EPA Compliance Disclaimer

Effective Date: February 1, 2026
Last Updated: February 1, 2026

1. Nature of the Service

Ref LeakLog, operated by Elite Tech Global LLC, is a software tool that assists users with:

• Tracking refrigerant charges, additions, and recoveries for equipment under their management
• Calculating leak rates using methods described in EPA regulations (40 CFR Part 82, Subpart F), including the Annualizing Method and the Rolling Average Method
• Monitoring equipment categories and their applicable leak rate thresholds (e.g., 10% for comfort cooling, 20% for commercial refrigeration, 30% for industrial process refrigeration)
• Tracking repair actions and verification testing when leak rate thresholds are exceeded
• Generating reports that may be useful in demonstrating compliance efforts
• Monitoring the 15-pound minimum full charge threshold applicable to equipment subject to EPA leak repair requirements effective January 1, 2026

The Service is designed to assist with compliance management — it does not guarantee, certify, or ensure compliance with any law, regulation, or standard.

2. No Government Affiliation

Ref LeakLog and Elite Tech Global LLC are not affiliated with, endorsed by, sponsored by, or in any way officially connected with the United States Environmental Protection Agency (EPA), the Department of Justice, or any other federal, state, or local government agency.

Any references to EPA regulations, the Clean Air Act, the AIM Act, 40 CFR Part 82, Section 608 requirements, or other regulatory standards are made solely for informational and functional purposes to describe the regulatory context in which the Service operates. These references do not imply endorsement, certification, or approval by any government entity.

3. No Legal or Regulatory Advice

Nothing in the Service, including but not limited to calculations, reports, alerts, guides, blog posts, educational content, or tool outputs, constitutes legal advice, regulatory guidance, or professional environmental compliance consulting.

The information provided through the Service is for general informational and operational management purposes only. You should not rely on the Service as your sole means of determining compliance with EPA regulations or any other legal requirements. We strongly recommend that you:

• Consult with a qualified environmental attorney or compliance professional regarding your specific obligations
• Review the applicable EPA regulations directly (available at 40 CFR Part 82, Subpart F)
• Contact the EPA directly for authoritative guidance on regulatory requirements
• Maintain independent compliance verification procedures beyond the Service

4. Accuracy of Calculations

The Service implements leak rate calculation methods based on our interpretation of the EPA's published formulas and regulatory guidance. While we strive for accuracy:

• Input dependency: All calculations are based on data you enter. Inaccurate, incomplete, or untimely data entry will produce inaccurate results. The Service cannot verify the accuracy of your inputs.
• Interpretation risk: EPA regulations and guidance may be subject to different interpretations. Our implementation represents our best understanding of the applicable methods, but the EPA or courts may interpret these requirements differently.
• Software limitations: Despite comprehensive testing, software may contain bugs or errors. We do not warrant that calculations will be error-free under all circumstances.
• Regulatory changes: EPA regulations, enforcement policies, and guidance documents may change at any time. While we endeavor to keep the Service up to date, there may be a delay between regulatory changes and corresponding updates to the Service.
• Edge cases: Unusual equipment configurations, atypical service histories, or complex scenarios may not be fully addressed by the Service's calculation engine.

You should independently verify any leak rate calculations, threshold determinations, or compliance conclusions generated by the Service before relying on them for regulatory reporting or decision-making.

5. Reports and Records

The PDF reports generated by the Service are designed to be useful in documenting your compliance activities. However:

• We do not guarantee that reports generated by the Service will satisfy specific EPA recordkeeping requirements or be accepted as sufficient documentation in the event of an audit or enforcement action
• The EPA may require additional documentation, formats, or records beyond what the Service provides
• Reports reflect only the data entered into the Service and cannot account for information not recorded in the system
• State and local regulations may impose additional recordkeeping requirements beyond federal EPA requirements

6. Chronic Leaker Identification

The Service includes functionality to identify equipment that may qualify as a "chronic leaker" under EPA regulations (equipment leaking at 125% or more of the applicable leak rate threshold in a calendar year). This feature is intended as an informational alert. Chronic leaker status determinations have significant regulatory consequences, including potential reporting requirements to the EPA. You should independently verify any chronic leaker determination and consult with a compliance professional before taking action or making reports based on these alerts.

7. EPA Certification Verification

The Service requires users to provide EPA Section 608 certification information. The Service does not independently verify the validity or currency of certifications entered by users. It is the responsibility of the organization Owner to verify that all technicians working under their organization hold valid and appropriate EPA certifications.

8. Limitation of Liability for Regulatory Outcomes

ELITE TECH GLOBAL LLC SHALL NOT BE LIABLE FOR ANY REGULATORY FINES, PENALTIES, ENFORCEMENT ACTIONS, CIVIL LIABILITIES, CRIMINAL LIABILITIES, OR OTHER CONSEQUENCES ARISING FROM:

• Your use of or reliance on the Service for compliance purposes;
• Inaccurate calculations resulting from incorrect or incomplete data entry;
• Failure of the Service to identify a compliance issue;
• Differences between the Service's implementation and the EPA's interpretation of regulatory requirements;
• Delays in updating the Service to reflect regulatory changes;
• Any action or inaction you take based on information provided by the Service;
• Service outages or technical issues that prevent access to records during an audit or inspection.

See our Terms of Service for complete limitation of liability provisions.

9. Fines and Penalties Referenced in Marketing

The Service's marketing materials reference potential EPA fines and penalties (such as daily civil penalty maximums for violations of Section 608 of the Clean Air Act). These figures are based on publicly available EPA penalty schedules and are provided for informational purposes to illustrate the potential consequences of non-compliance. Actual fines and penalties in any specific case are determined by the EPA and the courts based on a variety of factors, and may be higher or lower than the figures referenced. These references should not be construed as legal opinions about the penalties you may face.

10. Recommendation

We strongly recommend that all users of the Service:

• Maintain a relationship with a qualified environmental compliance professional or attorney
• Independently verify compliance status using authoritative regulatory sources
• Keep records beyond those stored in the Service, as appropriate for your operations
• Stay informed of regulatory changes through official EPA communications and Federal Register notices
• Use the Service as one component of a comprehensive compliance program — not as a sole compliance solution

11. Contact Information

If you have questions about this disclaimer, please contact us at:

Elite Tech Global LLC
Email: legal@refleaklog.app
Website: https://refleaklog.app