EPA’s Proposed Explanation of Who is a HFC “Fire Suppressant Recycler”
Footnote 48 Page 66394 (Page 23 in the PDF document):
Generally, an entity that collects used HFC fire suppressants and directly resells those recovered HFCs—with or without any additional reprocessing including testing for purity—to another person for reuse as a fire suppressant would qualify as a fire suppressant recycler (also referred to as a ‘‘recycler for fire suppression’’ in 40 CFR part 84, subpart A).
A person that recovers and aggregates used HFC fire suppressants for distribution to another entity for reprocessing before being sold for reuse as a fire suppressant would not be a fire suppressant recycler.