Freon Detection Requirements

There is a common misconception that synthetic refrigerants are exempt from all regulatory burden. Many end users are attracted to Freon refrigerants because of a desire to avoid PSM, RMP, and the many requirements associated with operating an ammonia refrigeration system: machinery room ventilation, detection, emergency response, mechanical integrity, etc.

While we have previously summarized the Federal and state regulations that govern synthetic refrigerants, it is important to emphasize that all Freon systems are required to be equipped with refrigerant leak detection. Here is a synopsis of the current codes and regulations that require refrigerant leak detection for Freon refrigeration systems installed in California:

California Mechanical Code

• All non-machinery rooms with an evaporator must have a refrigerant detector that alarms at 1,000 ppm [2016 CMC §1104.4(4)]
• Machinery Rooms must have one or more refrigerant detectors that activate an alarm at concentrations not exceeding 1,000 ppm. [2016 CMC §1106.4]
  Note: A second alarm level is required for select refrigerants, but is not required if the refrigerant is classified as A1 or B1 (non-flammable).

Air Resources Board Refrigerant Management Program

Systems exceeding 2,000 lbs of refrigerant must comply with the following:

• An automatic leak detection system must be installed to detect leaks from all portions of the system(s) located indoors [Title 17 CCR §95385(a)(2)]
• Leak detection systems must be calibrated per manufacturer’s recommendations [Title 17 CCR §95385(a)(5)]
• Leak detectors must accurately detect concentrations of 10 ppm [Title 17 CCR §95385(a)(5)(A)]
• Leak detectors must alert a facility operator if the concentration exceeds 100 ppm [Title 17 CCR §95385(a)(5)(B)]

2 responses to “Freon Detection Requirements”

1. Alan Shirley says:

   October 13, 2020 at 6:10 am

   What code would require monitoring for a leak in a storage area?

   Reply
   • Peter Thomas says:

     October 13, 2020 at 8:10 am

     There are several codes that could apply, depending on where the facility is located:
     1. Title 17 CCR §95385
     2. ANSI/ASHRAE 15-2019 §7.2.2(c)
     3. 2021 IMC §1104.2.2(3)
     4. 2018 UMC §1104.4(4)

     Reply