LeakLedgerWhy they matter
Under 40 CFR 84.106 a repair only counts once it is documented by both an initial and a follow-up verification test (84.106(d)(2)). After that, leak inspections continue until the leak rate stays under the threshold. Miss a test and the repair is not documented, even if the leak is fixed.
Initial verification test
It shows that the repairs held. Deadline: within 30 days of the appliance exceeding the leak rate threshold, or 120 days if an industrial process shutdown is needed (84.106(e)(1)).
- Repair without opening the system: test after the repair and before any refrigerant is added.
- Repair that needed evacuation of the appliance or part of it: test before adding refrigerant back.
- If the test fails, you can repair and retest as many times as needed inside the same window.
No single method is required. EPA's definitions list soap bubbles, electronic or ultrasonic leak detectors, pressure or vacuum tests, fluorescent dye and black light, infrared tests and handheld gas detectors as examples (84.102). Record which type you used.
Follow-up verification test
It shows the leaks are still repaired once the system runs. Deadline: within 10 days of the successful initial test, or within 10 days of the appliance reaching normal operating conditions if it was evacuated for the repair (84.106(e)(2)). If it is unsafe or impossible to test at normal operating conditions, test before the system returns to them where practicable.
| Step | Deadline | Rule |
|---|---|---|
| Repair the leaks | 30 days from the addition that exceeded (120 with IPR shutdown) | 84.106(d) |
| Initial verification test | Same 30 or 120 day window, before refrigerant is added | 84.106(e)(1) |
| Follow-up verification test | 10 days after the successful initial test (or after normal operation resumes) | 84.106(e)(2) |
| First leak inspection | Counted from the successful follow-up test | 84.106(g)(1) |
Leak inspections after the repair
An appliance that went over the threshold gets periodic leak inspections, counted from the date of the successful follow-up verification test (84.106(g)(1)):
| Appliance | How often | Until |
|---|---|---|
| Commercial refrigeration or IPR, 500 lb or more | Every 3 months | Leak rate calculations show no exceedance for 4 quarters in a row |
| Commercial refrigeration or IPR, 15 to 499 lb | Once a year | No exceedance for 1 year |
| Comfort cooling and all other appliances | Once a year | No exceedance for 1 year |
- Inspections must be done by a certified technician, using the method the technician finds appropriate (84.106(g)(2)).
- All visible and accessible components are inspected. Insulated, iced, underground or in-wall parts, parts that need someone more than two meters above a support surface, and parts site personnel judge unsafe to inspect are excepted (84.106(g)(3)).
- Not required on appliances continuously monitored by an automatic leak detection system that is audited or calibrated every year (84.106(g)(4)).
When the repair is considered successful
The next leak rate calculation must come in under the threshold. A repair is also presumed successful if, in the 12 months after a successful follow-up test, there is no further refrigerant addition, or the required leak inspections find no leaks (84.106(d)(2)). If the appliance is still over the threshold after repairs and tests, a retrofit or retirement plan is due within 30 days (84.106(h)(1)).
What to write down
- Each verification test: location of the appliance, date(s), location of every repaired leak tested, type of test, result (84.106(l)(7)).
- Each leak inspection: date, method(s), location of each leak found, and a certification that all visible and accessible parts were inspected (84.106(l)(5)).
The technician gives both to the owner or operator at the end of the service. Full list in refrigerant service records.
Written from the text of 40 CFR 84.102 and 84.106 on eCFR (September 2026) and the EPA leak repair fact sheet (January 2026). Section 608 (82.157) has matching test and inspection rules for CFC and HCFC appliances of 50 lb or more. Recordkeeping aid, not legal advice.