The Repair Passed. You're Not Done — the Leak-Inspection Schedule Just Started

Most contractors know the front half of the story by now. A refrigerant addition pushes the leak rate over the threshold — 20% for commercial refrigeration, 30% for industrial process, 10% for comfort cooling and everything else — and the 30-day repair clock starts. You find the leak, you fix it, you run the initial verification test, you run the follow-up verification test, it passes.

And then most shops file the paperwork and mentally close the ticket.

The regulation doesn't. The day that follow-up verification test passes, 40 CFR § 84.106(g) puts the appliance on a mandatory leak-inspection schedule — every three months or every year, depending on what the appliance is and how much refrigerant it holds. The schedule runs until the appliance proves, through the same leak-rate math that got it in trouble, that it's clean. Miss an inspection and you've traded a repaired leak for a fresh recordkeeping violation on a unit the EPA already has a reason to look at.

Here's the whole system: which schedule applies, when the clock starts, how you get off it, the one exemption, and the record every inspection has to leave behind.

The Trigger: One Exceedance, One Schedule

The inspection duty in § 84.106(g)(1) attaches to "any refrigerant-containing appliance exceeding the applicable leak rate" in § 84.106(c)(2). That's the same trigger as the repair clock itself — there is no separate, higher bar. If the unit blew its threshold, the schedule applies.

The split works like this:

Quarterly — the big commercial and industrial systems

Supermarket racks, cold-storage systems, process chillers — if it's commercial refrigeration or industrial process refrigeration and the full charge is 500 pounds or more, the cadence is quarterly.

Annual — everything else that exceeded

Two paragraphs carry the annual schedule, and together they cover the rest of the covered universe:

• § 84.106(g)(1)(ii) — commercial refrigeration and IPR appliances with a full charge of 15 up to (but not including) 500 pounds: once per year.
• § 84.106(g)(1)(iii) — comfort cooling appliances and anything else not covered by the first two paragraphs: once per year.

Read (g)(1)(iii) carefully, because it's the paragraph that covers most of a small contractor's book. A 40-ton rooftop unit with a 90-lb charge is comfort cooling — annual. A refrigerated trailer is not commercial refrigeration or IPR under the subpart's definitions, so it lands in "other" — annual. There is no quarterly tier for comfort cooling at any charge size. The 500-lb quarterly line only exists inside commercial refrigeration and IPR.

When the Clock Starts — and Why the Verification Test Is the Anchor

Both schedules run "after the date of a successful follow-up verification test." That date — not the exceedance date, not the repair date — is the anchor for every inspection due date that follows.

That detail does real work. The verification-test sequence already matters because it closes out the repair; now it also matters because it starts the inspection calendar. A follow-up test that never gets performed — or never gets documented — leaves the appliance with an exceedance on record and no anchor date, which is an open compliance question you don't want an inspector resolving for you.

The Exit: The Appliance Has to Prove It's Clean

The schedule is not permanent, but you don't exit it by feel. Both paragraphs use the same mechanism: the owner or operator must demonstrate through the § 84.106(b) leak-rate calculations that the appliance has stayed at or under its threshold —

• Quarterly systems: four quarters in a row.
• Annual systems: one year.

Notice what the demonstration runs on: the leak-rate calculation "required under paragraph (b)" — the math you do at every refrigerant addition. A clean year means the service history proves it. That's also consistent with § 84.106(d)(2), which presumes a repair successful if, over the 12 months after the successful follow-up verification test, there's no further refrigerant addition or the required inspections find no leaks.

The exit isn't a calendar event — it's a demonstration. The appliance leaves the schedule when its own service records prove four clean quarters or one clean year. If it exceeds again, you're back at day one: new repair clock, new verification tests, new inspection cycle.

What an Inspection Actually Is

Section 84.106(g)(2) and (g)(3) define the inspection itself, and they're refreshingly practical:

• Who: a certified technician.
• How: "method(s) determined by the certified technician to be appropriate for that refrigerant-containing appliance." Electronic detector, bubble test, UV dye — the regulation defers to your tech's judgment. What it doesn't defer on is scope.
• Scope: all visible and accessible components must be inspected. The exceptions in (g)(3) are narrow and concrete: components that are insulated, under ice, underground, behind walls, or otherwise inaccessible; anywhere personnel would have to be elevated more than two meters above a support surface; and components that site personnel determine are unsafe to inspect.

That "visible and accessible" phrase isn't just scope language — it's the exact phrase your inspection record has to certify. More on that below.

The One Exemption: Automatic Leak Detection

Section 84.106(g)(4) waives the quarterly/annual inspections for appliances — or portions of appliances — continuously monitored by an automatic leak detection system that is audited or calibrated annually and that meets the ALD requirements of § 84.108(c) through (g) and (i). We covered the ALD mandate for 1,500+ lb systems in the § 84.108 post; this is the flip side — the same monitoring, deployed voluntarily, buys your customer out of the manual inspection schedule.

Two catches:

1. Partial coverage means partial exemption. If the ALD system only monitors part of the appliance, (g)(4)(i) keeps the rest of the appliance on the manual inspection schedule.
2. The audit/calibration is itself a recorded obligation. An ALD system that skipped its annual audit doesn't qualify — and § 84.106(l)(6) requires records of the installation, the annual audits and calibrations, and every date the system flagged a leak.

The Record Every Inspection Must Leave Behind

Here's where this lands on you, the servicing contractor, even though the inspection duty formally belongs to the owner or operator. Section 84.106(l)(5) spells out both the record and who produces it:

Four required elements — date, method(s), the location of each leak found, and the visible-and-accessible certification — and a provide duty that names the technician directly. Just like the service-record duty in § 84.106(l)(4), the owner can't keep a record you never handed over. Walking off a quarterly inspection without leaving compliant documentation puts your own obligation in default, not just the owner's.

Like every Subpart C record, inspection records are subject to the three-year retention rule.

Worked Example

A grocery store's rack system (commercial refrigeration, 650-lb charge of R-448A) takes a 130-lb addition in March; the annualized rate comes back at 34% — over the 20% threshold. Repairs finish inside the 30-day window, and the follow-up verification test passes on April 10.

• The unit is commercial refrigeration ≥500 lbs → quarterly. Inspections are due on a three-month cadence anchored to April 10: July 10, October 10, January 10, April 10.
• Each inspection: certified tech, appropriate method, all visible and accessible components, and the (l)(5) documentation handed to the store before the truck leaves.
• If the leak-rate calculations across those four quarters never exceed 20%, the appliance exits the schedule after the fourth clean quarter. One bad calculation — say a 25% rate in October — and everything resets: new 30-day repair clock, new verification tests, and a new four-quarter cycle behind them.

Same store, same March exceedance, but on the 90-lb walk-in condensing unit instead? Commercial refrigeration between 15 and 500 lbs → annual. One inspection a year until a full year of calculations comes back clean.

One item to have on your radar for refrigerated transport: EPA proposed in May 2026 to exclude road and intermodal-container transport refrigeration units from the leak-repair requirements entirely (91 FR 30532). As of this writing it's a proposal, not a final rule — TRUs that exceed a threshold remain on the annual schedule under (g)(1)(iii) until that changes.

The Bottom Line

The inspection schedule is where Subpart C compliance stops being an event and becomes a subscription. An exceedance doesn't end when the repair verifies — it ends when the appliance has demonstrated four clean quarters or one clean year, with a compliant record behind every inspection along the way.