Background
Some man-made chemicals impair the ability of Earth’s ozone layer to filter out ultraviolet (UV) radiation. The regulatory term for these compounds is “ozone-depleting compounds” (ODCs). This group of chemicals consists of chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), Halons, and some chlorinated solvents. Most refrigeration systems, from minifridges to district cooling chillers and automobile air conditioners, use ODCs. Halon is a common gaseous agent in fire extinguishing systems. Some aerosol cans use CFCs or HCFCs as propellants.
The 1990 Clean Air Act Amendments phase out manufacture of some ODCs. The primary targets of the cutback are CFCs, Halon, carbon tetrachloride, and methyl chloroform. The goal of the program is to prevent releases of ODCs to the atmosphere. However, this is a different issue from low-atmosphere ozone, which is a pollutant.
In addition to restricting the production of these materials, EPA’s Protection of Stratospheric Ozone Program (in 40 CFR 82) includes requirements for reporting, tracking, and registration.
Key Concepts
Ozone-Depleting Compound
Any number of chemicals may deplete the ozone layer, which, collectively, are ODCs. Facilities have to manage other materials that contain ODCs, such as used compressor oil, under the same rules as ODCs.
CFC Compressor Oil
Resource Conservation and Recovery Act (RCRA) requires that facilities that generate oil with more than 1,000 parts of chlorine per million, by weight, manage that oil as a hazardous waste by default. EPA’s used oil regulations call this the “rebuttable presumption for used oil.” By documenting that the chlorine comes from CFCs or HCFCs, facilities can elect to manage the waste compressor oil under ODC regulations. See Resource Conservation Recovery Act — Used Oil.
Does this apply to my campus?
If your campus uses CFCs, HCFCs, Halon, or other ODCs in any quantity, the ODC regulations apply to you.
What do I have to do?
Every step of the production, distribution, sale, use, reclamation, and disposal process is covered by these regulations. Your use and disposal of CFCs, HCFCs, Halon, and other ODCs (including CFC compressor oil) must follow these basic requirements:
- Do not dispose of existing ODC inventories by venting them to atmosphere, regardless of quantity;
- label all containers that hold ODCs;
- ensure that all service of ODC-containing equipment is performed by trained and certified people;
- ensure that ODCs are reclaimed by trained and certified people;
- use EPA-registered and approved equipment to recover ODCs from all appliances and equipment before disposal or service;
- use specific techniques to remove and recover all ODCs;
- repair all leaking equipment that uses ODCs;
- buy ODCs only from licensed and certified distributors;
- maintain an ODC inventory; and
- dispose of ODCs only through licensed and certified distributors.
Maintenance of records creates evidence of compliance. There are several commercial software systems that facilitate record maintenance. Note that repairing leaks in ODC equipment within 30 days of discovery can reduce or eliminate reporting requirements.