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epa-608-type-1Recovery Requirements & Techniqueshard

A vending machine's factory sealed refrigeration deck is slid out of the cabinet in one piece with its circuit never opened, and that old deck is now going to a scrap hauler. What does Section 608 require?

Correct Answer

C) The refrigerant must be recovered before that deck is turned over for disposal

There are two separate triggers for recovery on a small appliance: opening the sealed circuit, and disposing of the unit. This job avoided the first one entirely by pulling the deck out whole, but the second one applies the moment the deck is handed off for scrap. Somebody has to recover the charge before that happens, and on a factory sealed deck under five pounds that somebody is a Type I certified technician. Telling the hauler about the charge does not transfer the duty, and there is nothing about this unit that calls for Type II.

Answer Options
A
Nothing further, because the sealed circuit was never opened during the removal
B
Nothing further, provided the hauler is told that a charge is still inside the deck
C
The refrigerant must be recovered before that deck is turned over for disposal
D
The deck must be tagged and stored indoors until a Type II technician can be found

Why This Is the Correct Answer

Disposal is an independent trigger for recovery, so a sealed unit that was never opened during service still has to have its charge removed before it is discarded. The deck is a factory assembled, factory charged, hermetically sealed unit under five pounds, which makes it a small appliance and puts the work within Type I certification. Recovery happens before the deck leaves for scrap, not after it arrives.

Why the Other Options Are Wrong

Option A: Nothing further, because the sealed circuit was never opened during the removal

Avoiding the first trigger does not avoid the second. Disposal brings its own recovery requirement whether or not the circuit was ever opened during the swap.

Option B: Nothing further, provided the hauler is told that a charge is still inside the deck

Passing along a warning is not recovery, and the duty stays with the person disposing of the appliance rather than moving to whoever hauls it away.

Option D: The deck must be tagged and stored indoors until a Type II technician can be found

A factory sealed deck holding under five pounds is a small appliance, which is squarely Type I work. Nothing about it requires a Type II technician.

Memory Technique

Two doors into the same room: opening it, or throwing it out.

Reference Hint

Recovery is required before a small appliance is opened and, separately, before it is disposed of.

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