AIM ACT FAQs
The EPA’s AIM Act is filled with complex requirements, which can be challenging for
Fire Equipment Distributors to navigate in day-to-day operations.
We are here to help clear any confusion. Below are a few popular FAQs we’ve been asked by others in our Industry:
The EPA classifies any discharge as a “release/emission event.” But not all events are treated the same.
Fines can happen if:
• The discharge was intentional (venting)
• Records are falsified to hide it
Fines don’t usually happen if:
• It was accidental during servicing or maintenance
• The release was caused by equipment failure
No, not required for Fire Suppression, despite FM-200 and FE-25 being HFCs. Automatic Leak Detection Sensors are only required for the Refrigeration Industry.
Reference: The AIM Act : Automatic Leak Detection Requirements for Appliances Containing Hydrofluorocarbons and Certain Substitutes
(40 CFR part 84 subpart C)
Yes, cylinders with recycled agent need to be labeled. There’s no single mandated type of label, but here is an example:
RECOVERED AGENT
HFC-227ea (FM-200)
RECYCLED MATERIAL
PROPERTY OF: [Company Name]
Yes. Under the AIM Act reporting requirements, recovered gas that is contaminated is still counted as part of your inventory.
It is important to note that if you have any contaminated recovered gas in your inventory on December 31st, it must be included in your EOY Inventory Report
No. Those Quarterly HFC Recycling Reports are only for Fire Suppressant Recyclers.
If you are only performing service work by taking out/installing system cylinders, your scope of work does not fall under the EPA’s definition of a Fire Suppressant Recycler.
This lightens your reporting burden, since those quarterly reports also must be Audited.
Yes. Regardless of who you sell your HFCs to, it must be added to the EOY HFC Sales Report.
Under the AIM Act HFC reporting framework, sales are reportable based on movement of regulated HFCs, not whether the buyer is an end user.
Yes. Maintaining documentation such as Lab Reports supporting the integrity of HFCs placed back into the market are required.
HFC Recycling Reports must be Audited by a third-party public accountant by May 31 of the following year.
HALON HERALD
By: Wesco
A monthly electronic newsletter offering the most complete coverage of the fire suppression industry – companies, products and people – published since 2004.