The Solo Technician’s Documentation Burden
When you work for a large HVAC company, an office manager or compliance department handles the paperwork. When you are solo, every record-keeping obligation falls directly on you. The EPA does not reduce documentation requirements based on company size. A one-person operation is held to the same standard as a national service chain.
The governing regulations are found in 40 CFR Part 82, Subpart F (Section 608) and the AIM Act Technology Transitions Rule (Subpart C). Together they establish what must be documented, how long records must be kept, and what format is acceptable.
The 13 Categories You Must Document
1. Refrigerant Recovery Events
Record the date, equipment identification, refrigerant type, quantity recovered, recovery machine serial number, and destination of recovered refrigerant (reclaim facility, storage, or destruction).
2. Refrigerant Additions and Charging
Document the date, equipment identification, refrigerant type and quantity added, source cylinder identification, and reason for addition (initial charge, post-repair recharge, or top-off).
3. Leak Detection and Inspections
Record the date, equipment identification, detection method used (electronic, UV dye, soap bubbles, ultrasonic), locations checked, leaks found with severity estimates, and negative results when no leak was located.
4. Leak Rate Calculations
Document the calculated annualized leak rate with formula inputs, full charge value and determination method, whether the applicable threshold was exceeded, and the regulatory framework (Section 608 or Subpart C).
5. Repair Actions
Record the date, specific repair description (component replaced, joint re-brazed, valve repacked), leak location on the system, and parts and materials used.
6. Verification Test Results
Document the date and time, test type (initial or follow-up), test method, result (pass or fail), and any additional actions taken on failure.
7. Refrigerant Disposition and Chain of Custody
Track cylinder identification, refrigerant type and quantity in each cylinder, source, disposition (charged, reclaimed, transferred, destroyed), and transfer documentation with recipient identity and date.
8. Equipment Profiles
Maintain owner and location, equipment type, manufacturer, model and serial numbers, refrigerant type, full charge amount and determination method, regulatory framework, and appliance category.
9. Technician Certification Records
Keep copies of your EPA Section 608 certification card, state or local certifications, and continuing education records.
10. Chronic Leaker Reports
Retain the report submitted to the EPA, submission date and method, and all supporting service records.
11. Repair Extension Requests
Document the extension request, reason, and approved timeline and conditions.
12. Retrofit and Retirement Plans
Keep plan documentation with timeline, recovery records from decommissioning, and final disposition of recovered refrigerant.
13. A2L Safety Compliance
For systems using mildly flammable refrigerants, retain safety checklist completion records, sensor verification documentation, and ventilation confirmation.
Retention Periods
The baseline requirement is 3 years from the date of the service event, with extensions in several situations:
| Record Type | Minimum Retention |
|---|---|
| Standard service records | 3 years |
| Records related to ongoing leak repairs | 3 years after final resolution |
| Chronic leaker reports | 3 years after filing |
| Equipment retirement/disposal records | 3 years after disposal |
| Records under active EPA investigation | Indefinitely, until investigation concludes |
Best practice: Retain all records for at least 5 years. Digital storage costs are negligible, and older records protect you in disputes or delayed investigations.
Format Requirements
The EPA does not mandate a specific format. Paper, spreadsheets, and digital tools are all acceptable if records are:
- Legible and complete: All required fields present and readable
- Organized and retrievable: Locatable within reasonable time during an audit
- Tamper-evident: Digital systems with audit trails are preferred
- Backed up: Loss due to a single hardware failure is not an acceptable excuse
Paper systems fail the backup requirement unless you maintain copies. Digital systems with cloud backup are strongly preferred for solo technicians.
Preparing for an EPA Compliance Audit
Organize Records by Equipment
Auditors investigate compliance at the equipment level. Producing the complete service history for a specific piece of equipment – every addition, recovery, leak test, repair, and verification – is what they need.
Verify Completeness Periodically
Review your records to catch common gaps:
- Missing verification test records after documented repairs
- Incomplete recovery documentation without quantities
- Unsigned or undated service records
- Equipment profiles missing full charge determination method
Know Your Numbers
An auditor may ask you to calculate a leak rate on the spot. Complete records make this straightforward. Incomplete records force you to reconstruct data from memory and invoices.
Common Documentation Mistakes
Recording net amounts instead of gross. If you recover 15 pounds and add 20, record both separately. Logging only the net 5 pounds violates requirements and understates actual handling.
Failing to document negative findings. If you inspected for a suspected leak and found nothing, that inspection must still be recorded. The absence of a finding is itself a record.
Using vague repair descriptions. “Fixed leak” is not adequate. Specify the location (e.g., “suction line Schrader valve at condensing unit”), repair method (“replaced valve core and cap”), and materials used.
Backdating records. Creating records after the fact to fill gaps is a serious compliance risk. If an auditor identifies backdated records, it raises questions about your entire documentation system. If you missed documenting an event, create the record as soon as possible and note it was recorded after the fact.
How FieldPad Enforces Record-Keeping Compliance
FieldPad makes EPA-compliant documentation the natural byproduct of your service workflow:
- Structured compliance logs: Guided forms require all EPA-mandated fields before a record can be saved. You cannot accidentally omit required data.
- All 13 action types supported: From refrigerant recovery to A2L safety checklists, every category is covered.
- Automatic retention enforcement: FieldPad’s ComplianceDeletionGuard prevents deletion of records within their mandatory retention period, routing them to archive instead.
- Equipment-linked records: Every compliance log ties to an equipment profile, making it simple to produce complete service histories during an audit.
- Automatic leak rate calculation: Logging a refrigerant addition triggers an immediate leak rate calculation with threshold exceedance flagging.
- Cloud backup with iCloud sync: Records are continuously backed up, eliminating single-device data loss risk.
- Export for audits: Records export in PDF, CSV, or JSON format, organized by equipment, date range, or action type.
Key Takeaways
- Document everything: The EPA requires records across 13 categories covering every refrigerant handling activity.
- 3 years is the minimum: Retain records for at least 5 years as a safety margin, and never delete records related to open matters.
- Organize by equipment: Auditors investigate at the equipment level, so records must be retrievable that way.
- Completeness prevents penalties: A missing verification test or undocumented recovery is a violation, even if the work was done correctly.
- Digital beats paper: Cloud-backed records with audit trails are more reliable and defensible.
- FieldPad automates it: Structured forms ensure completeness, deletion guards enforce retention, and exports produce audit-ready reports.
Sources & Regulatory References
- 40 CFR Part 82, Subpart F — Section 608 record-keeping requirements for ODS refrigerant service
- 40 CFR Part 84 — AIM Act Subpart C documentation and record-keeping requirements for HFC systems
- EPA Section 608 — EPA’s Section 608 regulatory page with compliance guidance
- EPA AIM Act — HFC Phasedown — EPA overview of HFC reduction requirements
