Type I: Small Appliances and Recovery Requirements

Type I is the shortest of the technical sections to learn, and the easiest to lose points on by mixing up two percentages. It covers small appliances only: home refrigerators and freezers, room air conditioners, dehumidifiers, water coolers. Here is what the rule actually says about them, with the regulation section for each fact.

What makes an appliance "small"

EPA's definition in 40 CFR 82.152 has three parts, and all three must be true. A small appliance is a product that is:

1. fully manufactured, charged and hermetically sealed in a factory,
2. with five pounds or less of refrigerant,
3. such as refrigerators and freezers, room air conditioners, dehumidifiers and drinking water coolers.

The factory-sealed part is where test questions hide. A field-charged system with a 4 lb charge is still not a small appliance, because it was not charged and sealed at the factory. Under 40 CFR 82.161, Type I certification is required for technicians who maintain, service or repair small appliances.

Source: EPA Section 608, 40 CFR 82.152 and 40 CFR 82.161.

What the Type I test covers

EPA's test topics page lists three headings for Type I: Recovery Requirements, Recovery Techniques, and Safety. Recovery Requirements is the one with numbers.

The recovery requirements

Before you open or dispose of a small appliance, you must recover the refrigerant using certified recovery equipment. 40 CFR 82.156(b) gives the levels:

Or, as an alternative to the percentages: evacuate the small appliance to four inches of mercury vacuum.

Source: EPA Section 608, 40 CFR 82.156(b) and EPA's service practice requirements.

How to remember it

The date is about the recovery machine, not the appliance. Newer recovery equipment is expected to do better, so 90 percent applies only when two things are true: the recovery equipment is from November 15, 1993 or later, and the appliance compressor works. If either one is missing, the number is 80 percent. A working compressor helps push refrigerant out; a dead one leaves more behind, so the rule asks for less.

Why the date November 15, 1993 keeps showing up

The same date splits the evacuation table for larger appliances in 82.156(a). In both places it refers to when the recovery or recycling equipment was manufactured or imported. Learn it once and it answers questions in Type I, Type II and Type III.

Disposal: the refrigerant still has to come out

Here is a fact that surprises people: under 40 CFR 82.161, disposal of small appliances does not require technician certification. That does not mean the refrigerant can go anywhere. 40 CFR 82.155 says anyone recovering refrigerant from a small appliance for disposal must evacuate it to the levels in 82.156(b), using the right equipment.

Responsibility sits at the end of the chain. The final processor, such as a scrap recycler or landfill operator, must either recover any remaining refrigerant, or verify that it was recovered earlier with a signed statement or a contract. A signed statement includes the name and address of the person who recovered the refrigerant and the date it was recovered. The final processor must tell suppliers that refrigerant has to be recovered before delivery, and keep the statements or contracts for three years.

If all the refrigerant has already leaked out, the final processor needs a signed statement saying so. The rule says "leaked out" does not include losses caused by negligence or deliberate acts, such as cutting refrigerant lines.

Source: EPA Section 608, 40 CFR 82.155.

Built-in service points

Under 40 CFR 82.154(e), small appliances must be equipped with a process stub, which makes it possible to recover refrigerant. Other appliances, except those with only exempt refrigerants, must have a servicing aperture. This is the kind of fact that turns up as a quick multiple-choice question.

Hydrocarbons in household units

Some household refrigerators and freezers use hydrocarbon refrigerants. EPA's venting prohibition page and 40 CFR 82.154(a) list isobutane (R-600a) and R-441A as exempt from the venting prohibition in household refrigerators and freezers, among other listed uses, and propane (R-290) in specific listed uses. "Exempt from venting" is a regulatory status for those specific uses, not a statement that the gas is harmless to handle. Safety is a Type I test topic for a reason: follow your training and the manufacturer's instructions.

The Type I test format

Type I is the one section that may be offered by mail. Appendix D to Subpart F says organizations providing Type I certification only may choose an on-site format or a mail-in format. Know the trade-offs before you pick:

• The passing score for mail-in Type I tests is 84 percent, compared with 70 percent for closed-book tests.
• A mail-in Type I test cannot be used toward Universal certification.
• Programs using the mail-in format must still take measures to make sure each technician completes the test honestly, and must verify identity.
• Appendix D also says training material for the mail-in format may not include sample test questions that mimic the language of the certification test.

If you think you will want Universal later, a proctored Type I result is the one that counts. See Universal certification: is it worth it.

Source: EPA Section 608, Appendix D to Subpart F.

A Type I question to try

Then try the three Type I questions in the free quiz.

Frequently asked questions

What is a small appliance for the EPA 608 Type I?

A product fully manufactured, charged and hermetically sealed in a factory with five pounds or less of refrigerant, such as a refrigerator, freezer, room air conditioner, dehumidifier or drinking water cooler.

How much refrigerant must be recovered from a small appliance?

With recovery equipment made on or after November 15, 1993: 90 percent if the compressor works, 80 percent if it does not. With older equipment: 80 percent. Or evacuate to four inches of mercury vacuum.

What is the passing score for a mail-in Type I test?

84 percent, per Appendix D to Subpart F. A mail-in Type I test cannot be used toward Universal certification.

Do I need certification to dispose of a small appliance?

40 CFR 82.161 says disposal of small appliances does not require certification, but the refrigerant still has to be recovered to the required levels, and the final processor must recover it or verify that it was recovered.