Type I: Small appliances

Study guide

License Method EPA 608 prep. This guide was checked against the eCFR (40 CFR Part 82 Subpart F and Part 84 Subpart C) as of October 20, 2026. Rules that changed recently are marked NEW or CHANGED. Sections marked Field practice come from EPA's test topics and shop practice, not regulatory text.

What Type I covers

Type I certification covers servicing small appliances: household refrigerators and freezers, window and room ACs, PTACs/PTHPs, dehumidifiers, under-counter ice makers, vending machines, and water coolers. (40 CFR 82.161(a)(1)(i))

Certification is needed for work that could breach the circuit: attaching hoses and gauges, adding or removing refrigerant or components, or cutting lines. Painting, rewiring a cord, or tightening bolts doesn't count. (82.152, "Technician")

• Disposal: people who dispose of small appliances (such as scrap-yard workers) need no certification, but must still use certified recovery equipment and meet the levels below. (82.161(a)(1)(vii); 82.155(a))
• Apprentices: a registered apprentice may work uncertified while closely and continually supervised by a certified tech, for up to two years from first registration. (82.161(a)(2); 82.152)

What makes an appliance a "small appliance"

A small appliance is fully manufactured, charged, and hermetically sealed in a factory with 5 pounds or less of refrigerant. (82.152) An appliance has to pass both tests:

1. Factory sealed. A field-brazed, field-charged split system fails, whatever its charge. It's Type II work.
2. 5 lb or less. A factory-sealed cooler with 6 lb of R-134a (medium-pressure) fails too. Also Type II.

Small appliances must have a process stub: tubing that gives access to the refrigerant and can be resealed after service (exempt-refrigerant units excepted). (82.152; 82.154(e)(2)) Connecting hoses and gauges isn't "opening an appliance," but it is still certified technician work. (82.152)

Required recovery levels (40 CFR 82.156(b))

Before you open a small appliance, and when you dispose of one, you must recover the refrigerant using certified recovery equipment. You must meet one of these levels:

• Old equipment: always 80%. Newer equipment: 90% with a working compressor, 80% with a dead one. A 4-inch vacuum always satisfies the rule.
• Recovered refrigerant may go back into the same appliance or another one owned by the same person without recycling or reclaiming. A new owner gets reclaimed refrigerant only. (82.156(h); 82.154(d))

Recovery equipment: self-contained vs. system-dependent

• Self-contained (active): removes refrigerant without help from the appliance's components. It usually has its own compressor. (82.152)
• System-dependent (passive): relies on the appliance's components, such as the compressor or system pressure, to move refrigerant out. (82.152)
• System-dependent equipment may not be used on appliances with more than 15 lb of refrigerant unless it is a permanently attached pump-out unit. (82.156(e)) Every small appliance is 5 lb or less, so passive recovery is allowed on all of them.

Equipment certification (82.158):

• An approved testing organization certifies the equipment to recover 90% with the test-stand compressor running, 80% with it off, or to reach a 4-inch vacuum where allowed. Pre-1993 equipment qualifies at 80% or a 4-inch vacuum. (82.158(e))
• The label shows the testing organization, appliance category, manufacture date, and serial number. Altering equipment in a way that affects performance makes it uncertified until retested. (82.158(b), (h))

Recovery techniques (Field practice)

From EPA's Type I test topics: expect them on the exam, but they're technique, not regulation.

• Working compressor + passive device: run the appliance compressor during recovery. It does the pumping.
• Dead compressor: install access valves on both the high side and the low side. One port leaves refrigerant trapped across the capillary tube.
• Dead compressor + passive device: warm the compressor and strike it sharply to drive refrigerant out of the oil. Cold keeps it dissolved.
• Vacuum pump method: a vacuum pump with a non-pressurized recovery container, never a disposable cylinder.

Piercing (solderless) access valves (Field practice)

• Bolt-on piercing valves give access where there is no service port. Their clamped gasket seal tends to leak over time, so leak-check them after installing.
• EPA's test topics say to remove solderless access fittings when service is finished and reseal the access point. A certified tech should confirm the sealing method.

Pressure, temperature, and non-condensables

• At a stable, known temperature, an idle system or cylinder should read close to its refrigerant's saturation pressure on a P/T chart.
• Identify refrigerant: check the nameplate, or compare an idle unit's pressure at room temperature with P/T charts.
• Non-condensables: a settled cylinder reading well above chart pressure suggests air. Liquid level doesn't change saturation pressure.
• psia = psig + about 14.7 at sea level. Compare like with like.

Disposal and the final processor (40 CFR 82.155)

Small appliances usually reach the scrap yard still charged, so the final processor (the last link, such as a scrap recycler or landfill) must either:

1. Recover any remaining refrigerant to the 82.156(b) levels, or
2. Verify that it was already recovered, using a signed statement or a contract.

• Signed statement contents: the name and address of the person who recovered the refrigerant and the date it was recovered.
• Contracts are for regular commercial suppliers, not individuals or one-time drop-offs.
• No stickers. EPA does not accept a sticker as verification.
• Leaked out: if all the refrigerant leaked out before delivery, the final processor needs a signed statement saying so and that recovery was not possible. "Leaked out" excludes deliberate acts, such as cutting lines, and negligence.
• Accepting a statement you knew or had reason to know was false is a violation.
• Records: the final processor keeps statements and contracts on site for 3 years. (82.155(c))
• The technician disposal records in 82.156(a)(3) apply only to appliances with more than 5 and less than 50 lb of refrigerant, so small appliances aren't covered.

NEW (Jan 1, 2028): used HFC disposable cylinders must go for heel removal, or a certified tech evacuates them to 15 in. Hg and signs a statement for the final processor. (40 CFR 84.116) Probably not on the current test.

Venting, de minimis releases, and exempt refrigerants

• You may not knowingly vent refrigerant while maintaining, servicing, repairing, or disposing of an appliance. Releasing refrigerant after you've recovered it is also venting. (82.154(a)(1), (a)(3))
• De minimis releases aren't violations. These are small, unavoidable releases during a good-faith recovery that follows the required practices with certified equipment, such as when you connect or disconnect hoses. (82.154(a)(2))
• CHANGED (2016 rule): the rules now cover non-exempt substitutes such as R-134a, not just CFCs and HCFCs. Zero ozone depletion potential doesn't mean exempt.
• Exempt in any application: CO2, nitrogen, and water. (82.154(a)(1)(i)-(iii))
• Exempt only in listed end uses: R-600a (isobutane) and R-441A in household refrigerators and freezers, plus other listed units, and R-290 (propane) in household refrigerators, room ACs, vending machines, water coolers, and other listed units. (82.154(a)(1)(viii)-(x)) Exempt means outside the Subpart F rules. It doesn't mean safe to release indoors.

Leak repair: not a Type I issue

CHANGED (2020): 82.157 leak repair now covers only appliances with 50 lb or more of ozone-depleting refrigerant. NEW: AIM Act HFC leak repair (40 CFR 84.106) starts at 15 lb. Small appliances fall under neither rule.

Refrigerants and flammable hydrocarbons

• R-134a has been the most common replacement for R-12 in household refrigerators. Many new refrigerators use R-600a, and some small units use R-290.
• Hydrocarbon household refrigerators are listed under SNAP for new equipment only, so no retrofits of an existing R-134a or R-12 unit to a hydrocarbon. (40 CFR 82 Subpart G use conditions)
• Under SNAP use conditions, service ports and process tubes on these units are marked red (PMS #185). Red means flammable refrigerant inside.
• Field practice for R-290/R-600a: no flames or sparks, ventilate, use equipment rated for flammables (recovery machines are tested under Appendix B4), and follow the manufacturer's instructions.
• Don't mix refrigerants in one recovery cylinder. A mixed cylinder generally can't be reclaimed to spec.

Sales restrictions and recordkeeping

• Since Jan 1, 2018, refrigerant sales (including HFCs) are limited to certified technicians, or employers of certified technicians who show proof, plus a few other listed buyers such as appliance manufacturers. (82.154(c)(1))
• Consumer exception: self-sealing car A/C cans of 2 lb or less with a unique fitting. Not for stationary equipment. (82.154(c)(1)(ix))
• Sellers keep invoices showing buyer name, sale date, and quantity for 3 years. (82.154(c)(3))
• Used refrigerant sold to a new owner must be reclaimed by a certified reclaimer. (82.154(d); 84.104(a))
• Technicians keep a copy of their certificate at their place of business until 3 years after they stop working as a technician. (82.161(a)(4))
• Penalties: up to $124,426 per day per violation (Clean Air Act, assessed on or after Jan 8, 2025; adjusted yearly for inflation). (40 CFR 19.4)

Safety (Field practice)

• Open flame or hot surfaces decompose refrigerants into toxic products, including phosgene and acids. Recover first, then braze.
• Refrigerant vapor is heavier than air and displaces oxygen in enclosed spaces. Ventilate.
• Wear safety glasses and gloves. Liquid refrigerant causes frostbite and eye injury.
• Fill recovery cylinders to no more than 80% so the liquid has room to expand. Overfilling risks rupture.
• Recovery cylinders are DOT-approved and usually have a gray body and yellow top. Never refill disposable cylinders.
• Pressure-test with dry nitrogen through a regulator, never oxygen or shop air.

The Type I test

• Each test has 25 Core questions plus 25 Type I questions. Universal is 100 questions. (Appendix D; 82.161(c))
• A Type I-only program may give the test on site or by mail-in (open book). Many programs now offer it online; check with yours. (Appendix D)
• Passing score: 70% for closed-book tests (18 of 25) and 84% for mail-in Type I (21 of 25).
• A mail-in Type I can't be used toward Universal. For Universal, Core and Type I must be taken closed-book and proctored.
• Time limits vary by certifying organization. EPA doesn't set a national time limit.
• Certification does not expire, though EPA can revoke it or require recertification in the future. (82.161(a)(3), (a)(5))

Common traps

• Mixing up the numbers. 5 lb defines a small appliance, 15 lb is the system-dependent limit, and 50 lb is the 82.157 leak-repair threshold.
• Reading 90% as the rule for every case. 90% applies only with post-1993 equipment AND a working compressor. Everything else is 80% (or a 4-inch vacuum).
• Calling a field-charged split system a small appliance. Both factory sealed and 5 lb or less are required.
• Treating "exempt" as "safe to vent indoors." R-290 and R-600a are flammable.
• Saying small-appliance disposal needs certification. It doesn't, but equipment and recovery levels still apply.
• Accepting a sticker or a "leaked out" statement for cut lines. Neither works.
• Thinking a mail-in Type I counts toward Universal.
• Assuming HFCs are unregulated because their ODP is 0.

Quick review

• Small appliance = factory sealed and 5 lb or less
• Pre-1993 equipment: 80%. Post-1993: 90% with a working compressor, 80% with a dead one. Any equipment: a 4 in. Hg vacuum
• Recover before opening and at disposal, with certified equipment
• Dead compressor: high- and low-side valves, heat and tap
• Working compressor with a passive device: run it
• Remove piercing valves when finished
• P/T chart: higher than chart pressure means non-condensables; psia = psig + 14.7
• Final processor: recover or get a signed statement or contract (name, address, date); keep 3 years; no stickers
• Exempt everywhere: CO2, N2, water. Exempt in listed uses: R-600a, R-290, R-441A
• Safety: phosgene, oxygen displacement, 80% fill, gray/yellow cylinders, nitrogen only
• Test: 25 + 25; 70% closed-book, 84% mail-in; mail-in doesn't count toward Universal; time limits vary

Rapid-fire numbers to memorize