Are You in the Know on the Refrigerant Rules?

On January 1, 2026 facilities with refrigeration appliances, including air conditioners, refrigerators, chillers, and freezers, with a full charge of 15 pounds or more of refrigerant may be subject to new leak repair requirements under 40 CFR Part 84, Subpart C (Management of Regulated Substances). Limitations on types of refrigerants that may be used in new installations, existing system rebuild restrictions, and new labeling requirements will be rolling out in the coming years under 40 CFR Part 84, Subpart B (Restrictions on the Use of Hydrofluorocarbons). Additionally, fire suppression equipment containing refrigerants will be subject to new regulations.

What does it mean?

Refrigeration appliances that have a full charge of 15 pounds or more and contain a regulated substance or a substitute for a regulated substance with a global warming potential (GWP) great than 53 will be subject to leak repair provisions. Regulated substances and substitutes with a GWP of over 53 include hydrofluorocarbons (HFC) like R-134a and blends of HFCs like R-410A or R-407C.

Facilities will need to identify, inventory, and categorize existing appliances. Certified technicians will be needed to conduct repairs and maintenance on regulated appliances.

Appliances with 15 pounds or more refrigerant at facilities will be subject to:

• Leak rate calculations and tracking, including chronic leak determinations,
• Leak repair timelines,
• Initial verification testing and follow-up testing after leaks,
• Routine leak inspections,
• Retrofit and retirement planning, and
• Recordkeeping and reporting.

Prior to January 1, 2026, facilities will need to review plans for new installations based on the type of refrigerant and purpose of the appliance. Installation deadlines are in place for new light commercial air-conditioning and heat pump systems, comfort cooling systems, cold storage warehouse systems, industrial process refrigeration systems, and chillers. Appliance rebuilds will need to be scrutinized for potentially triggering being classified as a new installation and face limits on type of refrigerant used.

Starting January 1, 2026 facilities will need to utilize trained fire suppression technicians for installations, maintenance, repairs, and disposal of fire suppression equipment that contain refrigerant. Prohibitions on venting or release of refrigerants, system testing and documentation requirements, and recycling and recovery equipment standards will also go into effect on January 1, 2026.

What’s Next?

Do you need support understanding compliance requirements, updating your refrigerant management program, or preparing training? ALL4 provides support for refrigerant management and compliance, including:

• Inventory development,
• Leak rate tracking and chronic leak reporting,
• Retrofit and retirement plan development,
• Project planning and purchasing guidance for future installations and rebuilds,
• Refrigerant Management Plans,
• Employee awareness training, and
• Refrigerant program compliance assessments.

If you have questions about how Part 84, Subpart B or Subpart C could affect your facility compliance, or what your next steps should be, please reach out to me at mdabrowski@all4inc.com. ALL4 continues to monitor all updates published by the U.S. Environmental Protection Agency (EPA) on this topic, and we are here to answer your questions and assist your facility with any aspects of environmental compliance.

ALL4 is Headed to ASSP Safety 2025 in Orlando, FL!

We are excited to announce that ALL4 will attend the ASSP Safety 2025 Conference and Expo on July 22-24, 2025 in Orlando, Florida! As one of the leading events for workplace safety professionals, this conference brings together thousands of Environmental, Health, and Safety (EHS) experts, innovators, and practitioners from around the world — and we are proud to be a part of it.

This year, we will coordinate with several of our safety software partners including Cority, KPA, and Intelex to showcase innovative safety solutions, share best practices, and connect with fellow professionals who are shaping the future of safety across industries.

Unlocking EHS Excellence Through Digital Solutions: How ALL4 Leads the Way

At ALL4 we believe that EHS success is not just about checking compliance boxes. It is about creating sustainable, forward-thinking systems that empower entire organizations. That is why our EHS and Digital Solutions capabilities are designed to work hand-in-hand, providing the programs, systems, data, and confidence to make smarter decisions every day.

ALL4 is proud to be aligned and partnered with some of the best software development platforms in the industry. From robust compliance management systems to intuitive reporting dashboards and custom integrations, our team brings superior experience and deep technical knowledge to every project. We do not just implement software — we design practical, tailored solutions that fit seamlessly into your business operations and maximize value.

If you are attending ASSP’s Safety 2025, we would love to connect with you! Stop by ALL4’s Expo Booth Number 1172 and learn how our EHS and Digital Solutions integration can help you streamline processes, reduce risk, and drive continuous improvement across your organization.

Whether you are attending to discover the newest tools in the industry, earn Continuing Education Units (CEUs), or network with likeminded safety leaders, we would love the opportunity to connect.

Want to Schedule a Meeting in Advance?

Contact us through our website https://www.all4inc.com/contact-us/ or reach out to ALL4’s EHS and Digital Solutions experts that are attending to coordinate a time.

Can’t make it to Orlando? Reach out anytime — we are ready to help you navigate the path to EHS success.

Let’s Make The Workplace Safer—Together

Follow ALL4 on LinkedIn for more updates as we get closer to the event, including our networking events and session announcements. See you in Orlando!

Changes to U.S. EPA PFAS Drinking Water Standards Under the Trump Administration

In April 2024, the United States Environmental Protection Agency (U.S. EPA) finalized Maximum Contaminant Levels (MCL) for five per- and polyfluoroalkyl substances (PFAS): perfluorooctanoic acid (PFOA), perfluorooctanesulfonic acid (PFOS), perfluorohexanesulfonic acid (PFHxS), perfluorononanoic acid (PFNA), and hexafluoropropylene oxide dimer acid (HFPO-DA or GenX), and PFAS mixtures containing at least two or more of PFHxS, PFNA, HFPO-DA, and perfluorobutanesulfonic acid (PFBS) using a Hazard Index to account for the combined and co-occurring levels of these PFAS in drinking water. The following table summarizes each compound or mixture and the MCL for that compound or mixture.

After review, U.S. EPA announced in a press release on May 14, 2025 that the agency will keep the current MCL for PFOA and PFAS. However, U.S. EPA intends to rescind the regulations and reconsider the regulatory determinations for PFHxS, PFNA, HFPO-DA, and the Hazard Index mixture. Further, U.S. EPA intends to extend the PFOA and PFOS MCL compliance deadlines to 2031 and establish a federal exemption framework.

U.S. EPA plans to initiate enhanced outreach to water systems, especially in rural and small communities, through its PFAS OUTreach Initiative (PFAS OUT). This is in response to comments and concerns from rural water systems that there are insufficient resources to monitor and mitigate PFAS in small water systems. U.S. EPA actions are intended to reduce the burden on drinking water systems and the cost of water bills, all while continuing to protect public health and ensure that the agency is following the law in establishing regulations such as these. Look for official changes in the Federal Register in the upcoming weeks.

What does this mean for Industry?

Based on the U.S. EPA press release on April 28, 2025 the agency intends to establish effluent limitation guidelines (ELGs) based on the PFOA and PFOS MCL. Look for additional information in a future 4TR article that will provide a move comprehensive summary of what U.S. EPA intends for PFAS regulation across multiple programs.

As we have seen, the Trump Administration is reviewing multiple programs and rules under U.S. EPA. Expect to see additional guidance and rulemaking in the next several months which will allow for additional comment from the regulated community.

ALL4 will continue to keep you informed on changes and updates to the ever-changing PFAS landscape. If you have any questions regarding PFAS at your facility, please reach out to Kayla Nuschke at knuschke@all4inc.com or Lizzie Smith at lsmith@all4inc.com.