What Triggers the Verification Requirement
A verification test obligation is triggered whenever a refrigerant leak repair is performed on regulated equipment. Under Section 608, this applies to equipment containing 50 pounds or more of refrigerant. Under AIM Act Subpart C, the threshold drops to 15 pounds or more for systems with a GWP above 53.
The trigger is the repair itself. Once you braze a joint, replace a Schrader valve core, tighten a flare fitting, or perform any action intended to stop a refrigerant leak, you must verify the repair through a structured two-stage testing process.
This process exists because some repairs that appear successful immediately can fail under operating conditions. Thermal cycling, vibration, and pressure fluctuations can re-open a leak that seemed sealed during the initial test.
Stage 1: Initial Verification Test
The initial test must be performed at the time of the repair, before you leave the job site. It confirms the repair is not actively leaking under current conditions.
Acceptable test methods include:
- Pressure or vacuum standing test on the repaired section, held long enough to detect leaks at the required sensitivity
- Electronic leak detection meeting regulation sensitivity requirements (typically 0.1 oz/year for Section 608, with enhanced requirements under Subpart C)
- Ultrasonic leak detection for pressurized systems where electronic detection is impractical
- Soap bubble testing at the repair location as a supplementary method (generally not accepted standalone for larger systems)
What you must record: date and time, test method, specific location tested, result (pass or fail), and any corrective action taken on failure.
Stage 2: Follow-Up Verification Test
The follow-up test is conducted after the system has returned to normal operation and run through multiple operating cycles. It catches repairs that hold initially but fail under real-world conditions.
The critical difference between frameworks is the deadline:
| Regulatory Framework | Follow-Up Deadline |
|---|---|
| Section 608 (ODS refrigerants, systems >= 50 lbs) | Within 30 days of repair |
| Subpart C (HFC refrigerants, GWP > 53, systems >= 15 lbs) | Within 10 days of repair |
The Subpart C timeline is significantly tighter, reflecting heightened concern around high-GWP HFC emissions. For solo technicians servicing mixed equipment fleets, tracking which deadline applies to which system is one of the more challenging compliance tasks.
Why Deadlines Matter
Missing a follow-up deadline is a standalone violation, separate from the underlying leak. Even if the repair was successful and the system is no longer leaking, failing to perform and document the test within the required window is a citable offense carrying the same penalty authority as substantive violations.
What Constitutes a Passing Test
A test passes when no leak is detected at the repair location using the specified method. For pressure-based tests, the system must hold test pressure within tolerances for the specified duration. For electronic detection, no alarm at the calibrated sensitivity level.
Important distinctions:
- The test covers the repair location specifically, not the entire system
- The follow-up should be conducted while the system is operating or has recently operated, so thermal cycling and vibration have stressed the repair
- Detector calibration must be current – an uncalibrated detector can invalidate the result during an audit
When Follow-Up Tests Fail
If the follow-up reveals the repair location is still leaking, the compliance clock resets:
- Perform an additional repair to address the persistent leak
- Conduct a new initial verification test at the time of re-repair
- Schedule a new follow-up test within the applicable deadline from the re-repair date
- Recalculate the leak rate if additional refrigerant was added
This cycle repeats until the follow-up passes or the equipment owner decides to retrofit or retire the equipment. Each failed cycle increases cumulative refrigerant additions, potentially pushing equipment toward chronic leaker classification at 125% of full charge.
Section 608 vs. Subpart C: Full Comparison
| Requirement | Section 608 | Subpart C |
|---|---|---|
| Charge threshold | >= 50 lbs | >= 15 lbs (GWP > 53) |
| Follow-up deadline | 30 days | 10 days |
| Detector sensitivity | Standard 608 requirements | Enhanced for certain HFC blends |
| A2L safety requirements | Not applicable | Required for mildly flammable refrigerants |
A2L Safety During Verification
When testing systems using A2L refrigerants (R-32, R-454B, etc.), additional precautions apply before any leak detection work:
- Verify refrigerant sensors in the equipment space are operational
- Confirm adequate ventilation in the work area
- Use detection equipment rated for flammable refrigerants
- Follow manufacturer A2L service procedures, including de-energizing ignition sources
These safety steps must be documented as part of the compliance record alongside the test itself.
Documentation Requirements
Every verification test requires:
- Date and time of the test
- Test type: Initial or follow-up
- Equipment identification: Location, type, serial number
- Repair being verified: Reference to the repair record
- Test method and equipment: Make, model, serial number, and calibration date for detectors
- Specific location tested
- Result: Pass or fail
- Technician identification: Name and EPA certification number
- If failed: Failure description and reference to subsequent repair
All documentation must be retained for a minimum of 3 years.
Scheduling Challenges for Solo Technicians
The follow-up test requires returning to the same job site within 10 or 30 days. For technicians with busy schedules and geographically dispersed customers, this return visit is easy to forget or deprioritize.
Practical strategies:
- Schedule the return visit before leaving the initial repair site
- Group follow-up visits geographically to minimize drive time
- Prioritize Subpart C follow-ups due to the tighter 10-day window
- Use automated reminders that escalate as deadlines approach
How FieldPad Tracks Verification Deadlines
FieldPad automates verification test management:
- Automatic deadline calculation: Logging a repair triggers framework detection from the equipment profile and calculates the correct follow-up deadline.
- Escalating reminders: Notifications at 7, 3, and 1 days remaining for Section 608; at 5, 2, and 1 days for Subpart C.
- Compliance dashboard: Pending tests appear with color-coded urgency. Overdue tests are flagged prominently.
- Linked records: Initial test, follow-up test, and repair record all link to the same equipment profile for a complete audit trail.
- Failed test workflow: Recording a failed follow-up prompts a new repair log and creates a fresh deadline automatically.
- A2L integration: For A2L refrigerant systems, the safety checklist is included in the verification workflow.
Key Takeaways
- Every leak repair triggers two-stage verification: initial test at repair time plus follow-up within the applicable deadline.
- Section 608 allows 30 days; Subpart C allows only 10. Know which framework applies to each system.
- Missing a deadline is a standalone violation, independent of repair success.
- Failed follow-ups restart the cycle: new repair, new initial test, new deadline.
- Document every test completely, including method, equipment, result, and technician ID.
- A2L systems require additional safety steps that must also be documented.
- FieldPad automates deadline tracking, sends escalating reminders, and links all verification records for audit-ready compliance.
Sources & Regulatory References
- 40 CFR Part 82, Subpart F — Section 608 verification test requirements
- 40 CFR Part 84 — AIM Act Subpart C verification requirements with 10-day follow-up deadline
- EPA Section 608 — EPA’s regulatory page for stationary refrigeration compliance
