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epa-608-type-1Small Appliance Scopehard

A household dehumidifier holds only 6 ounces of R-410A in its sealed circuit. What do the Section 608 rules require before that circuit is cut open for a repair?

Correct Answer

A) The charge must be recovered by a certified technician with certified recovery equipment, because there is no minimum charge exemption

Section 608 does not set a floor below which venting becomes legal. Knowingly releasing refrigerant during maintenance, service, repair, or disposal is prohibited regardless of how small the charge is, and small appliances have to be recovered to the applicable level using certified equipment. The de minimis allowance is narrow: it covers the trace amounts that escape during a good faith recovery attempt, such as what is left in a hose. It is not a permission slip for units with small charges.

Answer Options
A
The charge must be recovered by a certified technician with certified recovery equipment, because there is no minimum charge exemption
B
Nothing further, because a charge under one pound is treated as a de minimis release and needs no recovery step
C
The charge may be released as long as the technician records the amount that escaped and keeps the note with the job records
D
The charge may be released outdoors, because HFC refrigerants carry no ozone depletion potential and the venting rule reaches only chlorinated products

Why This Is the Correct Answer

The prohibition on knowingly venting applies to every covered appliance and every charge size, and the small appliance recovery requirements come with no lower charge threshold. A six ounce dehumidifier gets the same treatment as a five pound window unit: a certified technician recovers the charge with certified equipment before the tubing is opened.

Why the Other Options Are Wrong

Option B: Nothing further, because a charge under one pound is treated as a de minimis release and needs no recovery step

De minimis covers only the traces unavoidably lost during a good faith recovery effort, such as what stays in a hose. It is not a charge-size exemption, and reading it that way would legalize venting most small appliances in service.

Option C: The charge may be released as long as the technician records the amount that escaped and keeps the note with the job records

Recording a release does not make it lawful. Recordkeeping sits alongside the recovery requirement rather than replacing it, and no reporting option lets a technician open a sealed circuit to the air.

Option D: The charge may be released outdoors, because HFC refrigerants carry no ozone depletion potential and the venting rule reaches only chlorinated products

The venting prohibition was extended to substitutes, so it reaches HFCs such as R-410A as fully as it reaches the chlorinated refrigerants. Zero ozone depletion potential does not lift a refrigerant out of the recovery rules.

Memory Technique

De minimis is the drops in the hose, never the charge in the box.

Reference Hint

40 CFR 82.154 prohibits knowingly venting during maintenance, service, repair, or disposal; 82.156 sets small appliance recovery levels with no lower charge threshold.

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