HARDI Western Distributor Update

California Refrigerant Reporting Deadline Looms
HARDI Western Regional
Thermostat Recycling Mandates Persist

California Refrigerant Reporting Deadline Looms

UPDATE: The California Air Resources Board has extended the deadline to April 1.

For distributors with branches and locations within the state of California, tomorrow (March 1) marks the deadline for reporting 2011 refrigerant sales and transfers to the California Air Resources Board. Distributors are required to register each branch within the state, but reporting should be done on a company-wide basis. If you are having difficulty reporting, the Air Resources Board has made a training video which is accessible from the ARB website.

Reporting requirements also apply to reclaimers and facilities with systems carrying a refrigerant charge of 2,000 lbs or more.

HARDI Western Regional
Space still remains available for the HARDI Western Regional Meeting in Phoenix, AZ (March 11-13). Please, contact Stephanie Lingofelter to register for the event and to learn of limited remaining sponsorship opportunities. Among the topics being discussed:

• The Future of Incentives for HVACR Products and Systems.
• A Dozen Things You Can Do in HR that Will Save You a Million Dollars.
• HARDI Benchmarking: Regional & National Trends.
• R-22 Reductions? Dry-Ship Issues? Regional Standards? Navigate 2012's bumpy road of policy proposals and get a head start on Election 2012.

Thermostat Recycling Mandates Persist
All distributors with physical locations in California must act as a collection point for waste mercury thermostats and it has come to HARDI's attention the California Department of Toxic Substance Control is conducting pre-enforcement visits to HVACR wholesalers.

Failure to act as a collection point may lead to civil penalties of $25,000 per day, per violation. To avoid penalties, your branches must actively collect waste mercury thermostats. This includes having a recycling container, posting signage promoting the availability of the program at the location and ensuring staff is aware of the program is asked.

For recycling containers or promotional materials, please contact the Thermostat Recycling Corporation.

California Distributor Update

DTSC to Continue Inspections

The California Department of Toxic Substances Control (DTSC) has completed an initial survey of HVACR Distributors to monitor compliance with state policy mandating the recycling of mercury thermostats and found that some distributors are falling short of full compliance to state law. Distributors in California are required by law to serve as a collection point for mercury thermostats and DTSC is planning on increased enforcement in 2012.

HARDI has a formal partnership with the Thermostat Recycling Corporation (TRC), who can provide your business with all of the resources necessary to make sure you are in compliance with California state law.

If you would like to know if your business was inspected by the DTSC, please contact Jon Melchi.

New CARB Requirements

The New Year brings new requirements from the California Air Resources Board. Below are the new reporting requirements for Refrigerant Distributors and Reclaimers.

Beginning Jan. 1, 2012

Refrigerant Distributors must:

• Report previous year’s refrigerant sales or transfers by March 1
• Cover all California facilities that bought or received refrigerant from the wholesaler or distributor
• Include the following:
• The total weight, in pounds, of each type of refrigerant sold or transferred in the previous year, including:
• Transactions for eventual resale or delivery
• Shipments to certified reclaimers

Refrigerant Reclaimers must:

o Report previous year’s refrigerant sales or transfers by March 1

o Cover all California facilities that delivered refrigerant to the reclaimer

o Include total weight, in pounds, of each type of refrigerant that was:

§ Reclaimed or destroyed in California

§ Shipped out of state for reclamation or destruction

Illinois Mercury Thermostat Collection Act: Compliance Alert

As of July 1, 2011 all HVAC wholesale distributors must act as a collection point for waste mercury thermostats and utilize promotional materials provided by manufacturers.

Illinois EPA staff will begin conducting compliance assistance visits to Illinois HVAC wholesale distributors the week of July 25, 2011. The purpose of the visits are two-fold: 1) the agency wants to recruit wholesalers not yet participating in the program and 2) follow-up with wholesalers that have already ordered containers and assist them in managing and promoting the program.

If any of your locations in Illinois are not yet collecting thermostats and need collection container(s) or require promotional materials please contact TRC at 888-266-0550 or email trc@thermostat-recycle.org for assistance. More information on the TRC program is available at www.thermostat-recycle.org