A technician recovers R-22 into a cylinder and later opens the cylinder valve to empty it outdoors. Is this a violation?
Yes. Knowingly releasing a class I or class II refrigerant or a non-exempt substitute after it has been recovered is a violation of the venting prohibition, even outdoors and away from the appliance.
- No, the refrigerant was already out of the appliance
- Yes, releasing refrigerant after recovery is ventingCorrect answer
- No, as long as it happens away from buildings
- Yes, but only if the cylinder held over 15 pounds
Why “Yes, releasing refrigerant after recovery is venting” is correct
40 CFR 82.154(a)(3) says the knowing release of a class I or II refrigerant or non-exempt substitute after it has been recovered from an appliance is a violation of the venting prohibition.
Source: 40 CFR 82.154(a)(3)
Why the other answers are wrong
- No, the refrigerant was already out of the appliance — The rule specifically covers refrigerant released after recovery.
- No, as long as it happens away from buildings — Location does not matter; any knowing release is prohibited.
- Yes, but only if the cylinder held over 15 pounds — There is no cylinder-size threshold for this prohibition.
The source, word for word
The knowing release of a class I or class II refrigerant or a non-exempt substitute refrigerant after its recovery from an appliance is a violation of the venting prohibition.
What you can do with recovered refrigerant
Getting refrigerant out of the appliance does not end your duties. These are the legal ways forward.
- Return it to the appliance it came from, or to another appliance owned by the same person, without recycling or reclaiming it, unless the appliance is an MVAC or MVAC-like appliance (40 CFR 82.156(h)).
- Send it to a certified reclaimer. Used refrigerant generally has to be reclaimed before it can be sold to someone else (40 CFR 82.154(d)).
Why this is not de minimis
De minimis releases are small losses during a good-faith attempt to recover or recycle while following the required practices (40 CFR 82.154(a)(2)). Opening a cylinder to empty it is a deliberate release, so that protection does not apply. What may be released covers the exemptions.
Keep practicing
- EPA refrigerant recovery rules
- What may be released without breaking the venting ban
- Recover, recycle and reclaim compared
- What a shipped cylinder must show
- EPA 608 Core practice test
Unofficial, not affiliated with the EPA or any EPA-approved certifying organization. Questions are original practice written from public EPA material, not real exam questions.