compliance

Leak-repair verification: scope and deadlines

| | 3 min read

Executive Summary

Covered leak repairs require initial and follow-up verification. Both frameworks generally use a 10-day follow-up window; a failed test does not reset the repair period.

Confirm the covered repair

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.

Paragraph (e) of each rule requires initial and follow-up tests for leaks repaired under its paragraph (d). This is not a blanket statement that every repair on every appliance triggers the same federal testing duties. Separate equipment instructions and applicable safety requirements still matter.

Initial and follow-up testing

Initial verification belongs within the applicable repair period: ordinarily 30 days, or 120 days when an industrial process shutdown is required, subject to the rule’s extensions. It must be performed after the repair and before adding refrigerant, with the detailed procedure depending on whether evacuation was necessary.

Both §82.157(e)(2) and §84.106(e)(2) generally require follow-up within 10 days of successful initial verification, or within 10 days of reaching normal operating conditions when the appliance or isolated component was evacuated for repair. Review the provisions for situations where normal-operation testing is unsafe or impossible.

A failed test does not automatically reset the original repair period. Additional repairs and tests must fit within the applicable period; continuing leakage may require a retrofit/retirement plan under paragraph (h), or a qualifying extension under paragraph (f).

Preserve the actual evidence

The definitions in §82.152 and §84.102 describe verification tests and potential methods. Select methods appropriate to the appliance and repair; this article does not prescribe a universal detector sensitivity or prohibit appropriate soap-bubble testing.

Retain the dates, repaired leak locations, methods and results required by the relevant recordkeeping provisions. FieldPad can organize these records and reminders. Check the governing dates and supporting evidence; a checklist or notification does not certify successful repair, timely verification or compliance.

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