Why Property Managers Need Refrigerant Tracking: Your Legal Responsibility Under New EPA Rules
As of January 1, 2026, EPA regulations require building owners to track refrigerant in equipment with 15+ pounds—covering virtually all commercial HVAC systems. Property managers are responsible for maintaining compliant records. Here's what you need to know.
Introduction
If you manage commercial property—office buildings, retail centers, apartment complexes, or mixed-use developments—a new EPA regulation took effect on January 1, 2026 that directly impacts your operations.
The regulation dropped refrigerant tracking requirements from 50 pounds to 15 pounds under 40 CFR Part 84 Subpart C. This seemingly technical change has a major practical implication: virtually every commercial HVAC and refrigeration system now requires detailed record-keeping and leak rate monitoring.
Under EPA regulations, equipment owners and operators are responsible for refrigerant compliance. As a property manager, you're acting as the owner's representative—which means you're on the hook for maintaining accurate records, tracking leak rates, and ensuring timely repairs.
The good news: with the right tracking system, refrigerant compliance is straightforward. Think of it as your compliance insurance policy.
What Equipment Is Now Regulated?
The 15-pound threshold captures most commercial building equipment:
- Rooftop HVAC units (most contain 15-50 lbs of refrigerant)
- Large split systems serving office/retail spaces
- Chiller systems for building cooling
- Walk-in coolers and freezers (restaurants, grocery stores)
- Commercial refrigeration (retail food service)
- Server room cooling units
In plain terms: If you manage a commercial building, you almost certainly have equipment that now requires EPA compliance tracking.
Your Legal Responsibility as Property Manager
Under 40 CFR Part 84 Subpart C, owners and operators of equipment containing 15+ pounds of regulated refrigerants must:
Every time refrigerant is added to a system, you must calculate the annual leak rate and compare it to EPA thresholds:
- • Commercial refrigeration: 20% annual leak rate triggers repair requirement
- • Comfort cooling (most HVAC): 10% annual leak rate triggers repair requirement
- • Industrial process refrigeration: 30% annual leak rate triggers repair requirement
When a system exceeds its threshold, you have 30 days to repair it (120 days if industrial process shutdown required). The EPA requires verification testing and follow-up inspections until the system is fixed.
You must document equipment details, all service work, refrigerant additions/removals, leak rate calculations, and repair history. Records must be kept for 3 years after equipment retirement.
While HVAC contractors service your equipment, you own the compliance obligation. Contractors provide the data; you're responsible for maintaining compliant records and ensuring repairs happen on schedule.
The Risk of Non-Compliance
Property managers face several risks when refrigerant tracking falls through the cracks:
Financial Exposure
EPA enforcement actions can result in civil penalties, with violations assessed per day of non-compliance. For properties with multiple systems—say an office building with 4-6 rooftop units—missing records or delayed repairs create cumulative exposure.
Operational Disruption
Non-compliance can trigger mandatory equipment shutdowns, tenant complaints, lease violations, and even insurance liability concerns.
Audit Preparedness
The EPA can audit refrigerant records at any time. Properties without organized documentation face significantly higher risk during inspections.
Most violations aren't intentional—they happen because busy property managers rely on manual processes that break down under real-world conditions.
Why Manual Tracking Fails
Many property managers try to track compliance with spreadsheets and paper files:
- ❌Contractor emails you a service report (maybe) — You're supposed to file it and manually calculate leak rates
- ❌Service happens but paperwork goes missing — No record = compliance gap
- ❌Leak rate calculations done by hand — Complex formulas, easy to make mistakes
- ❌No alerts when systems exceed thresholds — Repair deadlines get missed
- ❌Multiple buildings = scattered records — Different contractors, different systems, different filing cabinets
- ❌Staff turnover — New property manager inherits incomplete records
The reality: Manual refrigerant tracking is time-consuming, error-prone, and doesn't scale. For property managers overseeing multiple buildings or large portfolios, it's nearly impossible to maintain consistent compliance.
RefriTrak: Your Refrigerant Compliance Insurance Policy
RefriTrak is purpose-built for EPA refrigerant compliance, with features designed specifically for property management workflows:
- • Organize unlimited buildings and locations
- • Hierarchical structure: Portfolio → Building → Floor → Equipment
- • Filter and search across your entire property portfolio
- • Single dashboard view of all HVAC/refrigeration assets
- • System calculates leak rates automatically after every refrigerant addition
- • Instant alerts when EPA thresholds are exceeded
- • Repair deadline tracking with notifications
- • No manual formulas, no spreadsheet errors
- • Upload and store service invoices, warranty documents, and equipment manuals on the Units page
- • All records accessible for EPA audits
- • 3-year retention requirement handled automatically
- • Track valuable refrigerant inventory used for equipment recharges
- • Monitor cylinder locations, weights, and contents
- • Prevent loss of expensive refrigerant gas
- • Compliance records for refrigerant purchases and usage
- • Generate QR codes for every HVAC/refrigeration unit
- • Contractors scan codes during service calls
- • Give contractors secure PIN-protected access to view equipment details
- • Service records automatically linked to the correct equipment
- • Complete audit trail of all contractor activity
- • No more chasing paperwork or handwritten notes
- • Export audit-ready reports for EPA inspections
- • Filter by property, building, equipment type, or date range
- • Leak rate summaries and threshold monitoring
- • 3-year historical records at your fingertips
Frequently Asked Questions
Q: I'm not the building owner—I just manage the property. Am I still responsible?
A: Under EPA regulations, both "owners and operators" are responsible. Property managers act as the operator/owner's agent and are responsible for day-to-day compliance unless the building owner explicitly handles it themselves (rare).
Q: Can't my HVAC contractor just handle compliance for me?
A: No. Contractors service the equipment and provide documentation, but you (the property manager/building owner) are legally responsible for maintaining compliant records, tracking leak rates, and ensuring timely repairs. The EPA holds the equipment owner accountable, not the service contractor.
Q: What if my building only has a couple small HVAC units?
A: Most commercial rooftop units contain 15-35 lbs of refrigerant, which means they're regulated. Check the equipment nameplate or ask your HVAC contractor for the refrigerant charge capacity. Even a single-building property benefits from automated tracking—it ensures you're protected without manual work.
Q: What if I discover equipment has been leaking for years?
A: You should repair leaking systems immediately and begin proper tracking going forward. Fixing systems proactively reduces EPA exposure and prevents more serious violations. RefriTrak helps you establish compliant processes from day one.
Q: Does this apply to residential apartment buildings?
A: It depends on the equipment. Individual residential AC units typically don't meet the 15-pound threshold, but large centralized HVAC systems serving multi-family buildings often do. Walk-in coolers, commercial laundry equipment, or shared cooling systems may also be regulated.
Q: How do I know if my refrigerant is regulated?
A: The regulation covers refrigerants with Global Warming Potential (GWP) greater than 53. This includes virtually all common HFCs like R-410A, R-134a, R-404A, and R-407C. Your HVAC contractor can confirm which refrigerants are in your systems.