CFC/HCFC Requirements & Enforcement Issues. Don Gansert Managing Consultant November 20, 2008. trinityconsultants.com. 40 CFR Part 82. Subpart A – Production & Consumption Controls Subpart B – Servicing of Motor Vehicle Air Conditioners
November 20, 2008
Most facilities have the necessary certifications or use contractors
Common problem areas!
Non-compliance with stratospheric ozone protection requirements is low-hanging fruit for USEPA and state agencies. $3.6 Billion in penalties for Part 82 in 1999 alone.
*If industrial process shutdown needed to make repair, then have120-day repair window