LeakLedgerWho keeps which record
The owner or operator of the appliance keeps the records, for at least three years, on paper or electronically (84.106(l)). The technician's part is to hand over the right paperwork at the end of each job. If you only remember one thing: no record, no proof the leak rate was ever calculated.
- AIM Act, 40 CFR 84.106(l): HFC appliances with a full charge of 15 lb or more.
- Section 608, 40 CFR 82.157(l): CFC and HCFC appliances with 50 lb or more. Same structure, with small differences listed at the end.
The appliance record
Every covered appliance needs a record kept until three years after the appliance is retired (84.106(l)(1)). For existing HFC appliances the full charge had to be determined by January 1, 2026. New appliances get it at installation.
- Owner or operator
- Address where the appliance is located
- Full charge, and the method used to find it
- Date of installation
- Any revision of the full charge, how it was determined and when
The four allowed full charge methods are: the manufacturer's value, a calculation from component sizes, refrigerant density and piping volume, actual measurement of refrigerant added or evacuated, or an established range. If you use a range, write down the range, its midpoint and how you got it (84.106(l)(1)(iv)).
Every service call
Each time an appliance of 15 lb or more is installed, serviced, repaired or disposed of, the owner or operator needs a record with (84.106(l)(2)):
| Field | Example |
|---|---|
| Identity and location of the appliance | Walk-in freezer WIF-2, back of house, 1180 Main St |
| Date of the work | September 12, 2026 |
| Part(s) worked on | Evaporator return bend, row 3 |
| Type of work on each part | Brazed leak, pressure tested |
| Name of the person doing it | Dana Kowalski |
| Amount and type of refrigerant added (or removed at disposal) | 3 lb R-404A |
| Full charge | 62 lb |
| Leak rate and the method used | 23.9%, annualizing |
The leak rate line is not needed for disposal, right after a retrofit, at a new installation, or when the addition is a seasonal variance.
Leak inspections and verification tests
These two records also go from the technician to the owner or operator at the end of the service (84.106(l)(5) and (l)(7)).
- Leak inspection: date, method(s) used, the location of each leak found, and a certification that all visible and accessible parts were inspected.
- Verification test: location of the appliance, date(s) of the test, location of every repaired leak that was tested, type of test, and the result. Keep both the initial and the follow-up test.
When these are required and how fast is covered in verification tests and leak inspections.
Less common records
- Retrofit or retirement plan: signed and dated by an authorized company official and kept at the site (84.106(h)(3), (l)(8)).
- Repair or retrofit extension requests sent to EPA (l)(9).
- Mothballing: the date the appliance was mothballed and the date refrigerant was added again (l)(10).
- Seasonal variance: a statement that you use it, plus the amounts added and removed (l)(12).
- Leak rate method change after acquiring a facility, with the leak rates under both methods (l)(3).
- Reports to EPA, such as a chronic leaker report, and EPA's replies (l)(13).
Section 608 differences
For CFC and HCFC appliances the list in 82.157(l) is the same idea at 50 lb or more. The appliance record has no installation date, there is no method change record, and the contractor's record does not need the full charge or the leak rate.
Written from the text of 40 CFR 84.102, 84.106 and 82.157 on eCFR (September 2026) and the EPA leak repair fact sheet (January 2026). Recordkeeping aid, not legal advice.