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First of all, in most cases laws restrict behavior, they don't allow behavior. Writing laws that allow certain things would be near impossible to enforce - since the implication would be - that anything not allowed - is illegal. That is way too open-ended and vague. In regard to 134A, there has never been a law to restrict the sale of it. So, it has nothing to do with "new" laws allowing it. In regard to the who can, who cannot? I didn't make any claims about it either way. However, what you claim in not necessarily the "end of the story" from the EPA. From what I can tell - the word "technician" does not legally apply to someone servicing an AC system that uses 134A. Their regs state: Technicians who repair or service CFC-12 and HFC-134a motor vehicle air conditioners must be trained and certified by an EPA approved organization. Note their use of the word "technician." It says nothing about what exactly IS a technician. If you are a plumber, or an accountant, you are NOT techincally a technician - so can you then legally work on your own AC system? Answer is - even people at the EPA don't seem to be sure. They have changed the official definition of the word "techinician" at least three times in the refrigerant documents. EPA wrote: " The March 12, 2004 final rule was not intended to either mandate section 608 technician certification for those maintaining, repairing, or servicing appliances using substitutes that do not consist of a class I or class II ODS or to restrict the sale of substitutes that do not contribute to the depletion of the stratospheric ozone layer, such as pure HFC and PFC substitutes." Note that the EPA is still arguing about 134A and is most cases, shows it as NOT a Class I or Class II ODS refrigerant. At to these quotes: "Standard 700-1993 that do not consist in part or whole of a listed class I or class II ozone-depleting chemicals will not be included in the new appendix, namely R-23; R-32; R-125; R-134a; and R-143a." Also from the same document it names what is: " . . . an ODS, namely R-11; R-12; R-13; R-22; R-113; R-114; R-123; R-124; R-401A and B; R-402A and B; R-405A; R-406A; R-408A; R-409A; R-411A and B; R-412A; R-500; R-502; R-503; and R-509 " Now - the EPA does not include 134A as a Class I or Class II ODS refrigerant. And - look at the definition (one of many) for what a technician is: "Technician means any person who performs maintenance, service, or repair that could be reasonably expected to release class I or class II refrigerants from appliances, except for MVACs, into the atmosphere." So, the upshop appears to be - if you are working on an AC system that uses 134A, your are NOT classified as a technician, and therefore don't need any sort of licensing . . . maybe. EPA also wrote - in a attempt to clear up some confusion : "March 12, 2004 final rule stated that the amended definition of technician could be misinterpreted to mean that technicians servicing and maintaining MVACs must also have section 608 technician certification. "
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