt to the customer. 3. Retrieves the refrigerant cylinder(s) from secured storage and hands them to the customer or places them on the pick-up counter. 4. Reminds the customer of safe handling requirements: *"Please transport cylinders upright and secured. Keep away from heat sources."* 5. Returns the customer's certification card immediately after recording.

The Counter Associate declines the sale and escalates to the Store Manager when: - The certification card is missing, expired, or from a non-EPA-approved organization - The name on the card does not match the customer's identity - The customer refuses to present a card or certification number - The card appears altered or counterfeit **Script for declining:** > *"I'm sorry, but federal law (40 CFR Part 82) requires us to verify EPA technician certification before selling this refrigerant. Without a valid certification card, I'm unable to complete this sale. Please contact an EPA-approved testing organization to obtain certification."* **Escalation action:** Notify the Store Manager immediately. The Manager documents the declined transaction in the sales log with the notation "SALE DECLINED – CERTIFICATION NOT VERIFIED" and the date/time. Do NOT release any refrigerant product.

The Counter Associate (or designated records custodian) ensures the completed log entry is filed in the refrigerant sales records system: 1. **Paper logs:** Place the completed log sheet in the current-month binder stored in the locked records cabinet. Label the binder with the month/year. 2. **Electronic logs:** Confirm the entry is saved and auto-backed-up in the compliance records folder. Do not delete or modify entries after saving. 3. **Retention period:** All refrigerant sales records must be retained for a minimum of **three (3) years** from the date of sale, per EPA Section 608 recordkeeping requirements. 4. **Audit readiness:** Records must be available for EPA inspection upon request. Confirm the filing location is known to the Store Manager. This step applies to both completed sales and declined-sale log entries.