Evaluating Software for EPA Record-Keeping, Part 1
Since the Clean Air Act of 1990, facility owners and managers have been faced with the monumental task of establishing and maintaining refrigerant use and service records. The Environmental Protection Agency (EPA) requires industry professionals to keep extensive records and submit detailed reports of refrigerant use, service, maintenance and disposal, even when contractors are hired to service equipment. Refrigerant documentation and record-keeping is the most important step to compliance. The EPA may fine anyone who fails to comply with regulations up to $27,500 per day; levy up to five years imprisonment for noncompliance; and up to two years imprisonment for improper record-keeping or falsification of records. The bottom line: The U.S. EPA requires that refrigerant users keep complete and accurate records.
In fact, the nine EPA regions have budgets for on-site inspections of suspected refrigerant violations. Passing a refrigerant inspection or preventing one from taking place requires that you instantly and consistently demonstrate good refrigerant management practices. It is important to realize that EPA is not looking for organizations it knows will pass an inspection easily -- it is looking for violators. Keeping detailed records is the fastest way to account for every ounce of refrigerant and much cheaper than risking the results of a discovered violation.
Software Record-Keeping ToolsManual refrigerant record-keeping can satisfy legal requirements, but it is prone to inaccuracies and takes time to reconcile. Some managers set up spreadsheets to log usage, but these can be limited and inflexible. Some organizations use internal information systems to develop a custom database for tracking refrigerants and usage. This can, however, be a waste of time and resources. In-house computer personnel usually do not understand refrigerant regulations, internal refrigerant policies and actual working practices well enough to develop a comprehensive system. Learning such information and processes can take months; the time and money might be better used elsewhere.
Commercial software packages are available to help you solve your refrigerant tracking challenges. Using a program developed by someone else can be a cost-effective way to take a big step toward compliance. Moreover, learning how a professional software program tracks refrigerants can provide you with ideas to better manage your own refrigerants.
Once you have decided to seek out a refrigerant tracking program, there are a number of factors to consider:
Platform. What kind of computer do you have? What kind do you expect to upgrade to next? It is not uncommon for service departments to have older, hand-me-down computers that were cast off by other departments upgrading to bigger, faster and better machines. Or maybe you are one of the lucky ones who is using, or expecting to start using, one of the new palm-top computers. They are useful for gathering on-site data to take back to the office to transfer information into the main database. Consider what your hardware upgrade path is likely to be and select software programs that will be able to keep up.
Network options should also be considered. Are your computers connected to a local area network (LAN)? Do you expect to have more than one person entering records and data? You will want to be sure the program you select offers the appropriate amount of security. For example, multiple users should need a password to log in data. This will provide more precise tracking on what your technicians are doing with the refrigerants.
Operating System. Certainly, you will want any software program you choose to be designed to run on the operating system you have. If you still have Windows 3.1 but expect to upgrade to Windows 95/98 or 2000 soon, you should plan to upgrade your record-keeping software as well.
Training. Will you or your staff require any specialized training to learn your new software? Is training even available? Consider how adept you and your staff are with computers. Training can be a smart investment to make sure the software is set up and used correctly from the start.
Support. Is telephone technical support available? No matter how easy a program is to learn and use, there always will be questions about some of the infrequently used features. Tech support can be a lifesaver. Support also includes upgrades to the software at reduced costs. Check to see if the company has a track record of previous releases and updates as the regulations change. This will ensure that you stay in compliance as the rules change.
Setup. When you begin using a refrigerant tracking program, there will be an initial setup phase. This involves entering information about all of your industrial process equipment that contain refrigerants and your current stockpile of refrigerants. For large operations, this can be a major project. However, once setup of the initial data is complete, recording usage and other refrigerant events can be a short daily or weekly event that is handled easily by a technician or data-entry clerk. Find out if the program you are considering has any suggestions, tips or tools for collecting and entering the initial setup data.
User-Friendly SoftwareEven with professional training and proper setup, the program you choose should be relatively easy to use. A refrigerant tracking software program should include features that reflect the way you do business. It should allow you to track cradle-to-grave refrigerant transactions from initial purchase through final disposal or use, including:
- Multiple building owners or customers.
- Usage, type, location and status of all refrigerant cylinders.
- Refrigerant usage rates and alerts.
- Refrigerant by type, cylinder or appliance.
- Refrigerant transactions, including purchases, transfers, disposals, sales and inventory.
- Recovery and recycling equipmentmaintenance and filter change records.
- Refrigerant appliance inventory.
Other software features you will want to include are comprehensive equipment upgrade and retrofit history; notes fields for additional information; a service dispatch system that generates service orders; service records that capture entire service procedures; and leak test and repair records. You also will want the ability to maintain and store service technician records, including certification information, comprehensive technician training history and vendor records, including addresses and phone numbers.
In my next column, I will discuss in more detail what your software program should do for your record-keeping procedures and how to integrate the system.