EPA Section 608 certification comes in four types, and the one you need depends on the equipment you work on. The rules sit in 40 CFR 82.161, with the exam standard in Appendix D to Subpart F.
Who must be certified
Anyone who could reasonably be expected to violate the integrity of the refrigerant circuit while maintaining, servicing, repairing or disposing of an appliance must pass an exam from an EPA-approved certification program (40 CFR 82.161(a)(1)). Since January 1, 2018, this covers appliances containing class I or class II refrigerants and non-exempt substitute refrigerants (40 CFR 82.161, introductory text).
Apprentices are exempt only while they are closely and continually supervised by a certified technician. Both the apprentice and the supervisor are responsible for compliance (40 CFR 82.161(a)(2)).
The four certification types
- Type I: required to maintain, service or repair small appliances (40 CFR 82.161(a)(1)(i)). A small appliance is fully manufactured, charged and hermetically sealed in a factory with five pounds or less of refrigerant, such as a household refrigerator or a window air conditioner (40 CFR 82.152).
- Type II: required for medium-, high- and very high-pressure appliances, other than small appliances, MVACs and MVAC-like appliances (40 CFR 82.161(a)(1)(ii)). By definition, high-pressure means a refrigerant with a liquid saturation pressure between 170 and 355 psia at 104 F; very high-pressure means above 355 psia or a critical temperature below 104 F; medium-pressure falls between 45 and 170 psia (40 CFR 82.152).
- Type III: required for low-pressure appliances (40 CFR 82.161(a)(1)(iii)), meaning a refrigerant with a liquid saturation pressure below 45 psia at 104 F (40 CFR 82.152).
- Universal: required to work on all of the appliances above, so it covers Types I, II and III (40 CFR 82.161(a)(1)(iv)).
Note the word disposal. Persons who dispose of small appliances, MVACs and MVAC-like appliances do not need to be certified (40 CFR 82.161(a)(1)(vii)).
What about Core?
Core is not a separate certificate in the rule. It is the general section of each exam. Every test must include at least 25 questions from the core group and at least 25 from each relevant technical group (40 CFR 82.161(c)). Under Appendix D, the general group covers the environmental impact of CFCs, HCFCs and substitute refrigerants, laws and regulations, and the changing industry outlook. The sector-specific group covers leak detection, recovery techniques, safety, shipping and disposal.
A Type I, II or III test therefore has 25 general questions and 25 sector-specific ones. A Universal test has 25 general questions and 75 sector-specific ones, 25 from each of the three sector areas (Appendix D to 40 CFR part 82, subpart F, section d). The certificate you earn is the type, and passing the general section is part of earning it.
Auto air conditioning is separate
Technicians who service motor vehicle air conditioners (MVACs) for consideration must be certified under 40 CFR part 82, subpart B, not under Section 608 (40 CFR 82.161(a)(1)(vi)). For MVAC-like appliances, a technician may hold a Type II certification or the subpart B certification (40 CFR 82.161(a)(1)(v)).
Does certification expire?
The rule sets no expiration date. EPA only reserves the right to require recertification at a future date by publishing a notice in the Federal Register (40 CFR 82.161(a)(5)). Certification can, however, be revoked or suspended if a technician fails to demonstrate proper recovery procedures or violates the subpart. A technician whose certificate is revoked must recertify before servicing appliances again (40 CFR 82.161(a)(3)).
Proof and records
- Wallet card: the certifying program must issue a standard wallet-sized identification card within 30 days of the test. It shows the program name, the person's name, the type of certification and a unique number that is not a Social Security number (Appendix D, section f).
- Keep your certificate: a technician must keep a copy of the certificate at the place of business and maintain it until three years after no longer operating as a technician (40 CFR 82.161(a)(4)).
- Buying refrigerant: restricted refrigerant may be sold to a certified technician, or to a buyer who employs one and provides proof to the seller. Sellers must keep that documentation and invoices for three years (40 CFR 82.154(c)(1) and (c)(3)).
- Program records: approved programs keep test records, including names, scores and test dates and locations, indefinitely unless transferred (Appendix D, section g). Since 2018 they must also publish an online list of technicians they have certified, with an opt-out (40 CFR 82.161(b)(6)).
Test-taking details also matter. The exams for Type II, Type III and Universal are closed-book, and proctors must check photo identification (Appendix D, section b). A program may give the test orally if the applicant asks in writing at least 30 days ahead (40 CFR 82.161(b)(3)).
Choosing a type
If you only service small appliances as defined above, Type I fits; if your work is limited to medium-, high- or very high-pressure equipment, Type II fits. If you work on low-pressure appliances, you need Type III. If your job could take you across all three, Universal avoids having to test again later.
Practice EPA 608 exam questions with explanations and timed mock exams.