First Name | Tim |
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Last Name | Frazee |
Email Address | tfrazee@raprec.com |
Affiliation | Rapid Recovery |
Subject | Enforcement of Proposd Regulation |
Comment | This regulation is a small step in the correct direction. The one component missing from this and all other refrigerant regulations is enforcement. Based upon my observations as someone intimately involve with refrigerant management on a daily basis, the vast majority of appliance owners and contractors do not take the existing, or this proposed regulation too seriously as they know that the Feds, and local government agencies, do not actively audit records, investigate reports of purposeful venting, or for all intents and purposes, enforce the law. The phasing of the regulation, based upon the size of the refrigerant charge, does soften any financial blow and allow businesses time to plan for changes in their operations. This is a good and generous allowance. One question I have relates to how the fee revenue is to be spent. I would propose that it be used to hire audits/investigators for enforcement purposes, which would add some sorely needed teeth to the regulation. Thanks, Tim Frazee Rapid Recovery |
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Date and Time Comment Was Submitted | 2010-03-30 14:48:43 |
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