40 CFR §84.106 · AIM Act leak-repair documentation, done for you
Your contractor did the repair. The federal record is still yours.
Since January 1, 2026, any appliance holding 15+ lb of HFC refrigerant puts leak-repair recordkeeping duties on you — the owner — not your HVAC vendor. Forward us the invoice; we return a release-ready, audit-ready Completeness Pack in 72 hours and keep your whole portfolio inspection-ready.
Get your free AIM Exposure Diagnostic See how it worksThe paperwork gap nobody staffed
Walk-in coolers, freezer racks, and many ice machines crossed into federal leak-repair coverage overnight. The duties didn't land on your contractors — they landed on your facilities inbox.
Invoices that can't make a record
"Service call — refrigeration — $840" has no refrigerant quantity, no type, no tech certification. You cannot compute the leak rate 40 CFR §84.106 requires you to keep — so the record simply doesn't exist.
Clocks nobody is watching
Cross a leak-rate threshold — 20% for commercial refrigeration — and a 30-day repair clock starts at the refrigerant addition, not when someone finally reads the invoice in AP.
A March 1 deadline with cumulative math
Add 125% of an appliance's full charge in a calendar year and a chronic-leaker report is due to EPA by March 1. Each top-off looks routine; the yearly total across six vendors is what bites.
How it works
A documentation factory, not another dashboard. No software for your team to run.
- Registry workshop (once). We build your appliance registry — types, categories, refrigerants, and evidence-backed full-charge determinations. No invented numbers, ever.
- Forward invoices. Set one email forwarding rule. Every refrigerant service event from every vendor lands in our intake and starts a pack run.
- The pack run. AI extracts the fields with verbatim source quotes; deterministic code computes leak rates, thresholds, and clocks; missing fields get chased with your contractor directly.
- A human releases it. Every Completeness Pack is released by a refrigerant-ops analyst; threshold trips, method switches, and chronic watchlines are reviewed by an EPA Section 608-credentialed reviewer. Hard fails — no full charge, no quantity, unknown category — block release until resolved or shipped as explicit gaps.
- Your binder stays ready. Pack PDF + a Portfolio Leak Register row, same day as release. Monday digest of open repair clocks and chronic percentages. 3-year, appliance-indexed retention.
Proof
We're onboarding founding customers now — real results will replace these placeholders, never fabricated ones.
Median missing-field count per invoice before vs. after our contractor chase templates, from founding pilots (with customer permission).
Founding-customer testimonial will appear here once earned and approved in writing. We do not publish invented quotes.
Downloadable sample Completeness Pack built from illustrative fixture data, clearly labeled as such.
Simple, per-outcome pricing
Never hourly. Never a percentage of "avoided fines."
Completeness Pack
$149–$399 per pack, tiered by complexity: Green $149 · Yellow $249 · Red $399 (includes 608-credentialed review). Founding pilot packs from $99. First pack in 72 hours from your forwarded invoice.
Portfolio Leak Register Retainer
$12–$28 per appliance per month (minimum $791/mo). Living Portfolio Leak Register, Monday digest of open repair clocks, chronic watch, deadline calendar, 3-year vault.
March 1 Chronic Pack
$791–$2,500 per reporting entity per year, only if an appliance actually triggers the 125% chronic threshold. You review, approve, and submit — you stay the duty holder.
Binder-Ready Guarantee. If a pack is rejected from your binder for a completeness defect of our making — wrong math, missing required section, unsourced field — we re-issue free and credit the pack fee. Cancel the retainer any time: you keep the Portfolio Leak Register and get a full export handoff.
Free AIM Exposure Diagnostic
Upload your appliance list — or just your last three refrigeration invoices — and get a human-reviewed Gap Score across the five records an inspector asks for, within 24 hours of your upload.
Thanks — we'll reply within 1 business day with next steps for your document upload. [PLACEHOLDER — connect form to intake inbox before launch]
FAQ
Isn't this my refrigeration contractor's job?
Your contractor performs the physical work, and certified technicians must do the repairs and refrigerant handling. But 40 CFR §84.106 places the recordkeeping and reporting duties — leak-rate calculations, repair clocks, verification-test records, 3-year retention, chronic-leaker reports — on the appliance's owner or operator. That's the part we do for you.
Which equipment is covered?
Generally, stationary appliances with a full charge of 15 lb or more of an HFC or substitute with GWP above 53 — think walk-in coolers and freezers, rack systems, and many ice machines. Residential and light-commercial AC/heat pumps are exempt from these leak-repair rules, low-GWP refrigerants (GWP ≤53) are out of scope, and a May 2026 rule excluded road and intermodal transport refrigeration units. Older R-22 equipment falls under the separate Section 608 regime — we tag and track both.
Do you repair leaks or install leak-detection hardware?
No. We are a documentation service. Repairs, verification testing, and any hardware stay with your certified HVAC vendors. That separation is deliberate — it keeps our packs objective.
What if my contractor won't provide the missing data?
We chase them with structured requests — two touches, 5 business days apart. If they stay silent after 10 business days, your pack ships on time with an explicit gap register and risk score — honest documentation of what exists, never invented data. Most customers attach our gap lists to their vendor scorecards.
Will this keep me from being fined?
No one can promise that, and you should be wary of anyone who does. Civil penalty ceilings under the Clean Air Act are adjusted annually and actual penalties vary case-by-case. What we deliver is completeness: the records the rule expects, organized the way an inspector asks for them.
Who submits reports to EPA?
You do. We draft chronic-leaker reports and supporting evidence for your review, but you remain the owner/operator of record and you approve and submit anything that goes to EPA.
Scope and disclaimers
LeakPack Clear provides documentation support only. It is not legal advice, not an EPA filing service, and not a substitute for work performed by certified technicians. Customers remain the owner/operator of record and are solely responsible for regulatory compliance, for the accuracy of attested full-charge determinations, and for reviewing and submitting any reports to EPA. LeakPack Clear does not guarantee regulatory outcomes or penalty avoidance.
Civil penalty ceilings under the Clean Air Act are adjusted annually for inflation; actual assessed penalties vary case-by-case and are not predictable or guaranteed to occur or to be avoided.
LeakPack Clear is an independent documentation service and is not affiliated with, endorsed by, or acting on behalf of the U.S. EPA.