EPA Part 84 compliance software for HVAC contractors. Audit-ready in 30 days.
Per-event leak-rate calcs with the post-2026 bootstrap basis stamped. 30 / 120-day repair clocks. Certified-technician gating. A records export with the eCFR cite on every row. TuffOps Comply is the EPA Part 84 / AIM Act compliance engine your work-order software doesn't have.
The AIM Act phasedown is in effect. Most HVAC shops are not ready.
EPA's 40 CFR Part 84 Subpart C took effect January 1, 2026. It rewrote the leak-repair rules for any appliance with 15 lb or more of regulated refrigerant — new methodology bootstraps, new repair clocks, new verification windows, new recordkeeping. Spreadsheets don't carry CFR citations. Paper service tickets don't bootstrap a leak-rate method on January 1, 2026. And the FSM software your shop runs on — ServiceTitan, Housecall Pro, Jobber, FieldEdge — doesn't know what §84.106(d)(3) means.
Five things EPA can ask for — today — on any covered appliance.
These aren't projections. These are the operative rows of 40 CFR Part 84 Subpart C as of the 2026-01-01 effective date. If your shop can't produce the right artifact for each of them on demand, you're exposed.
| # | What EPA wants to see | What "ready" looks like |
|---|---|---|
| 1 | Leak rate calculated on every refrigerant addition, with the right method bootstrapped on or after January 1, 2026 (annualizing or rolling-average). | A timestamped calc per top-off, with the methodology and the §84.106(b)(1)/(b)(2) bootstrap basis explicitly stamped on the row. |
| 2 | Repair started within 30 days of an over-threshold leak (120 days if industrial-process shutdown applies under §84.106(d)). | A repair episode with the deadline basis stamped — part84_106_d for the new clock, not part82_57_c_1 for the old one. |
| 3 | Initial verification within 30/120 days of exceedance, follow-up verification within 10 days of initial (§84.106(e)). | Two separate verification clocks per episode, each anchored to the right event and stamped with the §82.157 vs §84.106(e) basis. |
| 4 | Certified technician on every repair per §82.161(a) and §84.106(c)(1). | A current §82.161 cert on file for every tech who touched refrigerant, with expiration tracked and jobs gated when expired. |
| 5 | Records exportable on demand — leak-rate calcs, repair episodes, verification methods, mothball periods, RLCA carve-outs, methodology changes. | A CSV bundle where every row carries the eCFR paragraph it satisfies. Inspector can navigate from a value back to the rule. |
What TuffOps Comply actually does about it.
Not a "compliance dashboard." A regulatory engine wired into your work-order flow, with every clock, gate, and audit row anchored to a specific paragraph of 40 CFR Part 84 Subpart C. The features below are shipped, tested, and citable — not roadmap.
Per-event leak-rate calc with bootstrap basis stamped
Annualizing and rolling-average methodologies with the first-time-after-2026-01-01 365-day bootstrap stamped on the row, so an inspector can tell a synthetic regulatory bootstrap apart from a real elapsed-time calculation.
40 CFR §84.106(b)(1) · §84.106(b)(2)30 / 120-day repair clocks with industrial-shutdown toggle
Repair deadlines resolved per appliance category with the basis stamped on every episode. Operators with the right permission can flip industrial-process shutdown on; the deadline re-resolves atomically and the audit trail captures who, when, and why.
40 CFR §84.106(d)Initial + follow-up verification clocks
Two separate verification windows per episode: 30/120 days for initial, then 10 days for follow-up — anchored to initial_verification_at, not repair completion. Both clocks shift correctly when industrial shutdown toggles or a unit goes on mothball.
Mothball pause / resume with append-only audit ledger
Mothball an appliance and the §84.106(d) repair clock pauses; resume and every open episode's deadline shifts forward by the precise paused duration. Every period is logged with start, end, who, and why — your §84.106(l)(10) source of truth.
40 CFR §84.106(d)(3) · §84.106(l)(10)RLCA carve-out workflow with justification capture
Residential and light-commercial AC/HP carve-out is a permission-gated, justification-required toggle. Append-only audit ledger captures every flip. Records export carries the live RLCA stamp and the full enable / edit / disable history.
40 CFR §84.106(a)(3)(ii)Dual-cite certified-technician gating
Every refrigerant repair is gated on a current §82.161(a) cert. Refusal messages, notifications log, and override audit rows all carry the dual [§82.161(a), §84.106(c)(1)] citation tuple — frozen at override time so the historical record is immutable.
Repair-extension request packet
File a §84.106(f) extension request with the full (f)(3) reason narrative and the (f)(4) electronic-notification packet. Live state on the episode shifts the repair and initial-verification due-dates forward by the exact requested days; withdraw rolls back exactly.
40 CFR §84.106(f)(1)(3)(4)Methodology-change tracking for acquisitions
Switch leak-rate methodology under §84.106(b)(3) (M&A path or operator-edit path) and the change is fanned out across every affected appliance into an append-only ledger with prior method, new method, prior owner, new owner, and the operator narrative.
40 CFR §84.106(b)(3) · §84.106(l)(3)Records export with eCFR cite per row, per column
Inspector-grade CSV bundle: leak-rate calcs, repair episodes, verification methods, mothball periods, RLCA audits, methodology changes, extension requests. Every cell that satisfies a CFR obligation carries its citation in the export — and the manifest documents the schema.
40 CFR §84.106(l) recordkeeping familyDual-framework policy engine (Part 82 + Part 84)
One applicability decision per appliance, made by a single policy engine. When Part 84 doesn't apply, the unit stays under Part 82 — never regulation-free. When both apply, audit surfaces carry both citations side-by-side instead of collapsing to one.
40 CFR §84.120 (dual-framework anchor)Why TuffOps Comply, and not what you're using now.
We've benchmarked the major options HVAC shops actually run. None of them carry Part 84 obligations as first-class objects in their data model. You can run TuffOps Comply alongside your existing FSM software as your compliance system of record.
| Spreadsheets / Paper | ServiceTitan · Housecall Pro · Jobber · FieldEdge | TuffOps Comply | |
|---|---|---|---|
| Per-event leak-rate calc with bootstrap basis | ✗ | ✗ | ✓ |
| 30 / 120-day repair clock with industrial-shutdown toggle | ✗ | ✗ | ✓ |
| Initial + follow-up verification windows (§84.106(e)) | ✗ | ✗ | ✓ |
| Mothball clock pause/resume with audit ledger | ✗ | ✗ | ✓ |
| RLCA carve-out workflow | ✗ | ✗ | ✓ |
| Certified-technician cert tracking + repair gating | manual | partial | ✓ |
| Repair-extension request packet (§84.106(f)(4)) | ✗ | ✗ | ✓ |
| Records export with eCFR cite per row | ✗ | ✗ | ✓ |
| Survives an EPA records request without a fire drill | ✗ | ✗ | ✓ |
Comparison reflects publicly documented capabilities of each platform as of April 2026. We respect each of these vendors and many of our customers run them for dispatch, billing, and CRM. TuffOps Comply is purpose-built for the regulatory layer they don't cover.
"TuffOps is an absolute gamechanger for us. It surpassed our high expectations in every regard. No more paper and better service for our customers."
How "audit-ready in 30 days" actually works.
Not marketing fluff. A real, structured onboarding sequence with a checkpoint at the end of every week. You bring your equipment list and your refrigerant history; we bring the policy engine and the implementation playbook.
Data import & unit catalog
Import your customer and equipment lists. Tag every appliance with charge size, refrigerant type, equipment category, and RLCA eligibility. Catalog gaps surface immediately.
Workflow training
Train your office and field crews on the leak-repair episode flow, certified-tech gating, mothball pause/resume, and the industrial-shutdown toggle. Permissions configured per role.
Records export dry run
Generate the full §84.106(l) records bundle against your imported history. Walk through it together as if EPA had just asked. Identify and close any gaps.
Audit-readiness review
Final walkthrough with our team. Sign off on every CFR obligation in your scope. You leave the meeting with a documented audit-readiness statement on file.
Frequently asked questions about EPA Part 84 compliance software
What if I'm already on ServiceTitan, Housecall Pro, Jobber, or FieldEdge?
Run TuffOps Comply alongside as your compliance system of record. Your existing FSM platform keeps doing dispatch, billing, and CRM. TuffOps Comply owns the regulatory layer they don't cover. Many of our customers run exactly this configuration.
What if I don't do refrigerant work above the 15 lb threshold?
You're likely eligible for the §84.106(a)(3)(ii) RLCA (residential and light commercial AC/HP) carve-out. TuffOps Comply has a permission-gated, justification-required workflow to enable the carve-out per appliance, with full audit trail. The carve-out is also documented in your records export so an inspector understands why §84.106 obligations don't apply.
Is this enough for an actual EPA audit?
For 40 CFR Part 84 Subpart C — leak repair, verification, recordkeeping, methodology changes, mothball periods, RLCA carve-outs — yes, the platform is built directly against the operative paragraphs and the records export was designed to be inspector-ready. We'll walk through your specific scope on the demo. Subpart C areas we don't yet cover (refrigerant reclamation under §84.112, fire suppression under §84.110, EPA-submitted data under §84.118) are tracked transparently and called out in our scoping conversation.
Do I have to switch off my current FSM software to use this?
No. TuffOps Comply runs as an add-on alongside whatever you're using today. If you're also evaluating TuffOps for full work-order operations, we can scope that separately — but the compliance module stands alone.
How much does TuffOps Comply cost?
Comply is $15 per field technician per month as an add-on to the TuffOps Starter plan, and included at no additional cost on the Pro and Enterprise plans. Office and dispatch seats are free on every plan. A 6-tech shop on Starter pays $354/month for TuffOps + $90/month for Comply — well below the $57,617-per-day-per-violation civil penalty exposure for a single Clean Air Act recordkeeping failure. Full plan breakdown on the pricing page.
Can I see the records export before I sign anything?
Yes. The 20-minute walkthrough demos the records export against a sample data set. Bring a real scenario — an over-threshold leak, an acquisition with a methodology change, a mothballed unit — and we'll show you exactly what the CSV bundle looks like.
Who actually built this?
TuffOps is built by Caribe Solutions, headquartered in Redmond, Washington, and used by HVAC contractors across the continental United States and the Caribbean. The compliance module was scoped against 40 CFR Part 84 with consultant validation; our requirements matrix maps every shipped capability to its eCFR paragraph. For a deeper background read, see our guide to EPA Section 608, the AIM Act, and Part 84.
Where in the country (or world) do you support customers?
Anywhere in the continental United States, plus the U.S. Virgin Islands and Puerto Rico. Onboarding, training, and support are remote-first — we run scheduled video walkthroughs and the platform is web-based, so geography is not a constraint. For Pacific Northwest shops who want an in-person walkthrough, we are based in Redmond, Washington and happy to come on-site when it makes sense.
Get audit-ready in 30 days.
Book a 20-minute walkthrough. We'll demo the leak-repair flow, the records export, and the citation-stamped CSV bundle against a scenario from your shop. No slides, no sales pitch, no obligation.
Book your compliance walkthrough →