The short answer
The owner or operator keeps the records; the technician gives the owner the paperwork for each service event. The federal floor is 3 years, and full-charge information for a covered appliance is kept until 3 years after the appliance is retired. Which appliances are covered depends on the refrigerant: 50 lb or more of ODS under §82.157, or 15 lb or more of HFC / high-GWP substitute under §84.106 (from January 1, 2026). Smaller appliances still generate records — just under a different paragraph.
Which appliances trigger recordkeeping
| Rule | Appliances covered | Since |
|---|---|---|
| §82.157 (ODS) | Full charge of 50 lb or more of a Class I or Class II refrigerant (or blend containing one) | January 1, 2019 (ODS-only since April 10, 2020) |
| §84.106 (HFC) | Full charge of 15 lb or more of a regulated substance or a substitute with GWP over 53 | January 1, 2026 |
| §82.156(a)(3) (disposal) | Full charge more than 5 lb and less than 50 lb, when refrigerant is recovered for disposal | January 1, 2018 |
Two carve-outs to know: §84.106 does not apply to appliances containing solely an ODS refrigerant (those stay under §82.157), nor to appliances in the residential and light-commercial air-conditioning and heat-pump subsector. And remember: these are federal minimums — some states are stricter (California's Refrigerant Management Program, for example, requires covered large refrigeration facilities to keep records 5 years). Check your state's overlay before relying on the federal numbers.
What each service record must contain — §82.157(l)(2) / §84.106(l)(2)
For every installation (HFC rule), maintenance, service, repair, or disposal of a covered appliance, when applicable:
- (i) Identity and location of the appliance
- (ii) Date of the work performed
- (iii) Part(s) of the appliance worked on
- (iv) Type of work performed for each part
- (v) Name of the person who performed it
- (vi) Amount and type of refrigerant added — or, for disposal, removed
- (vii) The full charge of the appliance
- (viii) The leak rate and the method used to determine it — not applicable when disposing of the appliance, following a retrofit, installing a new appliance, or when the addition qualifies as a seasonal variance
If someone other than the owner or operator does the work, that person must provide the owner or operator a record with items (i)–(vi) — the tech's paperwork is the owner's record. That handoff is the single most-testable sentence in this whole page.
The rest of the file: full charge, inspections, tests, plans
- Full-charge record (§82.157(l)(1) / §84.106(l)(1)): owner/operator identity, appliance address, full charge and how it was determined, any revisions (how determined, and when), and — under §84.106 — the installation date. Kept until 3 years after retirement.
- Leak-inspection records: date of inspection, method(s) used, a list of each leak's location, and a certification that all visible and accessible parts were inspected.
- Verification-test records: dates and results of all initial and follow-up tests, including appliance location, the repaired leaks tested, the test type(s), and results.
- Retrofit or retirement plans and any extension requests submitted to EPA, plus copies of EPA reports and responses.
- Mothballing records: when the appliance was mothballed and when refrigerant was next added (deadlines suspend while mothballed).
- Automatic leak detection records: installation and annual audit/calibration, each date the system flagged a leak, and the leak's location.
Disposal records (5–50 lb) and sales invoices
Disposal — §82.156(a)(3). Technicians recovering refrigerant from appliances with a full charge of more than 5 and less than 50 lb for disposal must keep, for 3 years: (i) company name, appliance location, date of recovery, and type of refrigerant recovered for each appliance; (ii) total quantity by type recovered from all disposed appliances in each calendar month; and (iii) quantity by type transferred for reclamation and/or destruction, to whom, and when.
Sales — §82.154(c)(3). Sellers of ODS or non-exempt substitute refrigerant must keep invoices showing the purchaser's name, date of sale, and quantity purchased — plus the buyer's proof of certified-technician employment where that is the basis of sale — for 3 years. (Small MVAC cans under the retail exception and exempt substitutes are excluded.)
Reports to EPA are not records you just file away: an appliance that leaks 125% or more of its full charge in a calendar year must be reported to EPA by March 1 of the following year — §82.157(j) at 50 lb and up for ODS, §84.106(j) at 15 lb and up for HFC — and copies of submitted reports stay in the file.
Drill it
Recordkeeping questions reward anyone who can name the trigger size, the keeper, and the 3-year clock. Drill the leak math that generates these records, then take the mixed exam.