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Frequently Asked Questions About Ozone Depleting Substances (ODS) in Ontario

OZONE DEPLETION PREVENTION (ODP) CARDS

What is required for the purchase and/or handling of refrigerants in Ontario? What is an Ozone Depletion Prevention (ODP) card?

An Ozone Depletion Prevention (ODP) card is required to purchase and handle refrigerants in Ontario. An ODP card is a certificate indicating that the holder has successfully completed an environmental awareness training course to the satisfaction of the Ministry of Environment and Energy.

Is an ODP card a license to service air-conditioning equipment?

No. While the ODP card allows its holder to purchase and handle refrigerants, it is not an indication of the holder’s technical qualifications or ability to service equipment. Technical certification or licensing may be required under other legislation.

What type of qualifications are needed to service air-conditioning equipment?

Various technical qualifications may be needed in addition to the ODP Card. For example, the Ministry of Training, Colleges and Universities has developed the voluntary trade of Appliance Service Technicians, which also covers work on domestic appliances and window-mounted units. Also, in order to service anything larger than a single-phase, hermetically sealed, domestic self-contained unit with a factory mass-produced system, precharged with refrigerant, (e.g., central AC system), you need to possess a certificate of qualification as a Refrigeration and Air-Conditioning Mechanic from the Ministry of Training, Colleges and Universities.

What happens to cards that expired June 30, 2001?

All ODP cards that were issued before June 30, 2001 have been extended. As of July 1, 2001, depending on your last name, your card expires:

Last Name	Date by which you must recertify your ODP Card
A-G	December 31, 2002
H-P	December 31, 2003
Q-Z	December 31, 2004

Before your card expires, you must write a recertification examination. Upon successful completion of this test, you will be issued a card that is valid for three years.

It is expected that you will receive further information about the recertification process approximately a year before your card expires.

If you received your initial ODP Card training and certification after June 30, 2001, you will be given an ODP Card that expires 3 years after it was issued.

Where can I receive training for an ODP Card?

If you want information on where and when you can enroll in an ODP course please contact the Heating, Refrigeration and Air Conditioning Institute (HRAI) at (905) 602-4700 or at 1-800-267-2231 or visit their website at www.hrai.ca.

I lost my ODP card. How do I replace it?

Contact the Heating Refrigeration and Air Conditioning Institute (HRAI) at (905) 602-4700 or 1-800-267-2231. You can also fax the HRAI a letter requesting replacement of the card with your name, address, ODP number and credit card information at (905) 602-1197. There is a cost for a replacement card.

Does a member of a certified trade still need to have an ODP card?

Yes. The Refrigerants Regulation (O.Reg 189/94) requires that all persons who purchase and handle refrigerants have an ODP Card.

Are out-of-province ODP cards valid in Ontario?

No. An Ontario ODP card is required to purchase and handle refrigerants in Ontario.

People who hold cards issued by other provinces should contact HRAI (905-602-4700 or 1-800-267-2231) for information on obtaining an Ontario card.

Other Changes to the Refrigerants Regulation

What other changes have been made to the Refrigerants Regulation that will affect my business?

In addition to changes to the technician certification program, the Ministry of Environment and Energy has made changes to enhance the enforceability of the regulation.

The ministry has:

1. introduced technical standards of practice in the regulation, set out in the Environmental Code of Practice for Elimination of Fluorocarbon Emissions from Refrigeration and Air Conditioning Systems (this document can be obtained from Environment Canada - http://www.ec.gc.ca/ozone/DOCs/SandS/RAC/EN/cop/fluoro_cop.pdf ). For example, a leak test must now be performed in accordance with the code.
2. introduced record-keeping requirements for those handling refrigerants
3. required the reporting of refrigerant releases of 100 kg or more to the ministry’s Spills Action Centre (1-800-268-6060)
4. prohibited the refill of mobile air conditioners with chlorofluorocarbons after January 1, 2002

The ministry has also made some administrative changes to the refrigerants Regulation. The ministry:

• removed out-dated provisions
• added two new definitions (refrigerant and mobile air conditioner)
• clarified the definition of wholesaler to make it clear that anyone who purchases refrigerants for the purposes of resale must keep records as required under section 14.

What kind of information is required under the new ‘records of use’ requirement in the refrigerants Regulation?

All technicians who hold ODP cards are now required to keep records of use. These records must contain:

• All amounts and types of refrigerant purchased or obtained (if you do not buy it yourself) for the purpose of servicing or testing equipment.
• The amount of and explanation for any discharge of a refrigerant, whether or not it occurs in the course of servicing or testing equipment.
• The date of any work done servicing or testing equipment, the name of the company doing the work and the name of the individual doing the work.
• A description of the work done, the amount and type of refrigerant used in the work, the type of refrigerant recaptured in the course of the work and an estimate of the amount of refrigerant recaptured in the course of the work.

These records would be kept by each technician for a minimum of 2 years and must be made available to ministry staff upon request.

 

MOBILE AIR-CONDITIONING

Use of CFC refrigerants

Can I still use freon 12 in my vehicle’s air-conditioner?

After January 1, 2002, no person shall refill an air-conditioning unit of a motor vehicle with any refrigerant containing chlorofluorocarbons (CFCs including freon or R-12). This measure is a refill ban, not a use ban. This means that when refrigerant needs to be added to your system (usually because of a leak or a repair), you have to convert your air-conditioner to run on alternative, more environmentally friendly refrigerant. Alternatively, you may be able to discontinue use or have your air conditioning system removed from your vehicle.

What’s involved if I choose to convert my car’s air conditioner?

Conversion is expected to cost the average Ontario motorist around $320, or approximately the same as repairing the leak and refilling it with the original refrigerant. Since the price for CFC refrigerants is increasing, this conversion is cost-effective and will pay off in the long run.

How do I find out what type of refrigerant is being used in my car?

Vehicles manufactured before the end of 1995 may have air-conditioning units that contain a CFC-based (chlorofluorocarbon-based) refrigerant. A label under the hood or inside the driver’s door should identify the refrigerant used.

Service Practices for Mobile Air Conditioners

Can a vehicle’s air conditioning (AC) system be topped up with refrigerant because the AC is not cold enough?

No. refrigerant must not be added to any vehicle that may be leaking. A test must first be done to find out if there is a leak in the AC system. Once a leak test is performed, the system must be tagged with the results of the test, including:

1. the date of the test,

2. the name of the person who conducted the leak test,

3. the ODP number and expiry date appearing on the person’s ODP card,

4. the results of the test, and

5. if there is a leak in the equipment, a statement that no refrigerant shall be added to the equipment until the leak is repaired.

Furthermore, after January 1, 2002, no person shall refill an air-conditioning unit of a motor vehicle with refrigerants containing chlorofluorocarbons (CFCs).

Is there a standard for the type of leak test that needs to be performed before a system can be tagged as not having a leak?

Leak tests are to be performed in accordance with the practices set out in the Environmental Code of Practice for Elimination of Fluorocarbon Emissions from Refrigeration and Air Conditioning Systems, which is available from Environment Canada (http://www2.ec.gc.ca/ozone/refcode.htm).

Can a refrigerant be used during a test?

Yes. Appropriately qualified people certified under s.21 of O. R.189/94 can use refrigerants while performing a leak test but they must follow the rules of the Society of Automobile Engineers (SAE) [Standard J 1628, Technician procedure for using electronic refrigerant leak detectors for service in mobile air conditioning systems and Standard J 1627, Rating criteria for electronic refrigerant leak detectors]. Copies can be purchased on the SAE Web site (http://www.sae.org/), by telephone at (724) 776-4841 or by faxing them at (724) 776-5760.

However, it is important to note that CFC-based refrigerants (e.g., R-12) cannot be used to refill mobile air conditioners after January 1, 2002.

Where do the leak test tags go?

A new tag is to be attached to the AC system after each leak test. If all the leaks in the system are repaired, a new tag should be put on the system indicating that there are no leaks. The tag has to be visible to any mechanic who might be working on the system in the future. The tag can be placed on the inside of the driver’s side door frame or on any part of the AC system (compressor or hose). Old tags can then be removed. Old tags can be removed only if new tags are going to be placed on the system.

What happens if no leak is found?

If no leak is found, then refrigerant may be added to the system after it has been tagged as having no leaks. However, it is important to note that CFC-based refrigerants (e.g., R-12) cannot be used to refill mobile air conditioners after January 1, 2002.

Where are the tags available for purchase?

Tags can be purchased from most companies that sell business forms. Some associations have also developed tags that comply with the regulations. Tags must contain the appropriate information outlined in the regulation.

Must the mechanic evacuate the remaining refrigerant from the system if a leak is found in a vehicle’s AC system ?

No. The garage may only extract the refrigerant which it may have injected into the system to perform the leak test. The owner of the vehicle owns the refrigerant and must decide when and where to repair the leak. A mechanic should not remove it without the permission of the vehicle owner.

If the refrigerant is removed without this permission, the vehicle owner may only recover that refrigerant if s/he produces a certified refrigerant container in which to transport the refrigerant. Alternatively, if the leak in the AC system is fixed and the refrigerant is non-ozone-depleting, the system can then be recharged with the refrigerant that was removed. Owners should be aware that after January 1, 2002, no person shall refill an air-conditioning unit of a motor vehicle with any refrigerant containing chlorofluorocarbons (CFCs).

Can a garage be fined for leaving refrigerant in an AC system which it knows is leaking?

No. Once a garage has informed the owner of a vehicle that there is a leak in the AC system responsibility is transferred to the owner. Owners can decide to leave the repair shop with the car and any refrigerant that was in the system when it came in. Under the law, the owner is then knowingly venting and will have to have the AC fixed before any more refrigerant can be added. Regardless, a tag must be placed on the car with the results of the test.

What is the vehicle owner’s liability for a leaking AC system?

Permitting the discharge of a refrigerant into the natural environment is illegal in Ontario. Once the owner of an AC system is made aware his/her system is leaking, the owner is then considered to be permitting the discharge of a refrigerant into the natural environment.

What rules and regulations govern the testing of containers used to store refrigerant evacuated from automotive ACs?

Transport Canada regulates the containers in which refrigerant gases are stored according to the Canadian Standards Association (CSA) B339, s.24.2.4, s. 24.2.5 and s.24.2.9. Normal pressure vessels must be re-tested every ten years but since used refrigerants are corrosive, pressure vessels storing them must be tested every five years. Testing can be done at any Transport Canada approved testing facility. For more information, contact Transport Canada at (416) 973-9820.

To whom do I report illegal freon top-ups and suspicious servicing? To whom do I report non-certified AC repairmen?

Any suspicious AC servicing should be reported to your district office of the Ministry of Environment and Energy or the 24 hour Pollution Hotline at 1-866-MOE-TIPS (1-866-663-8477).

I have seen ads for air conditioner sealants (i.e., "stop-leak" products) - are these products legal to use in Ontario?

These products are designed to seal minor holes as refrigerant leaks out. The use of this product as a preventative maintenance practice (i.e., adding this product into the system after it has been certified as leak-free) is legal in Ontario. The use of this product as a repair method for a leaking air conditioner is not legal in Ontario if it requires the addition of refrigerant into the system without performing a leak test first.

 

ALTERNATIVE refrigerantS

Are there such things as satisfactory top-up refrigerants?

Currently, the Ministry of Environment and Energy does not offer a recommendation regarding top-up refrigerants. Contact your car dealer to see whether or not using a top-up refrigerant might invalidate your car warranty.

Which alternative refrigerants to ODS are legal for use in Ontario?

Currently, all suitable alternatives to ODS are legal for use as refrigerants in Ontario. The Ministry of Environment and Energy does not currently endorse, approve or disapprove of any alternative refrigerants. It is the responsibility of those seeking alternatives to determine whether a particular product is appropriate for their process or use (see below).

Which alternative refrigerants are suitable for uses in different applications?

No Canadian authority currently provides formal advice about the acceptability of alternatives. However, the US EPA provides technical evaluations of substitute, drop in or top-up refrigerants. Its evaluations are available on the Significant New Alternative Policy Web site at www.epa.gov/ozone/title6/snap. Environment Canada has an Ozone-Depleting Substances Alternatives and Suppliers List which also provides information and has recently established a panel which will be reviewing alternatives and making recommendations. This list can be obtained from their Web site at www.ec.gc.ca/ozone/archive/altlist/altlist.htm.

In Canada, the Federal-Provincial Working Group on Controls Harmonization (Ozone Depleting Substances) is conducting on-going discussions on this matter and does not recommend the use of hydrocarbon-based refrigerant alternatives in systems not designed to contain flammable refrigerants.

 

OZONE-DEPLETING SUBSTANCES (ODS) REGULATIONS

What regulations control the use of ODS in Ontario?

There are currently five regulations under Ontario’s Environmental Protection Act (see Part VI of the act) which deal directly with ozone depleting substances:

Reg. 356: Ozone Depleting Substances Regulation in General (pressurized containers, flexible foam, rigid insulation foam)

O. Reg. 189/94: refrigerants Regulation.

O. Reg. 413/94: Halon Fire Extinguishing Equipment.

O. Reg. 717/94: Solvents Regulation.

O. Reg. 718/94: Sterilants Regulation.

Sections 30 to 42 of the General Waste Management Regulation (Reg. 347) deal with the disposal of mobile and stationary refrigerant waste.

These regulations are available in the "Treaties, Statutes and Regulations" (/envision/Ozone/law.html) section of this Web site.

In certain industries, there are both federal and provincial regulations. Which take precedence?

In the case of ODS regulations, both federal and provincial regulations need to be implemented.

Solvents

Has Ontario banned the use of Class II solvents in Ontario?

The Solvents Regulation (O.Reg. 717/94) was amended to defer the phase-out of a single Class II solvent (known as AK 225) until December 31, 2008. All other Class II solvents were banned on July 1, 2001. The Ministry of Environment and Energy does not believe that there are suitable replacements for this solvent and is providing users an appropriate period of time to find technically and environmentally acceptable alternatives. AK 225 users must also submit annual reports documenting their efforts to reduce solvent use.

What information do I need to include in my annual report?

Companies who use AK 225 must submit annual reports documenting:

• location and volume used;
• measures taken to reduce emissions; and
• a review of available emission-reduction technologies

These reports are due on February 15 of each year.