compliance

Full-charge determinations and independent circuits

| | 3 min read

Executive Summary

Use the statutory full-charge methods for each appliance, retain the basis, and preserve a traceable history of revisions.

Determine the appliance before the charge

§82.152 and §84.102 treat each independent refrigerant circuit as a separate appliance. Four independent 45-pound circuits must not be combined into one 180-pound appliance for these calculations. Confirm the actual circuit arrangement.

Four statutory methods

The definitions allow one or a combination of:

  1. The manufacturer’s full-charge determination.
  2. Appropriate calculations using component sizes, refrigerant density, piping volume and other relevant factors.
  3. Actual measurements of refrigerant added or evacuated, including seasonal variances.
  4. An established range based on the best available normal-operating data, using the range’s midpoint as full charge.

Nameplate and detailed manufacturer specifications are evidence for the manufacturer method; they are not two separate statutory methods. Field measurements must establish the amount required for normal operation, not assume any amount charged is necessarily correct.

Applicability and revisions

Section 82.157 generally covers appliances with a full charge of at least 50 pounds of an ODS refrigerant or a blend containing ODS. Section 84.106 applies from January 1, 2026 to qualifying appliances with a full charge of at least 15 pounds of refrigerant containing either a regulated substance, or a substitute for a regulated substance whose GWP is greater than 53. The GWP cutoff belongs to the substitute branch. Part 84 excludes solely-ODS appliances and residential/light-commercial AC and heat pumps. Refrigerant identity or charge alone does not establish coverage.

For covered appliances, §82.157(l)(1) and §84.106(l)(1) require the full-charge basis and revisions to be retained until three years after retirement. When using the range method, record the range, midpoint and how it was determined. Record dates and reasons for revisions.

A revised equipment fact should create a traceable correction or new determination. Preserve the original inputs, result and rule version; do not silently rewrite historical evidence. FieldPad supports equipment facts and service records, but selecting a refrigerant and charge cannot establish every applicable duty.

For leak-rate arithmetic and elapsed-day rules, see annualizing and rolling-average methods.

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