NY Leak Inspection Requirements: What You Need to Know

A Quick Refresher on NYDEC’s Part 494 Regulation

New York’s Part 494 regulation (6 NYCRR Part 494), effective January 9, 2025, is the state’s framework for reducing emissions of high-GWP refrigerants (defined as those with a GWP20 greater than 10). The regulation applies broadly across the commercial and industrial refrigeration supply chain — including manufacturers, distributors, installers, service contractors, and owner/operators. At a high level, Part 494 primarily does four things:

1. Bans the sale/purchase of certain high-GWP refrigerants on a tiered schedule based on GWP.
2. Prohibits the manufacture, sale, and installation of new equipment and systems using high-GWP refrigerants, with timing varying by subsector (supermarkets, industrial process refrigeration, ice rinks, etc.).
3. Establishes a Refrigerant Management Program (RMP) for any commercial facility with refrigerant charge capacity of 50 lbs or more of regulated refrigerant — covering registration, labeling, leak inspections, leak repair, recordkeeping, and annual reporting.
4. Establishes a Supermarket Refrigerant Program (SMP) for chains with 20+ NY facilities (or 100+ nationally) operating supermarket systems of 200 lbs or more. Covered chains must transition to low-GWP refrigerants, meet an annual leak rate cap of 5% or less, or pursue other approved compliance pathways. More on the SMP in an upcoming article.

This article zooms in on one piece of #3 above — the leak inspection requirements under the RMP, which we’ve been fielding a lot of questions about from end-users.

Your Part 494 Leak Inspection FAQ

When did the Part 494 leak inspection requirements take effect?

January 9, 2025 — meaning manual leak inspections are already required for any facility operating equipment or systems with 50+ lbs of a high-GWP refrigerant in NY, with a few key exemptions covered below.

Who has to do manual leak inspections?

Owners or operators of any stationary refrigeration or air conditioning equipment in New York with a refrigerant charge capacity of 50 lbs or more of a high-GWP refrigerant. Residential equipment is not covered.

How often do I need to inspect?

Frequency depends on system charge size:

• ≥1,500 lbs (refrigeration): A compliant ALD system is required to monitor the system. Per DEC’s April 2025 enforcement discretion letter, any portion where ALD coverage is not technically feasible — such as a rooftop condenser or outdoor piping — may be manually inspected monthly through December 31, 2027.
• 200–1,499 lbs: Quarterly manual inspections, or install a compliant ALD system.
• 50–199 lbs: Annual manual inspections, or install a compliant ALD system.

How am I required to actually perform a manual inspection?

You must use either a calibrated handheld leak detector with a 10 PPM Minimum Detection Limit (MDL), or perform a bubble test.

What needs to be inspected?

You must inspect all visible and accessible components of your equipment, except for any portions that are:

• Continuously monitored by a compliant Automatic Leak Detection (ALD) system (see below)
• Insulated, underground, behind walls, covered by ice, or otherwise inaccessible
• More than two meters above a support surface
• Unsafe to inspect, as determined by site personnel

What qualifies as a compliant ALD system?

For ALD systems that monitor refrigerant in the air, Part 494 requires:

• An MDL of 10 PPM
• An ability to alarm at 100 PPM
• Annual audit and calibration of the unit per manufacturer procedures
• Sensors installed near compressors, evaporators, condensers, and other high-leak-risk areas

Are there events that trigger an inspection outside the normal schedule?

Yes — and this one often gets missed. A full system leak inspection (subject to the exemptions already mentioned) is also required when you:

• Add refrigerant equal to or greater than 5 lbs or 1% of the system charge (whichever is less), or
• Observe oily residue on any refrigerant circuit that may indicate a leak.