By Hao Nguyen, Esq.
Senior Product and Regulatory Counsel
If you have read enough articles I’ve written in the past (both at ComplyAuto and the now-defunct Auto Advisory Services) you know by now that I love jokes, but jokes about air conditioners? Not a fan.
Summer is upon us and the signs are everywhere: the kids are at home most of the day, you’re thinking about what to bring to the barbecue, and “What do you mean Joey Chestnut is banned!?” Another telltale sign of summer is a family road trip. In fact, 75% of American travelers surveyed by “The Vacationer” said that they plan to drive to their destinations this season, which means more visits to repair facilities across the country. And, with temperatures already on the rise, you can bet that your service department is in for a (cold) treat in air conditioning (AC) repairs! With the possible influx of this repair service, it is a good time to remind you that these specific types of repairs are overseen by the Environmental Protection Agency (EPA). The EPA requires that any technicians who work on mobile air conditioning (MVAC) systems must have an EPA-certified certificate. We’re going to discuss what this certification is about, what the certification entails, and, most importantly, what your dealership can do today to make sure you’re compliant.
Section 609 of the Clean Air Act
The Clean Air Act is a federal law that regulates air emissions from stationary and mobile sources. It was enacted to protect the public health and welfare of Americans by reducing emissions of harmful pollutants into the atmosphere. With over 296M vehicles on our roads today, MVACs are a significant source of these air emissions, so the EPA regulates repair services on these systems. Specifically, the EPA requires that any person who repairs or services MVACs for “consideration” (i.e. a fancy way to say payment) must be trained and certified under Section 609 of the Clean Air Act.
EPA Recognized Programs
The training program, and the subsequent technician certification, must be recognized and certified by the EPA. ComplyAuto has gone through the certification process with the EPA. As with most things involving the federal government, the process was rigorous, comprehensive, and time-consuming, but we achieved EPA certification and are now able to provide our dealer clients with a program that they can use for their technicians.
This complimentary training and certification program is available to all of our existing ComplyAuto Safety dealer clients, a savings of up to $50 per technician.
Contents of the Program
Contents of the ProgramThe program teaches technicians the basics of the environment, the chemicals involved in MVACs, their effects on the atmosphere, and the safe handling of the gas cylinders in which the chemicals are transported. As a preview, here is a quick look at the contents of our certified training program:
- Environmental and Health Consequences
- Technological Advancements
- Standards for Service and Repair of MVACs
- Labeling and Disposal Requirements
- Recordkeeping and Sales Restrictions
- Posting Requirements
What Dealers Should Do Today
Dealers should review their technicians’ certifications to make sure they are each certified to work on MVACs before completing any of these repairs or services on customer vehicles. If they are not certified, or you cannot find their certificate, we highly recommend that you enroll them in our training and certification program. Again, all existing ComplyAuto Safety clients have complimentary access.
Need Help?
ComplyAuto has built a solution to help dealers with all of their OSHA and EPA compliance goals, including MVAC technician training. It is also backed by the industry’s only $1M compliance guarantee. Please contact us at info@complyauto.com for more information.