The Automatic Leak Detection Compliance Paradox: When Leak Detection Becomes a Liability
What if the very tool you installed to reduce compliance risk is actually increasing it?
That’s the uncomfortable question that more and more facilities leaders are starting to ask. And with good reason: under the AIM Act and state-level refrigerant management regulations, Automatic Leak Detection (ALD) systems seem like a convenient “easy button” to help achieve compliance, and they are even required in some cases. But choosing the wrong ALD system, one that floods your inbox with false alarms or fails to detect the right leaks, can backfire in a big way.
Let’s break down the risks, the hidden costs, and the critical questions every executive and P&L leader should ask before signing their next ALD contract.
Risk #1: Each False Alarm is a Compliance Time Bomb
The AIM Act’s new rules (Subsection H, finalized September 2024) require owners of HVAC and refrigeration equipment to respond to ALD leak notifications within 24 hours. That means that every leak alarm from your ALD must be converted into a work order, the work order must be dispatched, and a technician must show up on site within 24 hours -- no exceptions for nights, weekends, or holidays. Failure to act on a single alert can trigger fines up to $57,000 per day, per violation.
As Keilly Witman often warns, “When the EPA starts an investigation, the first thing they do is look at your records, and it usually takes them 10 minutes to find a bunch of violations. Boom, you're in the middle of an enforcement action."
Now do the math: if your ALD system generates 100 alarms per week (a common occurrence with many ALD solutions), that’s 100 technician site visits that must occur, even if the alarms clearly aren’t legitimate. If you only dispatch technicians to 90 of these alarms, you are exposed to $57,000 in potential fines - per day - for EACH of the 10 remaining alarms ($570,000 per day).
Beyond fines, if only 10% are legitimate leaks, you’re left chasing 90 false alarms… and each one carries real financial, logistical, and relationship risks.
The result?
Soaring exposure to regulatory fines for any missed or delayed response
Bloated maintenance budgets from unnecessary truck rolls
Technician fatigue and distraction from real issues
In other words, if you aren’t careful, your ALD system can be your biggest compliance liability.
Risk #2: You’re Still on the Hook for Manual Leak Inspections
Many facilities leaders are shocked to learn that installing direct ALD gas sensors doesn’t exempt them from EPA-mandated monthly or quarterly manual leak inspections. Why?
Because gas sensors can’t cover everything. According to the text of the rule, “The Agency agrees that direct ALD systems are not effective for portions of an appliance that are outside of an enclosed space.”
According to the EPA, they don’t adequately cover:
Rooftop condensers
Underground lines
Overhead or hard-to-access piping
Non-enclosed areas like sales floors
The EPA is very clear: unless you are using an indirect “whole system” ALD solution that monitors 100% of the refrigerant system, manual leak inspections are still required. According to the text of the rule, “An owner or operator is required to inspect all portions of a refrigerant-containing appliance not monitored by an ALD system.” That means if you’re relying on point sensors or even multi-channel PPM gas sniffers, you’re likely still out of compliance and will need to pay for inspections on top of the ALD system.
Risk #3: Missing Documentation = Automatic Violation
Imagine this: the EPA or CARB shows up for an audit and asks for:
Proof of ALD system installation and calibration
Your annual ALD audit & calibration records
A record of every alert from your ALD system
Confirmation of technician response times for EVERY ALD alert
Proof that leak repairs were verified within the required window
If you can’t easily provide this documentation, or worse, if it doesn’t exist, you’re in violation.
Many ALD solutions are sold as “compliance tools,” but don’t actually provide the compliance artifacts required by the law. Without complete documentation, your company is exposed to enforcement actions even if the leaks were caught and fixed.
Critical Questions to Ask Your ALD Vendor
Before you commit to an ALD provider, ask them the following:
Last year, what percentage of confirmed leaks did you detect before 50 lbs or 10% of system charge leaked? What percentage of leaks did you miss or catch late?
Last year, how many false positive leak alerts did you generate per site?
How many regulatory audits have you helped your customers pass by providing required ALD documentation?
Is your system compatible with my existing CMMS (work order management system) and RTS (refrigerant tracking system)?
If the answers to these questions aren’t crisp, quantified, and credible, you should assume the system will increase your compliance risk,not reduce it.
What a Good ALD System Should Do
The right ALD system does far more than just trigger leak alarms. It should:
Detect leaks early (before major refrigerant loss or equipment failure)
Eliminate the need for manual inspections by covering the full system
Achieve compliance by detecting leaks before 50 lbs or 10% of system charge have leaked
Help you prioritize leak repairs based leak rate (lbs/day)
Generate audit-ready documentation automatically
Reduce refrigerant costs and emergency repairs
Help avoid “chronically leaking appliance” reporting requirements
Bonus: It should help you reduce corporate Scope 1 GHG emissions, one of the most immediate and tangible ways to advance your ESG goals.
Compliance is Mandatory. ALD Risk is Avoidable.
If you’re relying on an ALD solution that overwhelms your team, misses key areas of your system, or can’t produce the records regulators demand, you may be paying to increase your risk.
In this new regulatory era, it’s not enough to just “have ALD.” You need the right kind of ALD. One that actually helps you avoid fines, reduce downtime, and comply with EPA and state mandates without burning out your staff or your budget.
Because when enforcement begins on January 1, 2026, your ALD system will either be your best defense or your biggest liability.
Let me know if you’d like help evaluating your current leak detection setup, we’ve worked with many of the top-40 U.S. grocery chains to do just that.
Sources: AIM Act (EPA Subsection H), NASRC/Axiom Cloud webinars, EPA.gov, Therm, CARB, Ipsos, Sprouts.