HVAC insurance that keeps the license active.

EPA Section 608: who must be certified and what to record

Under 40 CFR 82.161, anyone who could reasonably be expected to open the refrigerant circuit while maintaining, servicing, repairing or disposing of equipment must pass an exam from an EPA-approved certification program. That covers ozone-depleting refrigerants and every substitute not on the short exempt list in 82.154(a)(1), which includes carbon dioxide, nitrogen, water and, in certain equipment only, ammonia and some hydrocarbons. The certification type has to match the equipment:

• Type I. Small appliances, meaning factory-sealed units with 5 pounds or less of refrigerant, such as window air conditioners.
• Type II. Medium-, high- and very high-pressure appliances other than small appliances and motor vehicle AC. EPA's definition names R-22 and R-410A equipment as high-pressure examples.
• Type III. Low-pressure appliances.
• Universal. All three of the above.

Apprentices are exempt only while a certified technician closely and continually supervises them, and the rule makes both responsible for compliance. Each technician keeps a copy of the certificate at their place of business until three years after they stop working as a technician.

Commercial service adds paperwork. Whoever adds or removes refrigerant must give the owner documentation at the end of the service on appliances with 50 pounds or more of an ozone-depleting refrigerant (82.157) and, since January 1, 2026, appliances with 15 pounds or more of an HFC or a substitute above 53 GWP (84.106, which excludes residential and light commercial AC and heat pumps). Technicians who recover refrigerant for disposal from appliances holding more than 5 and less than 50 pounds keep recovery records for three years (82.156).

When I take an application, I ask which certification each field employee holds and how many are still supervised apprentices.

California changeouts: permits and duct testing

Effective January 1, 2026, the field verification and diagnostic testing that used to run through the HERS Program sits in the Energy Code itself (Title 24, Part 6), and the person doing it is a certified ECC-Rater. The Energy Commission says properly permitted work triggers any required testing. For a single-family home, Section 150.2(b)1 of the 2025 Energy Code works like this:

• Equipment replacement (150.2(b)1E). Installing or replacing the air handler, the outdoor condensing unit of a split system, or a cooling or heating coil means the connected ducts must be sealed and tested in all climate zones. To pass, leakage must be 10 percent or less of air handler airflow, or 7 percent or less to the outside. If neither is possible, all accessible leaks must be sealed and verified by an ECC-Rater with a visual inspection and smoke test.
• Duct exceptions. Ducts previously sealed and verified, duct systems under 40 linear feet, and existing ducts built, insulated or sealed with asbestos.
• Refrigerant-side work (150.2(b)1F). Replacing a compressor, coil, metering device or refrigerant piping on an AC or heat pump requires setback thermostats. Air-cooled AC in Climate Zones 2 and 8 through 15, and air-source heat pumps in all zones, also need verified airflow of at least 300 cfm per ton (250 for small-duct high-velocity systems) and refrigerant charge verification (new factory-charged packaged units skip the charge check).

Keep the permit number and the verification records in each job file.

Official sources

• eCFR: 40 CFR Chapter I, Subchapter C (Part 82 Subparts F and G; Part 84 Sections 84.54 and 84.106)
• Federal Register: Phasedown of Hydrofluorocarbons, Reconsideration of Technology Transitions Requirements (final rule, May 26, 2026)
• EPA: Questions and Answers About SNAP
• CARB: California SNAP, Air-conditioning Equipment
• CARB: Hydrofluorocarbon (HFC) Prohibitions in California
• California Energy Commission: 2025 Building Energy Efficiency Standards (CEC-400-2025-010-F)
• California Energy Commission: Home Energy Rating System (HERS) Program
• IRMI: The Hazards of Products and Completed Operations: Understanding the Fundamentals
• IRMI: Policy Modifications and Endorsements Relating to Liability Insurance Coverage for Mold
• IRMI: The CGL Pollution Exclusion