Servicing a car's air conditioner for pay is clearly a Section 609 job. A tractor cab, a city bus or a refrigerated truck box is less obvious. This explainer answers one question from EPA's rules: which technician certification covers which vehicle air-conditioning system? It uses the definitions in 40 CFR Part 82, Subparts B and F, and EPA's own page on where Sections 608 and 609 overlap. Nothing here describes a rule change.
What counts as an MVAC?
Subpart B (Section 609) is built on two definitions in 40 CFR 82.32:
- A motor vehicle is "any vehicle which is self-propelled and designed for transporting persons or property on a street or highway, including but not limited to passenger cars, light duty vehicles, and heavy duty vehicles."
- Motor vehicle air conditioners are "mechanical vapor compression refrigeration equipment used to cool the driver's or passenger's compartment of any motor vehicle."
So the system has to cool the driver's or passenger's compartment of a self-propelled vehicle designed for transporting persons or property on a street or highway. The same definition then sets two things aside: it "is not intended to encompass the hermetically sealed refrigeration systems used on motor vehicles for refrigerated cargo and the air conditioning systems on passenger buses using HCFC-22 refrigerant."
Under 40 CFR 82.34(a) and (a)(2), no person repairing or servicing MVACs "for consideration" may perform "any service involving the refrigerant" unless trained and certified by a program EPA approved under 82.40, the Section 609 program.
What is an MVAC-like appliance?
Off-road machines fall under a second term, defined in 40 CFR 82.152. An MVAC-like appliance is "a mechanical vapor compression, open-drive compressor appliance with a full charge of 20 pounds or less of refrigerant used to cool the driver's or passenger's compartment of off-road vehicles or equipment." The definition adds: "This includes, but is not limited to, the air-conditioning equipment found on agricultural or construction vehicles. This definition is not intended to cover appliances using R-22 refrigerant."
That gives five conditions in the rule text: mechanical vapor compression, an open-drive compressor, a full charge of 20 pounds or less, cooling the driver's or passenger's compartment, and an off-road vehicle or equipment. R-22 systems are excluded.
Which certification can you use?
The rules give MVAC-like appliances a choice that MVACs do not have:
| System | Certification allowed | Where |
|---|---|---|
| MVAC, serviced for consideration | Section 609 (Subpart B) | 82.34(a)(2), 82.161(a)(1)(vi) |
| MVAC-like appliance | Section 609 (Subpart B) or Section 608 Type II | 82.161(a)(1)(v) |
For work that could be reasonably expected to violate the integrity of the refrigerant circuit (82.161(a)(1)), 40 CFR 82.161(a)(1)(v) states that technicians who maintain, service, or repair MVAC-like appliances "must either be certified as Type II technicians or be certified in accordance with 40 CFR part 82, subpart B." Unlike the MVAC part of 82.34(a), the MVAC-like part has no "for consideration" condition: it covers any person "repairing or servicing MVAC-like appliances" who performs service involving the refrigerant.
EPA's overlap page says the same thing in plain words: "People who service or repair MVAC-like appliances (e.g., farm equipment and other non-road vehicles) can choose to be certified under either the Section 609 program or the Section 608 Type II program." It adds a recommendation, not a requirement: "Due to similarities between MVACs and MVAC-like appliances, EPA recommends that technicians servicing MVAC-like appliances consider certification under Section 609."
What about buses?
EPA's overlap page separates buses by refrigerant. It states that "buses that use chlorofluorocarbon (CFC)-12 (also called R-12) are MVACs, but buses that use hydrochlorofluorocarbon (HCFC)-22 (also called R-22) are not MVACs or MVAC-like appliances, but rather are high-pressure equipment covered under the Type II Section 608 certification."
Neither source sorts other bus refrigerants. The definitions above are the rule text that applies.
What about refrigerated cargo?
The MVAC definition does not cover "the hermetically sealed refrigeration systems used on motor vehicles for refrigerated cargo." The MVAC-like definition covers only systems that cool the driver's or passenger's compartment. The pages we checked do not name a certification type for cargo refrigeration units. Under 40 CFR 82.161(a)(1), for a person who could be reasonably expected to violate the integrity of the refrigerant circuit, the Section 608 type depends on the appliance: Type I for small appliances, Type II for medium-, high- or very high-pressure appliances "(except small appliances, MVACs, and MVAC-like appliances)," and Type III for low-pressure appliances.
Disposal is different
Under 40 CFR 82.161(a)(1)(vii), "Persons who dispose of small appliances, MVACs, and MVAC-like appliances are not required to be certified." EPA's overlap page also notes that procedures involving MVACs that are not covered by Section 609, "such as the disposal of MVACs and the purchase of refrigerant for use in MVACs, are covered by Section 608."
Where to get each certification
Section 609 certification comes from an EPA-approved program. EPA's program page states that technicians "must be trained by an EPA-approved program and pass a test," and lists the approved programs. Its overlap page adds that the Section 609 tests "are different from the Section 608 technician certification tests."
Study with goraedu
Our EPA 609 study guide walks through Subpart B with the rule text, and the EPA 609 certification checker applies 82.34 to your situation. If you are going the Type II route, see the EPA 608 Type II practice test. All of our questions are our own, written from the regulation.