Enforcing Tamper-Resistant Refrigerant Regulations

2009 International Residential Code (IRC) and the International Mechanical Code (IMC) (updated in 2012) for Tamper-Resistant Refrigerant access valve port caps.

Residential, multifamily, and townhouse developments may be subject to significant fines stemming from the lack of enforcement of the 2009 changes to the International Residential Code (IRC) M1411.6 and International Mechanical Code (IMC) 1101.10 of the International Code Council (ICC), which require that all accessible access HVAC ports to be secured with tamper-resistant caps. 

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Access to the refrigerant ports of conditioning units is potentially dangerous for untrained persons, as any
sudden release of high-pressure refrigerant could come into contact with the skin or face and cause serious injury from freezing and the inherent tissue damage that it creates. Additionally, any such release of refrigerant in a location below grade that traps refrigerant and persons together in close proximity can cause severe injury or even death.

Of lesser frequency, but still of importance to note, is that anyone with a set of refrigeration gauges or refrigerant line set can connect to the access port and release the refrigerant for inhaling to achieve a “high” (or “huffing” as it is called), which is a current trend among teens, younger children, and even some adults. Tragically, many are seriously injured; some permanently and, even worse, some have died.

The refrigerant (or paints) themselves do not make one “high.” It is the lack of oxygen and the chemicals that are absorbed through the bloodstream that makes one feel intoxicated or worse. Early in my career, I was working on a refrigeration unit in a pit. The copper line broke off from the constant and repeated use while I was checking it for leaks, and refrigerant began to leak. I ran for the ladder and barely made it to the top where I was discovered by a janitor who was able to help me escape from the area to safety. I felt the effects of depleted oxygen levels from inhaling the refrigerant. From that moment on, I exercised much more caution whenever working with refrigerant systems, and I alerted others working in similar locations about the hazards and how to work under these conditions more safely. 

If you are interested in more information about the hazards of inhalation of aerosol products, please refer to the following website: http://www.inhalant.org.

The revised 2009 Code reads:

“International Mechanical Code (IMC) 1101.10 Locking access port caps. Refrigerant circuit access ports located outdoors shall be fitted with locking type tamper-resistant caps or shall be otherwise secured to prevent unauthorized access.” 

This is not to say that accessible access ports on other equipment should be ignored. Basically, if there is an access port on an HVAC unit easily within a person’s reach, it should have tamper-resistant caps installed. This mandate has not been enforced until recently. The large quantity of HVAC units installed throughout the United States along with the cost of the caps (approximately $30 per unit having two ports) would most certainly pose a significant financial expenditure to large building and property owners. This mandate has likely seen some resistance to its enforcement via lobbying at State level administrations to property owners and their supporters. 

Controlling access to HVAC equipment:

All condensing units and their refrigerant access ports are traditionally located with easy access for servicing, without consideration that this also provides easy access by unauthorized persons. As such, this can be an unnecessary liability for the property owner and his/her management team. Condensing units located on roofs may also fall into this category. 

The tamper-resistant requirement language indicates that “these locking caps restrict access to the refrigerant to only the person that has the matching key or keys for each cap.” This is generally intended to be the service technicians who normally work on the equipment. For multifamily properties with many pieces of equipment and several persons responsible for the HVAC equipment repairs, there may be a need for several keys because of varying brands of caps with their own matching keys. Implementation of a policy to limit the variety of locking cap keys by possibly limiting each site to only one brand of locking cap should be a consideration for property owners and management teams. In fact, this may also be incorporated with a refrigerant usage and recovery monitoring program which has been a requirement for some time now. 

The locking cap or other means mandate is not intended to apply to all systems; only to those that have accessible service ports are covered. Those units with access ports inside a secured cabinet, package units, or chillers are not affected.  According to the 2009 IMC Code Commentary, approved caps are ones that “cannot be removed without a specialty tool / key.” “Additionally, these locking caps restrict access to service personnel with a matching key.”

Harlan Miller, LEED Green Associate

Program Manager, EBI Consulting

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