Disposing of old equipment, refrigerants and chemicals

Why disposal deserves a written procedure

Every replacement job produces something to get rid of: a condenser, a furnace, a water heater, a dishwasher, a box of old bulbs or a half-used jug of chemical. Volume is not small. In Angi's 2025 survey, 22% of homeowners installed a new appliance during the year^[4], and each install usually means an old unit leaving the house. HVAC change-outs are adding to the pile as systems move to lower-GWP refrigerants: EPA's Technology Transitions rule set a 700 GWP limit for refrigerants in new residential and light commercial AC and heat pump systems, with a January 1, 2025 installation compliance date^[5].

Most disposal mistakes are not deliberate. They happen when a helper drops a unit at the scrap yard without the paperwork, or a box of old thermostats sits in the shop for two years. A written procedure fixes both.

Refrigerant: recovery before disposal

Under Clean Air Act Section 608, technicians who maintain, service, repair or dispose of equipment that could release ozone-depleting refrigerants must be certified^[2]. In practice that means a certified tech recovers the charge from a split system, rooftop unit or other comfort-cooling equipment before it is disconnected and hauled away, using recovery equipment that meets EPA standards.

Small appliances, such as refrigerators, freezers, dehumidifiers and window air conditioners, often enter the waste stream with their charge intact. For them, EPA places responsibility on the final person in the disposal chain, such as a scrap metal recycler or landfill, to ensure refrigerant is recovered before final disposal^[1]. That final disposer keeps a signed statement from whoever dropped off the appliance, including the name and address of the person who recovered the refrigerant and the date it was recovered^[1]. EPA does not accept a sticker on the unit as verification^[1].

What goes where

The federal universal waste rules cover five categories: batteries, pesticides, mercury-containing equipment, lamps and aerosol cans^[3]. They streamline hazardous waste requirements so these common items are easier to collect and recycle^[3]. States can add their own universal wastes, with examples including antifreeze, ballasts, electronics and solar panels^[3], so check your state environmental agency's list.

A change-out procedure techs can follow

1. 01

   Before the job

   Confirm in the job ticket that the old equipment is leaving with you, and whether the customer has asked to keep anything. Load an empty recovery cylinder with enough capacity.

2. 02

   Recover the charge

   A certified tech recovers refrigerant from the old system before disconnecting it. Note the system type, refrigerant and estimated amount recovered.

3. 03

   Remove other regulated parts

   Pull a mercury thermostat whole and put it in the closed collection container on the truck. Bag old batteries from thermostats and detectors.

4. 04

   Haul and sort at the shop

   Scrap metal goes to the scrap pile with a tag showing the job number and that recovery was done. Cylinders go to the cylinder rack.

5. 05

   Take scrap with paperwork

   Give the scrap yard what it asks for, such as a signed recovery statement. Keep a copy in the job folder.

6. 06

   Close the job

   Record the recovery details and disposal date in the job record. That is your evidence if anyone asks later.

Choosing a scrap yard and recyclers

Your disposal partners carry part of your risk, so pick them on more than the price per pound. A good scrap recycler asks you for a recovery statement on small appliances, because the rule puts that responsibility on them^[1]. A yard that never asks is a yard that may not be checking anyone else either. Questions worth asking before you commit to one:

1. Do you require a signed recovery statement for refrigerators, freezers and window units, or do you recover refrigerant yourselves for a fee?
2. Do you accept whole condensers and furnaces, or do you need components separated?
3. Will you give a receipt that shows the date, weight and type of material for each drop-off?
4. For universal waste, can you take thermostats, lamps and batteries, or should we use a separate recycler?
5. Do you offer roll-off containers or scheduled pickups for busy months?

For refrigerant cylinders, ask your supply house how it handles recovered gas. Many distributors accept recovered refrigerant for reclamation and track cylinders by number, which makes your recovery log easier to keep. Write the name of each partner, their contact and what they take on a single sheet pinned in the shop, so a new hire knows where every item goes.

Pest and cleaning chemicals

Pesticides appear on the federal universal waste list^[3], but the first rule is always the product label, which sets storage and disposal directions for the product and its container. Cleaning companies have a smaller but steady stream: old floor finish, degreasers and solvents that a client no longer wants. Do not pour unknown products down a drain at a job site or at the shop. Keep them in their original containers with labels intact and use your local household hazardous waste program if it accepts business waste, or a licensed waste hauler if it does not. Your hazard communication program should list who decides when a product is retired.

Talking to customers about haul-away

Customers ask two things: "Will you take the old one?" and "Can I keep it?" Have answers ready.

• "Yes, removal is part of the job. We recover the refrigerant first, as federal rules require, and take the old unit to a recycler."
• "You can keep the old unit, but we still need to recover the refrigerant before we disconnect it."
• "We will take the old thermostat too. Older ones can contain mercury, so we recycle them separately."
• "We cannot take paint or chemicals you have stored in the garage, but your local household hazardous waste site can."

Put haul-away and disposal in your written estimate so the customer sees it before the job. The service terms guide covers how to word it.

Example: a two-truck appliance and HVAC shop

Example: a fictional shop replaces about eight systems and twenty appliances a month. It used to drop old refrigerators at a scrap yard with no paperwork and keep old thermostats in a coffee can. The owner now keeps a recovery log in the shop, a lidded thermostat bin on each truck and a disposal folder with every signed statement, sorted by month. The scrap yard visits take five minutes longer. In return, the owner can answer any question about where a unit went and who recovered its refrigerant, and the thermostats go out twice a year to a recycling program instead of sitting on a shelf.

Records to keep

• Section 608 certification cards for every tech who recovers refrigerant.
• A recovery log: date, job, equipment type, refrigerant, approximate amount and cylinder number.
• Copies of signed statements or contracts given to scrap recyclers.
• Shipping papers or receipts for universal waste sent to recyclers.
• Your state's universal waste list, printed and dated, so staff know what counts.

If you also haul large equipment across state lines, check whether your trucks fall under the DOT rules for service trucks.