EPA Section 608 Compliance
Are all of your stores in compliance with Section 608? Do you know? Are you sure? Really?
Section 608 of the Clean Air Act, which regulates refrigerant production, use, emissions and end-of-life, can be complicated in theory and in practice. The compliance burden falls on individual supermarket stores, which means that it takes only one store to bring down your company’s good name. It is very difficult to be sure that each and every store is ready for an EPA inspection, but at fines of $37,500 per violation, per day, it’s better to be safe than sorry.
Full compliance with EPA regulations is best achieved with a compliance program that includes training, a robust record-keeping system, a self-auditing process, an action plan to rectify problems, and a strategy to prevent violations.
Is it too late to avoid enforcement problems?
If you are on the hook with the EPA for Section 608 violations, you should seek assistance from a specialist in refrigerant regulations and refrigerant management. Your law firm(s) probably do not have an expert in this area.
An expert with in-depth knowledge of refrigerant regulations, EPA enforcement goals, and the way the EPA works can help you negotiate. And you SHOULD always negotiate if you are in violation of EPA regulations.
If you need expert assistance with EPA Section 608 Compliance and keeping on top of refrigerant regulations, contact KW Refrigerant Management Strategy.