EPA compliance · guide

The 30-day repair clock and the two verification tests

40 CFR 84.106(d)–(i) · in force since January 1, 2026

The moment a leak rate calculation comes out over the threshold, a fixed sequence starts with fixed dates. Most people know about the 30 days. Fewer know the clock starts on the day the refrigerant went in, not the day somebody noticed — or that two separate verification tests are required, with their own deadline after the first one passes.

Day zero is the day refrigerant was added

The rule gives you 30 days “of when refrigerant is added to a refrigerant-containing appliance exceeding the applicable leak rate”. Not from when the calculation was done, not from when the paperwork reached the office. From the addition.

That matters because the calculation and the addition often happen days apart. If a technician tops up a rack on the 3rd and the leak rate gets worked out on the 10th, you have already used a week.

“Owners or operators must identify and repair leaks… within 30 days (or 120 days if an industrial process shutdown is required) of when refrigerant is added to a refrigerant-containing appliance exceeding the applicable leak rate.” — 40 CFR 84.106(d)

What has to happen inside those 30 days

A certified technician conducts a leak inspection to find where the leaks actually are. Guessing does not count — the rule requires an inspection to identify the locations.
The leaks get repaired, and repaired well enough to bring the leak rate below the applicable threshold. Not to zero — below the threshold.
An initial verification test is performed, inside the same 30-day window.

Then, after that window: a follow-up verification test, on its own separate deadline.

The initial verification test

This one asks a narrow question: did the repair hold? It has to demonstrate that the adjustments or alterations made to the appliance have held.

If the repair did not require opening or evacuating the appliance, the test happens after the repairs are finished and before any more refrigerant goes in.
If the repair did require evacuating the appliance or part of it, the test happens before adding any refrigerant back.

If it fails, you are allowed to keep repairing and keep retesting — as many times as it takes, provided it all happens inside the applicable time period.

The follow-up verification test, and its 10 days

This is the one people miss. A follow-up verification test must be performed within 10 days of either:

the successful initial verification test, or
the appliance reaching normal operating characteristics and conditions, if it or an isolated component was evacuated for the repair.

Its job is different from the initial test. The initial test asks whether the repair held; the follow-up asks whether the leak is actually repaired, with the system running as it normally runs. Where it is unsafe or impossible to test at normal operating conditions, the rule says the test must where practicable be done before the system returns to those conditions.

“A follow-up verification test must be performed within 10 days of the successful initial verification test or 10 days of the refrigerant-containing appliance reaching normal operating characteristics and conditions.” — 40 CFR 84.106(e)(2)

120 days, and when you actually get them

The 120-day version is not a general extension for big equipment. It applies where an industrial process shutdown is required to do the repair. If you can repair it without shutting the process down, you are on 30 days.

The clock can be paused

If an appliance is mothballed — evacuated to at least atmospheric pressure and temporarily shut down — the time frames are suspended. They restart on the day refrigerant is added back to the appliance, or to the isolated leaking component.

Extensions exist, and they are not a rubber stamp

You can have longer than 30 or 120 days if you meet the conditions in the rule — among them radiological contamination, other federal, state, local or tribal regulations that make repair in the window impossible, and a handful of similar situations. The request must be signed by an authorised company official.

One detail worth knowing: the request is considered approved unless EPA notifies you otherwise. That is not permission to invent a reason — it is an enforcement posture, and the conditions still have to be genuinely met.

If the repairs do not get you under the threshold

You do not get to keep trying indefinitely. If you elect to repair and fail to bring the leak rate below the applicable rate, you must create and implement a retrofit or retirement plan. The plan has to be created within 30 days of the trigger, must contain a schedule, and — with limited exceptions — the work has to be completed within one year of the plan’s date. Extensions to that year can be requested, as can relief from the plan altogether if certain conditions are met.

And then the inspections start

Going over the threshold also puts the appliance on an inspection schedule until it has behaved itself for long enough.

Appliance	Leak inspection	Until
Commercial refrigeration and IPR, full charge 500 lb or more	Once every 3 months	Leak rate calculations show no exceedance for four quarters in a row
Commercial refrigeration and IPR, 15 to under 500 lb	Once per year	No exceedance for one year
Comfort cooling and everything else covered	Once per year	No exceedance for one year

Inspections run from the date of a successful follow-up verification test, must be done by a certified technician, and must cover all visible and accessible components — with sensible exceptions for parts that are insulated, iced over, underground, behind walls, more than two metres up, or unsafe to reach. Appliances continuously monitored by an automatic leak detection system that is audited or calibrated annually do not need the periodic inspections.

Leaking 125% or more of the full charge in a calendar year makes the appliance a chronically leaking appliance, and that has to be reported to the EPA by March 1 of the following year. It is a separate obligation from everything above.

Know when the clock started

All of this hangs off one date and one number: when refrigerant went in, and what the leak rate came to. Work out the number with our refrigerant leak rate calculator, and check you are applying the right threshold in 10%, 20% or 30%.

Three deadlines per leak, per appliance

AirCert starts the clock on the right date and keeps it

Thirty days from the addition, an initial verification test inside that window, a follow-up within ten days of it passing, then quarterly or annual inspections until the appliance is clean. AirCert works out all of those dates the moment the leak rate goes over, reminds you before they run out, and prints the record. Out now on Android, and coming soon to iPhone and iPad.

Get it on Google Play

ToolRefrigerant leak rate calculator Before this10%, 20% or 30% — which threshold applies After thisWhat refrigerant records the EPA requires, and for how long

Where this comes from

Repair deadlines, verification tests, extensions, retrofit and retirement plans, leak inspections and the chronic leaker report are all at 40 CFR 84.106, paragraphs (d) to (j). The EPA summarises the same sequence in its January 2026 leak repair fact sheet.

This is a guide, not legal advice. Every deadline here is cited to the regulation, but your situation may involve extensions, mothballing or shutdown conditions that change the dates. Check the regulation, and take advice where it matters.