LeakLedgerPart 84 guide
Does the 15-lb Rule Apply to My Equipment? Racks, Walk-ins, Rooftops and Refrigerants
Part 84's leak repair rule applies to an appliance when two things are true: it holds 15 lb or more of refrigerant, and that refrigerant is an HFC or a substitute with a GWP above 53 (40 CFR 84.106(a)). Two exclusions remove ODS-only systems and residential and light commercial A/C. Here's how that plays out across the equipment you service.
Test 1: is the full charge 15 lb or more?
The threshold is the appliance's full charge — the amount of refrigerant it needs for normal operation — not the amount in it today. §84.102 lets you determine the full charge four ways: the manufacturer's determination, an appropriate calculation (component sizes, refrigerant density, piping volume), actual measurement, or an established range whose midpoint is used.
The rule applies per appliance, so a store with ten 8 lb reach-ins has no covered appliances among them, while a single 22 lb walk-in freezer is covered. Whether connected cases on one rack form a single appliance follows from how the refrigerant circuit is built; when in doubt, document how you drew the line.
Test 2: what's the refrigerant?
| Refrigerant | Typical use | Leak repair applies? (15 lb+) |
|---|---|---|
| R-404A, R-507A | Older supermarket racks, walk-ins, cold storage | Yes — HFC blends |
| R-448A, R-449A | Newer and retrofitted racks, walk-ins | Yes — contain HFCs |
| R-134a | Medium-temperature systems, chillers | Yes — HFC |
| R-410A | Commercial A/C and rooftop units | Yes, unless the unit is residential / light commercial A/C |
| R-22 | Legacy equipment | No, if it contains only R-22 — Section 608 applies instead |
| R-744 (CO₂), R-290 (propane), R-717 (ammonia) | Transcritical racks, self-contained cases, industrial | No — GWP of 53 or less |
GWPs for substitutes come from table 1 of 40 CFR 84.64(b). Check blends you're unsure about against the table: a blend containing an HFC contains a regulated substance.
The residential and light commercial A/C exclusion
Appliances "used for the residential and light commercial air conditioning and heat pump subsector" are excluded (§84.106(a)(3)(ii)). The regulation doesn't define the subsector, so EPA's preamble and guidance are the place to look for where light commercial ends. Rooftop units and split systems on small commercial buildings are the usual gray zone; chillers and refrigeration are not part of this exclusion. If a rooftop unit's status is unclear, record your reasoning — LeakLedger lets you mark an appliance as residential / light commercial A/C, and its reports state why each appliance is or isn't covered.
Common equipment, at a glance
- Supermarket racks: almost always covered — large HFC charges, commercial refrigeration, 20% threshold. Racks of 500 lb or more get quarterly inspections after an exceedance; 1,500 lb or more need automatic leak detection.
- Walk-in coolers and freezers: covered when the system's full charge is 15 lb or more of an HFC; many condensing-unit systems are.
- Reach-ins and self-contained cases: usually under 15 lb, and many new ones use R-290 — typically not covered.
- Ice machines: usually small charges; check the nameplate.
- Cold storage and industrial process systems: covered when HFC-based; IPR has a 30% threshold.
- Chillers and commercial comfort cooling: covered with HFCs; 10% threshold.
Once it's covered
Every refrigerant addition needs a leak rate calculation (§84.106(b)). Try one in the leak rate calculator — it also checks coverage — or read the complete Part 84 guide.
Do this math for every appliance automatically
LeakLedger reads the service records you already keep, calculates every leak rate with the arithmetic shown, tracks each Part 84 deadline, and builds a branded report for each customer. $149/month, 14-day free trial.
This guide summarizes 40 CFR 84.102, 84.106 and 84.108 as published in the eCFR. It is not legal advice; where the rule is unclear we say so. Read the rule: 40 CFR Part 84, Subpart C.