The Montreal Protocol is an international treaty established in 1987 that aims to decrease the production and use of ozone-depleting substances (ODS). The Kigali Amendment was adopted in 2019 and ratified by the United States in 2022. This amendment includes provisions to reduce the production and use of hydrofluorocarbons (HFCs) due to their high global warming potential (GWP).
HFCs are chemicals used in cooling equipment such as air conditioners and refrigerators, as well as in aerosols, foams, and other products. The United States enacted the American Innovation and Manufacturing Act (AIM) in 2020, which gave the Environmental Protection Agency (EPA) the authority to phase down the production and use of certain HFCs.
States can implement regulations to align with, or be more stringent than, federal regulations. In January 2025, the New York Department of Environmental Conservation (NYSDEC) amended the HFC Standards and Reporting Regulation (6 NYCRR Part 494), also known as Part 494, including the requirements for a Refrigerant Management Program (RMP) outlined in Subpart 2. The amended regulation sets prohibitions on newly manufactured products and systems with a high GWP; establishes equipment labeling, registration, and annual reporting deadlines based on the quantity or charge capacity of the refrigerant; and outlines leak monitoring and repair measures.
Part 494 sets prohibitions on newly manufactured products and systems, such as commercial refrigerators and building air conditioning systems, which contain HFCs with a high GWP. New York prohibitions incorporate federal prohibitions and include additional products and equipment such as air conditioning chillers with an EPA 100-year GWP (GWP100) above 20, and commercial heating, ventilation, and air conditioning (HVAC) equipment with an EPA GWP100 above 10. Depending on the product or equipment, the prohibition compliance date ranges from January 1, 2026 to January 1, 2034. More information about prohibited products and deadlines can be found in 6 NYCRR 494-1.4. The manufacture and sale of bulk regulated substances, as defined in 6 NYCRR 494-1.3, is also prohibited, and the prohibition date depends on the GWP100 of the substance.
In addition to prohibitions, New York’s regulation establishes labeling, registration, and annual reporting deadlines for owners or operators of commercial equipment with more than 50 pounds of refrigerant through the RMP. Owners of “large” equipment with a refrigerant charge capacity of 1,500 pounds or more should have labeled and registered the equipment with the NYSDEC by June 1, 2025. “Medium” equipment with a refrigerant charge capacity between 200 and 1,499 pounds should be labeled and registered by June 1, 2026, and “small” equipment with a refrigerant charge capacity between 50 and 199 pounds should be labeled and registered by June 1, 2028. Annual reports are due on March 31 beginning the year following the registration deadline. More information about refrigerant management compliance deadlines can be found in Trinity Consultants’ May 22, 2025, news post.
Leak monitoring depends on the size of the equipment. For large refrigeration equipment, the installation of automatic leak detection systems (ALDS) is required by June 1, 2025. If the equipment was installed after June 1, 2025, the installation of an ALDS is required within 30 days of equipment installation. Medium equipment must be inspected quarterly or have an ALDS, and small equipment should be inspected annually or have an ALDS. More information can be found in 6 NYCRR 494-2.3. Leaks must be repaired within 14 days of discovery, although this timeline can be extended if a certified technician to complete the repair, or the parts needed, are not available.
How Does This Affect Science and Technology Buildings?
Buildings rely on HVAC systems to maintain temperature and indoor air quality (IAQ) within their structures. Temperature maintenance is especially important in buildings where science and technology-related work is taking place since laboratory and computing equipment generate heat. The RMP requirements apply to these buildings, so building owners should take an inventory of equipment that may be regulated, register and label applicable equipment, and follow leak monitoring procedures. If older equipment in a building requires repair, the owner or operator might face challenges obtaining necessary materials for equipment repair due to prohibitions on bulk regulated substances, even though exemptions exist if they are used in servicing equipment.
Tenants in science and technology buildings might be subject to RMP requirements if they have cold rooms in their facilities, depending on the size and type of cold room. Laboratory refrigerators and freezers contain less than 50 pounds of refrigerant, so they are exempt from labeling, registration, and leak monitoring. However, the servicing and repair of older cold storage might be hindered due to the prohibition on bulk regulated substances.
When purchasing secondhand cold storage, the refrigerant used in the equipment should be checked to confirm it is not a regulated substance. The NYSDEC created a Regulated Substance Key that includes the most common regulated substances. Sustainable cold storage is recommended because it is likely to use refrigerants with a lower GWP that are not subject to federal or New York regulatory prohibitions.
For additional information on Part 494 and the RMP, and how these requirements could apply to your facility, contact us!
This blog was written by Rae Moore, Safety Partners’ Senior Quality, Research, and Training Specialist.
