EPA Refrigerant Tracking Software: What It Must Do in 2026

Before 2026, leak-rate tracking applied to appliances holding 50 lbs or more of refrigerant — a population dominated by supermarkets and industrial plants that had dedicated staff or enterprise platforms for the job. The AIM Act rule (40 CFR Part 84, Subpart C) dropped the threshold to 15 lbs, pulling reach-in coolers, walk-ins, and commercial rooftop units into scope — equipment owned by restaurants, convenience stores, and small property portfolios, and serviced by small HVAC/R contractors. The obligation that came with it is not "keep a folder." Under § 84.106(b), the leak rate must be calculated every time refrigerant is added to a covered appliance. Under § 84.106(d), crossing the category threshold (10% comfort cooling, 20% commercial refrigeration, 30% industrial process) starts a 30-day repair deadline — followed by verification tests (§ 84.106(l)(7)) to prove the repair worked. A separate calendar-year total decides whether the appliance crossed the 125% chronic-leaker line and owes EPA a report by March 1. And all of it must survive three years and be reconstructable per appliance when an inspector asks. The regulation, in other words, assumes computation at the moment of service — not transcription at the end of the month. Tools that do that computation are what this category is.

Judge any tool in this category — including ours — against the duties the rule actually imposes: 1. Capture the eight § 84.106(l)(2) service-entry fields as the entry form — appliance identity and location, date, parts worked on, type of work, technician, refrigerant amount and type, full charge, and the leak rate with its method. If the form doesn't demand them, your records won't contain them. 2. Compute the leak rate at the moment pounds are logged, using one organization-wide method (annualizing or rolling average) applied consistently. 3. Know the appliance's category threshold and open a repair action with the federal 30-day deadline the moment a calculation crosses it — then track the verification tests that close it. 4. Total each appliance's calendar-year additions against 125% of full charge — a separate calculation from the leak rate, on a separate window — and surface the March 1 reporting duty. 5. Maintain the standing appliance file (§ 84.106(l)(1)): full charge, the § 84.102 method used to determine it, and a documented trail for any revision — the full charge is the denominator of every leak rate the appliance will ever have. 6. Keep everything at least three years and produce a per-appliance history on demand — the audit is per unit, not per shop. 7. Handle the § 84.106(l)(4) handoff: when a contractor does the work, the owner or operator must receive a record with the required contents. Software that only serves one side of that exchange leaves the other side exposed.

Four honest lanes: Paper or a spreadsheet. Legal — the rule allows it explicitly. A well-built spreadsheet can hold all eight fields and a leak-rate formula. What it cannot do is watch itself: nobody gets alerted when a threshold is crossed, the 30-day clock lives in someone's head, the 125% total needs its own maintained formula, and the per-appliance history has to survive three years of file moves. If you run a handful of covered appliances and service them rarely, this can genuinely be enough — we publish a free spreadsheet template with every required column because for some shops it is the right answer. Field-service management suites (ServiceTitan, Housecall Pro, Jobber). These own scheduling, dispatch, and invoicing — and they do not do Subpart C compliance. A custom field on a work order is storage, not calculation: no approved-method leak rate, no threshold logic, no repair clock, no chronic-leaker total. Keep your FSM for running the business; it is not a compliance answer. Enterprise refrigerant compliance platforms (Trakref, Verisae/Trax and kin). Built for supermarket chains and cold-storage portfolios: site hierarchies, procurement workflows, quote-based pricing, onboarding projects. If you operate hundreds of racks, this is your lane. If you are a five-truck contractor or own three walk-ins, you will pay for depth you never touch. Small-market refrigerant compliance tools. The newest lane, and the one that exists because of the 15-lb change — purpose-built Subpart C trackers priced for small operations, typically $15–$90 per month. Ref LeakLog is in this lane, and it is not alone there (RefriTrak, RefriComply, and LeakClock are also working this segment). The tools in this lane look similar on a feature grid — which is exactly why the next section matters.

Feature lists converge; correctness on the rule's hard cases does not. These questions have verifiable right answers in the regulation, and a vendor demo either passes them or it doesn't — run them against any tool in the small-market lane, including ours: • First event: an appliance's first addition since January 1, 2026 — does the annualizing method use D = 365 so the rate isn't artificially amplified, or does it divide by days-since-nothing? • Purge-and-destroy: § 84.106(k) says refrigerant purged and destroyed at ≥98% destruction efficiency does not count toward the leak rate. Is there a field for it, and does the math subtract it? • Exclusions: a retrofit, a new installation, a seasonal variance — the rule excludes these additions from triggering a calculation. Does the tool model them, or does every top-off fire a false threshold alarm? • Method switch: changing between annualizing and rolling average is allowed but governed (§ 84.106(b)(3)) and must itself be documented in the records (§ 84.106(l)(3)). Does the tool restart the rolling window correctly and write the switch record — or just flip a setting silently? • Full-charge revision: correcting a full charge changes every future leak rate for that appliance. Does the tool document how and when it changed (§ 84.106(l)(1)), or silently rewrite the denominator? • Two clocks: show the vendor an appliance with many small top-offs, each below the leak-rate threshold, that cumulatively pass 125% of full charge in a calendar year. Does the chronic-leaker flag fire even though the leak rate never did? A tool that gets these wrong doesn't fail loudly — it produces confident, wrong numbers that sit in your records for three years until an inspector reads them.

Small-market tools cluster between roughly $15 and $90 per month depending on seats and equipment counts; enterprise platforms are quote-priced and typically an order of magnitude beyond that once onboarding is counted. Two anchors keep the number honest. Downward: a spreadsheet is free, and if your fleet is small and stable it may genuinely serve. Upward: the 2026 maximum civil penalty is $59,114 per day per violation, and a single missed 30-day deadline on a single appliance is a multi-day violation by definition. Price the software against the cost of the failure mode it prevents, not against zero. One structural thing to check regardless of price: whether compliance capability is gated by tier. If the vendor's cheap plan calculates leak rates but the repair-deadline tracking or the chronic-leaker report lives in the expensive plan, the pricing page is telling you compliance is an upsell. Seat counts and fleet size are honest axes to price on; the compliance engine itself should not be.

This is our guide, so here is our position, stated plainly. Ref LeakLog is a small-market Subpart C tracker: the log entry form is the § 84.106(l)(2) field list, the leak rate and method are computed as the pounds are logged, a threshold exceedance opens the repair action with its 30-day deadline and its verification-test workflow, the chronic-leaker total runs on its own calendar-year window, and every report the app prints is built for the per-appliance audit. Every tier — Independent ($29/mo, 1 seat), Crew ($59/mo, 3 seats), Business ($89/mo, 8 seats) — runs the identical compliance engine; the tiers differ in seats, never in compliance capability. Every correctness question in the section above is answerable in the live demo on fictional data, no signup required. And if you read all this and conclude a spreadsheet is enough for your fleet — take our free template. It has every required column and no email gate. The obligation is real either way; the tool should fit the fleet.