Refrigerant Leak Detection in the US

Background

We wrote a blog post a while back about the benefits of Automatic Leak Detection (ALD) in refrigeration applications. If you missed it, you can read it here. Most of that information focused on what leak detection looks like in Europe and the United Kingdom. We’ve also hosted a couple of webinars on the topic and interviewed Sensitron’s R&D manager about trends in refrigerant gas sensor technology. In those videos we explain the EU regulations that require leak detection, the standards that apply to the detector technologies, and the benefits of automatic leak detection (ALD) in refrigeration operations.

Here, we’ll move across the Atlantic Ocean to talk about the United States of ‘America. The US has the largest refrigeration market in the world, and most of the benefits of ALD that apply to the rest of the world also apply there. However, there are some big differences that relate to when leak detection is required, what gases need to be detected, and what requirements detectors must meet. In this blog post, we’ll focus on when leak detection is required and provide some resources that show you how automatic leak detection requirements (ALDR) are enacted at a federal and state level.

Leak Detection at a Federal Level

In the US, laws are enforced at Federal, State, and Local levels. Generally, any law that does not exist at a federal level is left up to the states to enforce. The same thing applies from state to local legislation. At the federal level, Automatic Leak Detection requirements are enforced by the Environmental Protection Agency (EPA) under the Code of Federal Regulation (CFR). Title 40 of the CFR, which establishes the EPA and lays out all their regulatory statues, describes automatic leak detection requirements (ALDR) in Part 84 Subpart C Section 108. These requirements explicitly apply to refrigeration systems containing more than 1,500 lbs. of refrigerant charge, which is a massive amount.  It’s available to read online for free here.

Leak Detection at a State Level

For areas the Federal regulations don’t apply, the states are able to set their own ALDR. So, for smaller systems that still contain harmful refrigerants, states effectively enforce ALDR through several means. One source is in their building codes. All fifty states in the US have adopted the codes created by the International Code Council (i-codes). These codes are enforced locally by various Authorities Having Jurisdictions (AHJ). The states differ in version of the i-codes they have adopted, but for the most part the requirements are identical. In the International Mechanical Codes (IMC) and International Fire Codes (IFC), Chapters 11 and 6 govern ALDR respectively.

The specific sections that cover ALDR in detail are IMC 1105.3 and IFC 608.9 through 608.18. The ICC makes their codes available to read for free here.

Safety Standards Referencing Leak Detection

The IFC and IMC reference various safety standards to ensure refrigeration systems are designed and installed in a standard and safe manner. And an important part of ensuring safety in refrigeration systems is in their leak detection designs and requirements. The standards that the IMC ad IFC reference are American Society of Heating and Air-conditioning Engineers (ASHRAE) Standard Number 15, the International Institute for Ammonia Refrigeration (IIAR) Standard Number 2, the National Fire Protection Association (NFPA) Standard Number 70 (also known as the National Electric Code or NEC) and several different safety standards from Underwriters Laboratories (UL). All the safety standards that they list for manufacturers and designers to conform to have leak detection requirements mentioned. We’ve made a table below of the codes, standards, and UL approvals that might be needed to meet the different standards.

States with Extra Environmental and Personal Safety Requirements

Some states have opted to enforce particularly strict refrigerant management programs, namely California, New York, and Washington. In California, the California Air Resources Board (CARB) requires operations with refrigeration systems to participate in the Refrigerant Management Program (RMP). That program requires operators of large-refrigeration systems to install ALD. Washington and New York have similar requirements, and it’s expected that other states will follow their examples for establishing functional RMPs.

You can learn more about each state’s RMP by reading here: California, Washington, New York

 

Non-regulatory ALD

There are also non-regulatory reasons to install ALD. For building and construction projects that are seeking to achieve LEED sustainable building certification, installing ALD can give you points towards certification. In their “Enhanced Refrigerant Management” requirements, you can receive a point towards certification if you “specify an automatic leak detection system in fully enclosed spaces with equipment that has an overall refrigerant charge exceeding 100 tons of equivalent CO₂ emissions.”

Automatic Leak Detection Solutions

Refrigeration is a critical process. It’s also complicated. Every month there are new refrigeration system designs, retrofits, new refrigerant gases, and new laws on how to manage all of it. ALD can help safeguard your operation from regulatory and financial risks. At Crowcon, we know leak detection. Whether you are using A2L gases, natural refrigerants like R717, R744, or R290, or older F-gases that are environmentally toxic, we make detectors that meet your needs. If you have questions or are interested in how our detectors can help safeguard you from those risks, reach out.