Is the EPA 608 Type I Test Open Book?

Only Type I can be taken outside a proctored, closed-book setting. Organizations that certify only Type I may give the test in a mail-in format (Appendix D to 40 CFR Part 82, Subpart F, section a). Types II, III and Universal must always be closed-book and proctored in a secure environment.

The mail-in Type I has an 84 percent pass mark instead of 70 percent, and it cannot be used toward Universal. A Core section taken open-book cannot be used toward Universal either (EPA: Certification Requirements).

Appendix D sets the standards every certifying program must meet. On test format and grading, it says:

• Organizations providing Type I certification only may choose either an on-site format or a mail-in format.
• Type II and Type III require a closed-book, proctored test given in a secure environment.
• Universal requires a closed-book, proctored test, or series of tests, in a secure environment. Mail-in Type I tests cannot be used toward Universal.
• Type I is a closed-book exam when it is taken as part of a Universal certification.
• The pass mark is 70 percent for closed-book tests and 84 percent for mail-in Type I.
• Mail-in programs must take steps to make sure each technician completes the test honestly, and must verify the test-taker's identity, for example with a driver's license or passport.
• Training material sent with a mail-in test must not include sample questions that mimic the wording of the real test, and all mail-in material is subject to EPA review.

Both formats lead to the same Type I certification, and the card carries no expiry date either way. The difference is what you can build on afterwards.

Many approved organizations now offer Type I online, and EPA's program list marks those with remote or online testing. 'Online' does not tell you which format you are getting. Some online Type I tests are remotely proctored and closed-book, and some may be run under the mail-in style rules for Type I-only programs.

Before you pay, ask the provider two questions. Is this test proctored and closed-book? Will it count toward Universal if I later pass Type II and Type III? If the answer to the second is no, you are getting the 84-percent, Type-I-only format.

Every Type I test includes the 25-question Core section. EPA states that a Core section taken as an open-book exam cannot be used to get Universal certification. The Core must be taken proctored (EPA: Certification Requirements).

So a technician who passes an open-book Type I and later wants Universal will need to pass Core and Type I again under closed-book, proctored conditions, along with Types II and III. If you expect to work on split systems, rooftop units, supermarket refrigeration or chillers, it is usually simpler to take a proctored test from the start.

Type I covers only small appliances: products fully manufactured, charged and hermetically sealed in a factory with 5 pounds or less of refrigerant (40 CFR 82.152). The definition lists household and commercial refrigerators and freezers, medical and research refrigeration, room air conditioners including window and portable units and packaged terminal air heat pumps, dehumidifiers, under-counter ice makers, vending machines and drinking water coolers.

EPA has not said, in the rule, its Q&A or its certification pages, whether a ductless mini-split or other split system is a small appliance. Read against the definition, a split system whose indoor and outdoor units are joined on site with line sets is not fully manufactured and hermetically sealed in a factory, even if the outdoor unit ships pre-charged. EPA's 2016 rule also treats a condensing unit or line set as a component, not an appliance. On that reading it is not a small appliance whatever its charge, and with R-410A or another high-pressure refrigerant it falls under Type II (40 CFR 82.161(a)(1)(ii)). EPA's Q&A does say that installing a mini-split needs Section 608 certification when it means adding or removing refrigerant or connecting or disconnecting hoses or pre-charged lines. Note also that disposing of small appliances does not require certification at all (40 CFR 82.161(a)(1)(vii)), though the recovery equipment used must still meet EPA standards.

Open-book or not, you will need to know the material. EPA's test topics for Type I are short:

• The definition of a small appliance.
• Recovery levels (40 CFR 82.156(b)): with recovery equipment made before November 15, 1993, recover 80 percent. With equipment made on or after that date, recover 90 percent if the compressor works, or 80 percent if it doesn't. Or evacuate to 4 inches of mercury vacuum.
• Using pressure and temperature to identify a refrigerant and detect noncondensables.
• System-dependent (passive) recovery when the compressor is dead: install both high- and low-side access valves, heat and sharply strike the compressor, or use a vacuum pump with a non-pressurized container.
• Running a working compressor during passive recovery.
• Removing solderless access fittings at the end of service.
• R-134a as the likely substitute for R-12.
• Decomposition products of refrigerants at high temperatures.