Refrigerant leak records: paper, spreadsheet or software?
As of Nov 8, 2026
The EPA rule does not pick a tool. 40 CFR 84.106(l) says records must be kept “for at least three years in electronic or paper format, unless otherwise specified.” So paper, a spreadsheet and software can all be allowed. What differs is how easily each one keeps the required records complete and findable. Not legal advice.
What the rule asks of any option
Definition: a leak record system is wherever you keep the records 84.106(l) names: the appliance register ((l)(1)), a record for each service event ((l)(2)), and records of inspections and verification tests ((l)(5), (l)(7)).
Appliance information is kept “until three years after the appliance is retired” ((l)(1)). Most other records are kept at least three years. If someone other than you does the work, they “must provide a record” with the (l)(2)(i) through (l)(2)(vi) items to you ((l)(4)). See the log template, column by column.
Four ways to keep the records
Editorial comparison of general patterns. No vendor is named and no price is claimed. The rule text above is the only sourced part.
| Option | Fit with the rule | Weak spot | Often fits |
|---|---|---|---|
| Paper log or binder | Works under the rule’s “paper format” wording. Easy to start. | Leak rate math is by hand each time; entries can be missed or misfiled; hard to see all appliances at once. | One or two appliances, a single site. |
| Spreadsheet | Works under “electronic format”. Free, familiar, you control the columns. | Formulas can break silently; one person usually owns it; contractor invoices still have to be keyed in. | A handful of appliances and one careful owner of the file. |
| Dedicated software | Can store every record in one place and do the leak rate math for you, depending on the product. | Costs money; fit to the rule varies by product, so check it against 84.106(l) yourself. | Many appliances or many sites. |
| Contractor-held records | The contractor must give you a record for each job under (l)(4). | The record lives in their system and their format; you still need the register and the history in one place. | Only as a source of records, not as your only copy. |
Five questions to test any option
- Can you pull up every appliance of 15 or more pounds, with its full charge and how it was determined?
- Does each service record carry the pounds and type of refrigerant added?
- Where does the leak rate get calculated, and with which method?
- Are repair dates and verification test dates in the same place?
- Will the records still be readable three years from now, and three years after the appliance retires?
Questions people ask
Does EPA require software to keep refrigerant leak records?
No. 40 CFR 84.106(l) says records must be kept for at least three years “in electronic or paper format, unless otherwise specified.” The rule names records, not a tool.
How long do I keep appliance records?
Appliance information under (l)(1) is kept until three years after the appliance is retired. Service and other records are kept at least three years, unless (l) says otherwise.
If my contractor does the service, who keeps the record?
Paragraph (l)(4) says a person other than the owner or operator who does the work must provide a record with the (l)(2)(i) through (l)(2)(vi) items to the owner or operator. Read (l) for who holds which record.
Is a spreadsheet enough?
The rule does not say a spreadsheet is or is not enough. It says electronic or paper. What matters is that each record the rule names is there and findable. The log template page lists the columns.
Does Leakplate sell record-keeping software?
No. Leakplate is a concept in validation with no product yet. This page compares options in general terms and names no vendor.
Source
eCFR, 40 CFR 84.106 (leak repair and records): ecfr.gov. Fetched Nov 7, 2026 for the other Leakplate guides. The comparison table is our reading, not EPA guidance.
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