Even though it's not the preferred method of transport, it's OK to lay a refrig down for moving, even new R134a if you pay close attention to the refrigerant lines. Determine where the suction line runs up into the freezer. This is the largest tube connected to the compressor, and is usually (though not always) visible running up the back of the cabinet. As long as the refrig is laid down on whichever side allows this line to stay 'high', there'll be minimal oil migration, and when you arrive at your destination, just stand it upright for an hour or so and it'll be fine. Obviously, the shorter the trip, the better. If the suction line runs up the door handle side, just duct-tape the doors securely closed before you lay it down to keep them from opening and getting damaged. It helps to lay a block of wood under the top end, just to keep it inclined a bit, too. I've been moving refrig's for some 32 years now, and while moving them in an upright position IS best, sometimes you just can't. I work out of a van, and have often laid both refrig's and upright freezers down for transport with no ill effects.
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