While recordkeeping is critical, it alone will not ensure compliance. Before compliance became a greater concern, each organization used its own methods and procedures when working with refrigerants. Typically, this meant each department had carved out its own little area of responsibility and implemented its own work processes geared to meet its particular needs. Seldom did organizations set up one system for all departments.
To ensure the entire organization complies, managers must examine and standardize all work processes and procedures involving the use of refrigerants. And they must replace or modify procedures that fail to comply. Where no set work processes or procedures exist, managers need to develop new ones and ensure personnel receive training in their use.
The most successful programs have designated one person as compliance manager. This person develops, implements and oversees the operation of the compliance plan across all departments and units in the organization.
But simply designating someone to be compliance manager without giving him or her the authority and funding needed to implement and operate the program will only lead to program failure. The temptation to simply continue working the same as in the past will be too strong.
Refrigerant Compliance: EPA and the Clean Air Act
How to Recycle Ozone-Depleting Refrigerants
Refrigerant Management: Standardize Processes and Procedures
