A technician disconnects a set of gauges from a system, and a small amount of refrigerant escapes from the hose during that disconnection. Is this a violation of the Section 608 venting prohibition?
Not quite. The answer is C: No — this qualifies as a 'de minimis' release, an unavoidable small quantity released while connecting or disconnecting service hoses and gauges, which is not treated as a venting violation
The venting prohibition targets knowing release, and the rule carves out de minimis releases from good-faith recovery work — the small amount that escapes when a hose or gauge is disconnected. The carve-out is conditional: it only holds when the technician is following the required evacuation practices, using certified recovery equipment, and is properly certified. It is not a license for careless practices or for deliberately releasing a system's charge to avoid recovery.
Reference: 40 CFR Part 82 § 82.154(a)(2) (De minimis releases)
Checked against the official text
Read the eCFR text current through 2026-10-30 of § 82.154. Paragraph (a)(2) exempts de minimis releases that occur during good-faith recovery when the listed practices are followed, including use of certified recovery equipment and certified technicians.
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