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“Minimum A/C Equipment”
(including a refrigerant identifier)
and “Minimum Required Work” Set For Calif A/C Service Shops In 2001
by I.M. Cool
Appeared Sep/Dec 2000 Cool Profit$ Magazine
© 2000 All Rights Reserved

For the fiscal year 1998/99, California’s Bureau of Automotive Repairs (BAR) received 28,724 written consumer complaints filed against the state’s 33,000+ automotive repair dealers. With 98% of those complaints now closed, they found that 1,679 (8%) of them were air conditioning/cooling system related. The 1,679 complaints resulted in 3,082 allegations to be filed by subject. A breakdown by those subjects shows that approximately 1,278 (41%) of the complaints were related to competence/negligence, 13% (416) alleged false and misleading statements, another 13% (389) were allegations regarding damages to other parts of the vehicle, 12% contractual (355), and 3% (107) were fraud related.

Responding to the complaints
Given the above, in early 1999, BAR leaders targeted air conditioning service and repair as one of the areas needing immediate attention. They mapped out a plan to address key enforcement areas. In March 1999 they met with the industry leaders and government regulators associated with air conditioning repair to identify and discuss key problem areas. Their goal was to establish appropriate A/C service standards.

A follow-up meeting was held on May 6, in which everyone agreed that their proposed newly-developed regulations were necessary to resolve the problems currently occurring in the A/C repair industry. Assuming that these proposed regulatory changes are enacted, California’s A/C service shops will have to contend with new conditions in 2001 that fall into these two categories:

  • 1) a list of the minimum equipment required to perform A/C services, and,

  • 2) a list of the minimum services that must be performed for shops offering A/C service.

Both will be added to Division 33 of Title 16 of the California Code of Regulations.

The minimum equipment list
§3351.6. Equipment Requirements for Automotive Air Conditioning Repair Dealers
“All Automotive Repair Dealers engaged in the service or repair of automotive air conditioning systems in vehicles covered by the Act shall be subject to the following minimum requirements.
An automotive repair dealer that is performing service or repair to motor vehicle’s air conditioning system, which involves evacuation or full or partial recharge of the air conditioning system, shall have all repair, measuring, testing and refrigerant recovery equipment and current reference manuals necessary to service or repair the system, including but not limited to:
(a) Refrigerant identification equipment that meets or exceeds current Society of Automotive Engineers (SAE) standards.
(b) Refrigerant leak detection equipment that meets or exceeds current Society of Automotive Engineers (SAE) standards.
(c) Refrigerant recovery equipment that meets or exceeds current Society of Automotive Engineers (SAE) standards.
(d) Low and high pressure gauges for the purpose of measuring pressure in a mobile air conditioning system. As a minimum, the low pressure gauge shall be capable of measuring from zero to thirty inches of vacuum Hg, and zero to 250 pounds of pressure per square inch (psi). As a minimum, the high pressure gauge shall be capable of measuring from zero to 500 pounds of pressure per square inch (psi).
(e) An air conditioning system vacuum pump. When connected to a sealed automotive system, the pump shall be capable of reducing system pressure to a minimum of 29.5 Hg (inches of vacuum) measured on the low pressure gauge at sea level.
(f) A thermometer capable of testing air conditioning system efficiency. As a minimum, the thermometer shall be capable of measuring air temperatures from 20 to 100 degrees Fahrenheit.”

The minimum work list
§3366. Automotive Air Conditioning
Any automotive repair dealer that advertises or performs, directly or through a sublet contractor, automotive air conditioning work and uses the words service, inspection, diagnosis, top off, performance check or any expression or term of like meaning in any form of advertising or on a written estimate or invoice shall only do so when all of the following work is done:
(a) Exposed hoses, tubing and connections are examined for damage or leaks;
(b) The compressor and clutch, when accessible, is examined for damage, missing bolts/hardware, broken housing or leaks;
(c) The compressor is rotated to determine if it is seized or locked up;
(d) Service ports are examined for missing caps, damaged threads and conformance with labeling;
(e) The condenser coil is examined for damage, restrictions or leaks;
(f) The expansion device, if accessible, is examined for physical damage or leaks;
(g) The accumulator receiver dryer and in-line filter have been checked for damage missing or loose hardware or leaks;
(h) The drive belt system has been checked for damaged or missing pulleys or tensioners and for proper belt routing, tension, alignment, excessive wear or cracking;
(i) The fan clutch has been examined for leakage, bearing wear and proper operation;
(j) The cooling fan has been checked for bent or missing blades;
(k) Accessible electrical connections have been examined for loose, burnt, broken or corroded parts;
(l) The refrigerant in use has been identified and checked for contamination;
(m) The system has been checked for leakage at a minimum of 50 PSI system pressure;
(n) The compressor clutch, blower motor and air control doors have been checked for proper operation;
(o) High and low side system operating pressures have been recorded on the final invoice; and,
(p) The center air distribution outlet temperature has been recorded on the final invoice.

What did they say?
The bottom line of all of the above says to A/C shops: “Use the right tools, do the right service.” Essentially, shops that advertise the service and either perform it themselves, or, contract it out to another shop (or mobile service), will have to have, along with the normal A/C service tools, a refrigerant identifier before they can break into the system. In addition, a reasonably thorough minimum “service” is now defined. For many of the shops today, there will be no change in the way they do things, or the tools they use. For others, well, let’s say that a “gas-’n-go” is no longer acceptable.
If the wording of these regs sounds pretty reasonable to you›—like it was written by actual service technicians—it’s because it was. The final version turned out quite a bit different from the preliminary draft because of the generous, conscientious work of several shop owners, technicians and experienced trade representatives. (Cool Profit$ is aware of the specific input from Southern California shops. This may however, be a state-wide compilation of suggestions.)

US-wide acceptance
Time will tell if these requirements will end up being the norm nationwide. I’m sure, however, that all state’s governing agencies will be watching the reaction to them carefully during the next two years.

More of the why
In closing, here is a little extra in-depth information as to the specifics as to why the California BAR took the actions that they did. In their Initial Statement of Reasons, the BAR identified the problem of differing rules and requirements leading to confusion in the A/C service industry, amongst car owners and the various regulatory agencies themselves.
As an example, they pointed out that even the USEPA, while banning the production and importation of R-12, did not require the “repair” of a leaking R-12 system prior to recharge. However, two of California’s powerful rulemaking agencies, the South Coast Air Quality Management District (SCAQMD) and the Bay Area Air Quality Management District (BAAQMD) differ in how repair of leaking R-12 systems is handled. The SCAQMD only requires that R-12 systems be made leak-free before recharging. The BAAQMD demands that leaks be repaired on all systems, no matter what refrigerant is used.
Here are issues that the BAR was concerned with and therefore needed to be addressed in the regulatory changes:

  • Legal vs. illegal use of refrigerants;

  • Use of dangerous flammable refrigerant substitutes;

  • Failure to identify the refrigerant in use;

  • Repair shop theft of refrigerants from consumer air conditioning systems;

  • Inaccurate diagnosis and repair cost estimates by the industry;

  • Failure to disclose to consumers whether air conditioning systems are recharged with a new or recycled refrigerant;

  • Inappropriate advertising of air conditioning system services; and

  • Most of the recovery and recharging equipment used by the industry to service air conditioning systems has not been certified by the local county Weights and Measures departments. As a result, conflicts have arose relating to how a repair shop can itemize the amount of refrigerant removed from or added to an air conditioning system.

Your impressions
Repair shop theft of refrigerant is troubling. Is this really a problem? I’m very interested in your thoughts about these regulations in general. Are they good, bad, needed, unneeded? Let me know—go ahead, burn up the fax or email.
By the way, in case you need one, here are the two manufacturers of refrigerant identifiers: Neutronics Inc., Peter Coll, Exton, PA, 610-524-8800, and, Yokogawa Corp of America, James P. Young, Newnan, GA, 770-254-0400. You can now buy an identifier for as low as about $800.

Editor: Be sure to check in with “current” vendor list on the web at: www.imcool.com/buyersguide/.
Vendors: If you would like to be listed as a vendor to the automotive (and Heavy Duty) radiator and A/C service industry, please call, fax, email or fill out the form on the imcool.com web site. Look for Buyer’s Guide Data Entry Form.
Your cost to be listed on the web site and in the 2002 Annual Guide is only $15. For that, you also get a subscription to Cool Profit$ Magazine. In addition, your web listing will be maintained for free (name, contact, address, phone, email, URL, etc.). One heck of a deal.

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