| F-GAS | F GAS Regulations & Legislation, News, Articles & Information
Air-conditioning Specialists
| F-GAS | F GAS Regulations & Legislation, News, Articles & Information
| F-GAS | F GAS Regulations & Legislation, News, Articles & Information

The future of HFC policies

UK Government support for a proposal that would allow Montreal Protocol parties to negotiate proposals for a phase down of HFC use after the Copenhagen Climate discussions in December this year, must not ignore system energy efficiency and the option of selecting the most appropriate refrigerant as far as the UK refrigeration and air conditioning industry is concerned.

Issued by the Air conditioning and Refrigeration Industry Board
11th November 2009
 
The Institute of Refrigeration has compiled this guidance note to provide non-partisan advice on the effects of refrigerant choice and system design on the carbon footprint of a refrigerating system. Two effects are considered: the direct global warming potential of the refrigerant selected and the climate change effect of energy use by the system. The direct effect is measured as a “global warming potential” (GWP), usually against a reference of the potential of carbon dioxide over a 100 year period. Strategies for the reduction of carbon footprint include designing more efficient systems, minimising sources of leakage through the selection of more robust system components, reducing the quantity of refrigerant required to operate the system in order to mitigate the effect of a large leak and substituting refrigerants with a high GWP for those with a lower potential. These include ammonia, hydrocarbons, carbon dioxide, some low-GWP HFCs and hydrofluoroolefins (also known as unsaturated HFCs or HFOs)
 
There are many situations where the direct substitution of a hydrofluorocarbon (HFC) with a “natural” refrigerant is not reasonably practicable, either due to toxicity or flammability or high pressure. In such cases it would be possible to minimise HFC charge, or even eliminate it, by using a secondary fluid but this would tend to make the alternative system more expensive and less efficient. Rather than promoting a total ban of HFCs a more appropriate course would be to advocate a policy of “responsible use” of fluorocarbons in order to ensure that the climate effects of refrigerant emissions are minimised. A responsible refrigerant policy would place a high emphasis on the elimination of leak sources, the efficiency of the overall system and the life cycle cost of ownership.  
 
 
Energy Efficiency and Refrigerant Selection
 
Energy Efficiency of refrigeration systems is governed by the laws of physics and by practicality. Practicality embraces cost, cycle, legislative requirements, refrigerant choice and maintenance. Efficiency is not only dependent on choice of refrigerant but also on good design, selection of an appropriate system and good maintenance. Selection of the refrigerant demonstrating highest efficiency in an appropriate system is unlikely to improve system efficiency by more than 10% over efficiency of an optimized system using an HFC refrigerant. Some “natural” refrigerants such as carbon dioxide may result in reduced system efficiency unless they are integrated into a heat recovery system. At current levels of knowledge and expertise, practicality often leads to a choice of HFCs for good efficiency to be realistically achieved and maintained. In some applications, ammonia, carbon dioxide or hydrocarbons would be the preferred choice, but these refrigerants are not suitable for all applications. Good efficiency is vital to minimize emissions of greenhouse gases.
 
 
The practicality element will change as costs and design changes associated with HFC use evolve, and more components, experience and skills for ammonia, HCs and CO2 are developed. This can be expected to reduce the applications that require HFCs, but not eliminate them in the foreseeable future. Examples of highly practical HFC applications include split A/C systems, and in particular VRF combined cooling/heating systems. 
 
Arbitrary constraints on how designers can specify systems (such as bans on the use of specific refrigerant fluids) could result in less efficient systems being installed and will not drive the industry along the path of lowest GHG emissions.
 
To obtain ‘good efficiency’ attention needs to be given to the following steps:
 
1) Avoid refrigeration / reduce the cooling load. This is the most important first step – there is no point designing an efficient system if the load was unnecessary!
2) Get the overall system design right (e.g. best cycle, splitting loads at different temperatures onto different suction levels, etc. etc)
3) Get the control philosophy right (don’t forget the “off-design” operating conditions which are much more common than the peak “design point”, avoid head pressure control, avoid partly loaded compressors, avoid fixed speed auxiliaries like pumps and fans, etc. etc.)
4) Optimise individual components for efficiency (e.g. how big should heat exchangers be, which compressor has best efficiency etc.)
5) Operate and maintain the plant for best efficiency.
 
Mistakes in any of the above can change the efficiency of a plant by large amounts (e.g. 20% to 50%). Where does refrigerant selection fit in? It can either be thought of as a system design issue or a “component optimisation”. The impact of the refrigerant on efficiency is likely to be less than 5%, assuming all other design parameters are optimized.

The European Commission haslaunched a public consultation on strengthening EU measures.

The European Commission haslaunched a public consultation on strengthening EU measures to reduce emissions of fluorinated gases. 

The consultation runs until 19 December 2011 and is addressed to all interested stakeholders. A Commission review adopted on 26th September 2011 concludes that the EU's existing Regulation on fluorinated gases ('F-gases') is having a significant impact but that, without further measures, F-gas emissions are expected to remain at today's levels in the long term. The review suggests wide scope for further cost-effective emission reductions, mainly due to the growing feasibility of replacing F-gases in several sectors with alternatives that make less or no contribution to climate change. It finds that potentially the EU could eliminate up to two thirds of today's fluorinated gas emissions by 2030. The potential policy options being consulted on include new voluntary agreements, bans for new products and equipment and the introduction of a scheme for phasing-down the placing of HFCs on the EU market.
 
Connie Hedegaard, European Commissioner for Climate Action, said: "The EU Regulation on fluorinated gases has successfully broken a growing trend in emissions and driven technological innovation. However, making the transition to a competitive low-carbon EU economy by 2050 requires ambitious action to cut emissions from all sectors. It is clear there is considerable scope for cost-effective reductions in F-gas emissions and following the public consultation I intend to propose new legislative measures next year."
| F-GAS | F GAS Regulations & Legislation, News, Articles & Information
"The refrigerant R22 is one of many currently in use in refrigeration and air conditioning equipment which is classified as an Ozone Depleting Substance."

New requirements for use of R22 refrigerant

The refrigerant R22 is one of many currently in use in refrigeration and air conditioning equipment which is classified as an Ozone Depleting Substance (also known as an HCFC refrigerant), and which comes under the EU ODS Regulations.  These regulations were recently revised and additional obligations have been placed on owners regarding leak checking, record keeping and labelling In addition the Commission has provided some definitions related to the recovery and reuse of ODS refrigerants in stationary rac and heat pump equipment. These are summarised below.

1. CONTINUED USE OF HCFCs

The phase out dates remain unchanged:
  • from 1st January 2010 it is illegal to use virgin HCFCs to service RAC equipment. This ban applies even if HCFC was purchased before the ban date. It is illegal to stockpile and use any supplies of virgin HCFCs after the end of 2009.
  • from 1st January 2015 it will be illegal to use recycled or reclaimed HCFCs to service RAC equipment.
Note: these bans refer to the “use” of HCFCs for servicing and maintenance. Customers can continue using RAC equipment containing HCFCs beyond the phase out dates provided that no additions of refrigerant are required.
 
Any company anticipating using reclaimed HCFCs to maintain systems after the end of 2009 should contact their refrigeration supplier to discuss how to meet the anticipated demand. Due to the impending deadline on the use of virgin HCFCs, suppliers are likely to run-down their stocks of virgin gases before the actual deadline, so stocks may become limited before the end of December 2009.
 
2. RECLAIMED OR RECYCLED?
 
The new legislation includes an important distinction between “recycled” and “reclaimed” gases.
 
Recycled HCFCs are recovered HCFC that has been subject only to a basic cleaning process (this might include mechanical filtering and moisture removal). Recycled HCFCs may only be used by either the undertaking which carried out the recovery (in most cases the refrigeration contractor) or the undertaking for which the recovery was carried out (the owner). Recycled HCFCs may not be placed on the market – "placing on the market" means the supplying or making available to third persons within the Community for payment or free of charge. For example, the owner could use the recycled. HCFC in RAC equipment at other sites they operate from but they cannot sell recycled HCFC to a third party.
 
Reclaimed HCFCs are recovered HCFC gas that has been chemically reprocessed to a specified standard. Reclaimed HCFCs may be placed on the wider market and used by undertakings other than the original contractor and owner. Reclaimed HCFCs must be held in containers labelled as such, with information on the batch number and name and address of the reclamation facility. Reclaimed material has been reprocessed to a specified quality that is suitable for use in a refrigeration system whereas recycled material is of an unknown quality – it might contain contaminants that could impair the performance of a refrigeration plant.
  
Labelling of equipment using recycled or reclaimed HCFC
Where recycled or reclaimed HCFCs are used, the RAC equipment must be labelled to show:
· The quantity and type of recycled/reclaimed HCFC added in the system, and
· Other label elements set out in Annex I to Regulation EC/1272/2008
 
 3. SUMMARY OF OTHER NEW REQUIREMENTS
 
i. Leak testing and rectification
These new operator (or equipment end user) obligations are broadly similar to those of the EC F gas Regulation:
· to prevent and minimise any leakages and emissions of controlled substances.
· to carry out the new leak testing requirements as in the table below:
 
ii. Storage for recycling or reclamation
Before you recover HCFC refrigerant for recycling or reclamation you should consider the following points if the owner intends to store the materials on site:
· The holder should ensure that cylinders used to store recovered/recycled HCFCs remain within their statutory pressure test validation period.
· Recovered HCFCs pending recycling or reclamation are hazardous waste subject to the Hazardous Waste Regulations. Facilities storing recovered HCFCs must register with the Environment Agency as an exempt waste operation. Storage of recycled or reclaimed HCFCs does not require a permit.
 
iii. System record keeping
· Users of equipment containing over 3 kg of HCFC refrigerant must keep a record of the quantity and type of any gases removed or added, and of the company or technician carrying out the service or maintenance.
· Undertakings using recycled or reclaimed HCFCs for service or maintenance must keep records of the undertakings which supplied the reclaimed gases and the sources of recycled gases.

4. WHERE TO GET MORE INFORMATION
 
Further advice on HCFC phase out strategies, solutions and decision criteria are available in the full information sheet “RAC 8—R22 Phase out” available from F Gas support. Additional leaflets on all aspects of the F Gas (HFC) and ODS (HCFC) Regulations are available at www.defra.gov.uk/fgas  :
 
RAC 1– Overview
RAC 2 – Usage of F gases and ODS
RAC 3 – Key Obligations
RAC 4 – Getting Started
RAC 5 – Certification of personnel and companies
RAC 6 – Practical Guidance including details of labelling requirements
RAC 7 – Refrigerant Selection covering alternative refrigerants
RAC 8 - R22 Phase Out
Sample log sheet: in PDF or word format
 
F Gas Support - UK Government have set up a free helpline to deal with individual queries about the F Gas Regulations and to provide a central resource for information, particularly for end users but also for anyone else affected by the F Gas or ODS Regulations. The following contact points are now in operation:
Telephone Helpline: 0161 874 3663   Email: Fgas-support@enviros.com   Website: www.defra.gov.uk/fgas 

Key Dates for those working on stationary refrigeration air conditioning and heat pump equipment (over 3kg charge size/6kg herm)

Important notes to consider.

9 April 2007
GB ODS Qualifications Regulations 2006 No1510 require anyone handling ODS refrigerants in stationary equipment to hold either City and Guilds 2078 or CITB equivalent.
 
4 July 2007
Under EU F gas Regulation No 842/2006 operators of stationary refrigerating equipment now have to:
  • Prevent leakage - have leaks repaired as soon as possible by certified personnel and keep service and maintenance records detailing quantity and type of F gas used.
  • Carry out a regular fixed schedule of inspections for leaks for equipment with a circuit charge of 3kg or more following a standard leak checking and procedure laid down by the Commission. This includes an obligation to check repairs made within one month.
  • Where systems have a charge of over 300kg they must in addition install fixed leakage detection systems.
  • Ensure the proper recovery of F Gases by certified personnel, to ensure their recycling, reclamation or destruction
Additionally it should be noted that the placing on the market of non refillable containers of F gases has now been banned. Containers already placed on the market at that date can still be sold.
 
1 April 2008
New Products and new field assembled systems containing HFC have to  be appropriately labeled when they are first placed on the market.

9th March 2009
GB F Gas and ODS Training Regulations came into force, naming the new qualifications and confirming that operatives holding an existing qualification City & Guilds 2078 or valid CITBJ01 by this date would be considered to be temporarily with an interim certificate - allowing them until July 2011 to update their qualifications to the new standard.

4 July 2009
Companies who employ operatives who undertake activity within the scope of the F Gas Regulations must have obtained a Company Certificate to continue to carry out this work.
 
1 January 2010
Under the EC (ODS) Regulation 2037/2000 No virgin HCFC can be supplied or used for servicing existing equipment
 
4 July 2011
Personnel carrying out service, maintenance, recovery or leak checking on stationary refrigeration equipment containing refrigerants covered by the F Gas Regulation must have obtained one of the updated national qualifications (C&G 2079 or CITB J01)
 
1 January 2015
Under the EC (ODS) Regulation 2037/2000 No recycled or recovered HCFC can be supplied or used to service existing equipment.  

Questions and answers for contractors

Below is an importand list of frequently asked questions and answers.

Contractors - your obligations 
 
I employ engineers who work on RAC Systems containing F gases – who needs re-training?

You must use only qualified personnel for installation, commissioning, service or other refrigerant handling activities on stationery RAC systems that use HFC or HCFC refrigerants.  The qualifications that are acceptable in the interim period - CITB J01 and C&G 2078 - do not meet the new minimum standards set out in Commission Regulation 303/2008, but where individual hold these certificates issued before 9th March 2009 they are considered to be be valid until July 2011 to work on RAC containing F gases. The only exception is for those working on equipment with a refrigerant charge of less than 3 kg where there may also be the option to hold an in-house qualification or to apply for an interim certificate based on previous experience
           
What are the new training courses and where can I find a training centre?

Qualifications from CITB and C&G that meet the minimum requirement of the Commission Regulation 303/2008 became available earlier this year - C&G 2079 and CITB J11-14.   To remain working in the RAC sector on equipment containing F gases relevant personnel will need to gain one of these qualifications by July 2011.

The ACRIB website has a regularly updated list of F Gas training providers and shows the length and style of training available at www.acrib.org.uk .
 
Where can I get a company F Gas certificate?

Your company should be certificated by 5th July 2009 if it carries out activities specified in the regulations.  The details of this new scheme are were released in June 2009 and three bodies have been appointed to issue company certificates.

 
How will the regulations affect the systems I am installing now?
  • Article 10 of the EC Regulation No 1516/2007 requires that all newly installed equipment should be checked for leakage immediately after installation
  • If you install stationery systems containing 300 kgs or more of F gas then they will need to be fitted with ‘automatic leak detection systems’
  • You should be aware that any new system placed on the market or fitted must be fitted with a label clearly stating the type and quantity of HFC refrigerant used.   
  • Regarding split systems, the method of installing can affect whether it can be labelled as hermetically sealed or not, which can determine obligations under the regulations for certain sized systems.
  • All personnel doing installation work that relates to the refrigeration circuit (e.g. joining pipework, evacuation, charging, leak testing etc.) must have a suitable qualification.
Are there any changes to how I handle and store refrigerant containers ?

Any containers you use to fill equipment should be returned so that any remaining gas can be recovered and if appropriate they can be re-used.  The use of non-refillable containers for transporting or storing F gas refrigerants is banned. Placing on the market of non-refillable containers used to service equipment is banned from July 2007, except for those already filled at that time.
 
What records do I need to keep?
As a refrigeration contracting business you must keep records of:
  • Personnel qualifications & training
  • Imports & exports outside EC    
  • Recovery of HCFCs that you intend to resell after 1st Jan 2010 (details are awaited on the format of these records)
  • Records for any of your own in-house RAC systems  
Don’t I need to keep records of refrigerant used?

Under the EC F gas Regulation it is the responsibility of the operator to keep records of relevant information specifically identifying any stationary RAC equipment on site that contains 3 kg or more of HFC refrigerant. This includes separate records on each piece of equipment identifying work completed, by whom, when and why, detailing any results and follow up actions. The records must also specify quantities of refrigerant added/removed at the time along with details of what was done with recovered refrigerant.   Many operators have previously relied on their contractors to do this for them, often resulting in the loss of information when contractors change. The obligation on operators to keep records will mean that information is not lost but kept on site or centrally by the operator.
 
Where can I get more information on all of this?

F Gas support published a range of free detailed guidance notes at www.defra.gov.uk/fgas . The following will be most helpful on these topics:
  • RAC 3 - Key Obligations including definitions of hermetic systems, system records
  • RAC 5 - Certification of personnel and companies  
  • RAC 6 - Practical Guidance and FAQs including labelling of new equipment you fit.

Skills and Training Chapter of BRA and IOR Guide to Good Commercial Refrigeration Practice published - 11/9/2008

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The Guide will be published in 9 separate Parts beginning in September 2008 with Part 9 ‘Assessment of Skills Related Competence and Training’ which is now available as a free download.
Part 9 of the Guide has been prepared in conjunction with the Air Conditioning and Refrigeration Industry Board (ACRIB), and its subject matter will be of great importance to companies and individuals working in the HVACR sector
The aim of the complete Guide is to build up over the next six months into a standard industry reference document providing authoritative information on the good practice requirements for design, installation, commissioning, operation and service & maintenance for commercial and light industrial applications.
Each section of the Guide will be fully up to date with current legislation requirements and also deals with the need to ensure that the most efficient solutions are applied to both new and existing installations and consideration given to options for choice of refrigerant
The Guide will eventually be published in the following Parts:
Part 1:Introduction
Part 2:System design and Component Selection
Part 3:Safety regulations, standards and directives
Part 4:System Installation                                                                        
Part 5:System Commissioning                                                                         
Part 6:System Maintenance and Service
Part 7:System and component decommissioning and waste disposal
Part 8:Refrigerants and Retrofitting
Part 9:Assessment of skills related competence and training 

Parts 4 ‘System Installation’ and 5 ‘System Commissioning’ will follow shortly after Part 9.

The BRA and IOR are delighted to be producing  the new Guide as a cross industry collaboration, and are indebted to ACRIB’s Education and Training Committee for their key role in producing Part 9.

COUNTDOWN TO THE F GAS REGULATIONS

What needs to be done and when?

The European Union's F-gas Regulation No 842/2006 became law on 4 July 2006 and many of the requirements came into force on 4th July 2007 however, some of these requirements are still awaiting clarification from the Commission. The table below helps to outline what you need to do now.

F-gases include all HFC refrigerants, such as R134a, and blends containing F Gases such as R407C, R410A, R404A. If you are handling, recovering, supplying, installing, manufacturing or own equipment containing HFC refrigerants in stationary equipment you now have new legal obligations under the F Gas Regulations.

UK RAC industry prepares for mandatory assessment of workforce skills

The European Commission has now finalised its detailed requirements for the training and certification of engineers working on stationary refrigeration and air conditioning equipment under the European Fluorinated Gases Regulation – known as the F Gas

Whilst most UK engineers have been assessed in refrigerant handling to the City and Guilds 2078 or CITB standard over the past 15 years, the new F Gas standard will be a much more thorough and wide ranging examination. It will include a range of observed practical assessments and a multiple choice examination which will test the knowledge of underpinning principles.  
 
 John Ellis, Past President of the IOR and Past Chairman of ACRIB who has reviewed the specification in detail comments “This is the first time that an assessment specification has been written into a Regulation on refrigerant handling. There is no doubt it will be tough to comply with but it would have been a lot worse without the work of ACRIB and DEFRA negotiating at a European level.”
 
Since the Commission finalised the requirements in December 2007, industry representatives through ACRIB have been working with existing awarding bodies (City and Guilds and CITB) to come up with a top-up qualification for those who already have refrigerant handling or S/NVQ qualifications. The new F Gas qualification is still under development and consultation, and will be presented to UK Government at the end of January.
 
Given that the whole of the existing workforce of up to 40,000 engineers will need to take all or part of the new assessment, one of the key briefs was for this to be as efficient as possible in terms of the time taken. It is expected that it will take approximately 4 hours for each candidate to be assessed by a qualified assessor. The level of training needed to get technicians up to the standard necessary to pass the assessments will depend on the prior qualifications, experience and knowledge of the individual. It is likely that this could be up to four days however, because much of the assessment is theoretical and covers principles of refrigeration required to assess performance of systems and their energy efficiency.
 
Jane Gartshore President of the IOR welcomed the work ACRIB is doing and said “We should not forget that whilst there will be a cost to industry, the F Gas training will also improve standards of competence throughout the workforce”
 
Training providers and colleges should be able to register to deliver the new qualifications early in the Spring with the first assessments going ahead in early July, when the requirements for F Gas Personnel Certification were due to come in. However with the current limited provision of training and the significant changes and challenges that the new F Gas qualifications will present, it is expected that it will take some years to get the whole of the UK workforce re-certified. Only those who have taken the new F Gas assessment will be recognised as competent throughout the whole of Europe, so in order to work with F Gas refrigerants, the sooner the new certificate is obtained the better.
 
The Commission requires that all technicians should have obtained this new qualification by January 2009. However the  UK Government will be consulting in the early summer on whether to allow a further three years (up to July 2011) for existing personnel to obtain the new qualification. ACRIB is pressing to ensure that the UK is granted an extension of the full three years to complete certifications. In the mean time , of course,  the existing certificates C&G 2078 or CITB equivalent  continue to be the existing national legal requirement for both F Gas and ODS refrigerant handling. The ACRIB voluntary register provides proof of competence through a register and card scheme. 
 
These requirements will be enforced by a Statutory Instrument expected to be published early this year which will lay down penalties for infringement. A programme of enforcement is currently being prepared by Government based on an awareness campaign targeting the key business sectors responsible for emissions of F Gases and gaining high level commitment to meeting the requirements of the Regulation from these businesses.
 
The Commission also recently agreed the principles for a Company registration scheme. Companies employing certified personnel will need to be registered, but again the deadline may be extended until July 2011. If so, companies will need an interim certificate by July 2009. The Government will be consulting on possible arrangements for the issuing of these interim company certificates and the length of the transitional period.
 
Guidance on the education and training requirements and all other aspects of the Regulation including the full text of the Regulations are available from ACRIB and its member organisations in the dedicated section of this website.

New obligations from 4th July - 3/7/2007

 EC Regulation No842/2006 on certain fluorinated greenhouse gases
 
The principal objective of the EC Regulation is to prevent and thereby reduce emissions of F Gases covered

Obligations coming into force on 4 July will have direct effect on those affected without any further legislation by the Government.
 
Containment and recovery
Key requirements include leakage checking and repair by certified personnel (Article 3) and proper recovery by certified personnel (Article 4). Sectors affected include (article 3) stationary commercial and domestic refrigeration, air conditioning, heat pump and fire protection sectors as well as (Article 4) the recovery of F gases from these systems as well as from equipment containing fluorinated greenhouse gas based solvents and high voltage switchgear and mobile equipment (where this is technically feasible and does not entail disproportionate cost).
 
The containment and recovery articles in the F Gas Regulation (Articles 3 and 4) will have an impact on operators of relevant systems (typically a company) that will have a range of obligations including record keeping and ensuring certified personnel are used.
 
Reporting
The Regulation will also have an impact on producers, importers and exporters of F gases if they produce, import or export more than 1 tonne of F gases per annum as there is a requirement in the Regulation to report to the Commission and member States’ competent authorities on the amounts produced, imported or exported. The first report has to be submitted to the Commission by 31 March 2008.
 
Placing on the market/use bans
Specific uses of F gases and products that contain F gases are controlled or banned by the Regulation. These are set out in Articles 8 and 9 and cover certain uses of sulphur hexafluoride for magnesium die-casting, use of certain F gases in non-refillable containers, fire protection systems, tyres, one component foams, novelty aerosols, footwear and windows and self-chilling cans well as placing on the market prohibitions of specific products containing, or whose function relies upon, F gases.
 
Upcoming requirements
Several stakeholder bodies are continuing to assist Defra/DTI with the work being led by the European Commission to develop minimum qualification requirements for relevant sectors that will apply from 4/7/08 subject to transitional arrangements (which may run through to 2011 for most sectors). Stakeholders are also providing assistance in relation to Commission proposals for labelling and reporting. The labelling requirement will not come into force until the label has been agreed and a date specified for its application to products placed on the market (currently likely to be about mid-2007).
 
More information
The Government is continuing to work with stakeholders to ensure that the F Gas regulation is successfully implemented and its environmental objectives achieved. In this context, Defra is currently consulting on Regulations prescribing offences and penalties applicable to infringements of the EC Regulation. These are likely to come into force in November. The consultation can be accessed using the following link:
 
 
Further information on the F Gas Regulation and how it is being implemented in the UK, including guidance and frequently asked questions, is available on the Defra website at the following link:
 

NEWS UPDATE MARCH 2007

The Air Conditioning and Refrigeration Industry Board has added two new guidance notes to its website.

F Gas Regulation update

The first provides information for End Users (owners or operators of refrigerating equipment) regarding their obligations under the F Gas Regulation.  This one page definitive guide is endorsed by DTI and DEFRA, and states the dates by which the key obligations will come into force.  If you would like further supplies of this leaflet for distribution to clients and customers please contact acrib for details.

UK Government is expected to consult during April on a draft piece of legislation on penalties for infringement of the F Gas Regulation and specifying interim minimum refrigerant handling qualifications which will apply in the UK until July 2008 by which time the EU will have clarified what the European requirements will be.  Details will be available from the ACRIB and DTI websites as soon as this is available.

Negotiations are taking place at the F Gas Regulatory Committee in Brussels regarding minimum standards for certification of individuals and companies as well as leak testing procedures.  ACRIB has provided substantial input regarding existing UK qualifications and registration schemes in refrigerant handling via the UK Defra and Dti representatives.

WEEE Regulations

Detailed guidance on the Waste Electrical and Electronic Equipment Regulation of 2006 has recently been published and this 80-page document can also be downloaded from the ACRIB site.  It outlines obligations of producers and distributors of electrical and electronic equipment under the regulation.

Consultation on Proposals for offences and penalties and enforcement in relation to EC Regulation 842/2006 on Certain Fluorinate

 

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| F-GAS | F GAS Regulations & Legislation, News, Articles & Information
"As part of the European Union’s obligations under the Kyoto protocol, the community has taken action to regulate fluorinated gases."

F-GAS REGULATIONS

After a long process through the European Parliament the F-Gas regulations became law when they were published in the EU Official Journal in June 2006. They entered

The objective of this regulation is to contain, prevent and thereby reduce emissions of the fluorinated greenhouse gases covered by the Kyoto Protocol. The regulation addresses containment, use, recovery, destruction, reporting, labelling, training, certification and some placing on the market prohibitions for the fluorinated gases.

 

HFCs are one group of fluorinated greenhouse gases covered by this legislation.

 

The regulation does not ban the use of HFCs in any static refrigeration or air conditioning application. There is, however, a huge onus upon those working in the industry to apply these measures so that emissions are significantly reduced.

 

The relevant parts affecting the refrigeration and Air Conditioning industry are detailed below.

 

CONTAINMENT (article 3)

 

Operators of stationary refrigeration, air conditioning and heat pump equipment shall use all measures which are technically feasible and do not entail disproportionate cost to prevent leakage of HFCs and as soon as possible repair any detected leakage.

 

An operator is defined as; the natural or legal person exercising actual power over the technical functioning of the systems covered by this regulation. A member state may in specific situations designate the owner as being responsible for the operator’s obligations.

 

These operators shall ensure systems are checked for leakage by certified personnel, as defined by the training and certification requirement and to the following schedule;

 

Leakage inspection

 

Systems shall be checked for leakage dependent on refrigerant charge: 

  • 3kg charge and above - check at least once every 12 months.
  • 30kg charge and above - check at least once every 6 months.
  • 300kg charge and above - check at least once every 3 months.

Hermetically sealed systems, which are labelled as such and contain less than 6kg, are exempt.

 

The application shall be checked for leakage within 1 month after a leak has been repaired to ensure the repair was effective.

 

If a properly functioning appropriate leak detection system is in place, the frequency of the checks required for systems with 30kg or more are halved.

 

Operators of equipment containing 300kg or more shall install leakage detection systems.

 

These must be checked at least once every twelve months to ensure they are functioning properly.

 

‘Checked for leakage’ means that the system is examined for leakage using direct or indirect methods, focusing on those parts of the system most likely to leak.

 

By 4th July 2007 the commission shall establish the standard leak checking requirements.

 

Record keeping

 

Operators of equipment containing 3kg or more will need to maintain records on the quantity and type of HFC installed. Any quantities added or recovered during maintenance, servicing and final disposal will need to be recorded along with leak checks, actions taken, the name of the service Company, the engineer / technician who performed the servicing and maintenance, dates and results of inspections. These records have to be made available to the competent authority upon request.

 

RECOVERY (article 4)

 

Operators of refrigeration, air conditioning and heat pump equipment are responsible for putting in place arrangements for the proper recovery by certified personnel, who comply with the training and certification requirements, of fluorinated greenhouse gases to ensure their recycling, reclamation or destruction.

 

Recovery, for the purpose of recycling, reclamation or destruction must take place before the final disposal of that equipment and where appropriate, during its servicing and maintenance.

 

When a refillable or non-refillable container reaches the end of its life, the person utilising it for transport or storage purposes is responsible for putting in place arrangements for the proper recovery of any residual gases it contains to ensure their recycling, reclamation or destruction.

 

TRAINING AND CERTIFICATION (article 5)

 

By 4th July 2007 The European Commission must define minimum qualifications for both companies and personnel using fluorinated greenhouse gases.

 

By 4th July 2008 Member States shall establish or adapt their own training and certification requirements for companies and all relevant personnel involved in installation, maintenance and servicing based on the minimum qualifications.

 

The operator of the relevant application shall ensure that relevant personnel have obtained the necessary certification which implies appropriate knowledge of the applicable regulations and standards as well as the necessary competence in emission prevention and recovery of fluorinated greenhouse gases and handling safely the relevant type and size of equipment.

 

By 4th July 2009 Member States must ensure that companies involved in activities affected by containment and recovery will only take delivery of fluorinated greenhouse gases where their relevant personnel hold the required training and certificates.

 

REPORTING (article 6)

 

For the calendar year 2007 each producer, importer or exporter of more than 1 Tonne of fluorinated greenhouse gases must report quantities to the Commission.

 

Member states will have to establish reporting systems for the relevant sectors with the objective of acquiring emission data.

 

LABELLING (article 7)

 

In addition to existing labelling requirements, all equipment or product placed on the market for the first time from 4th July 2007 must have a label identifying the chemical name of the fluorinated greenhouse gas using the accepted industry nomenclature. Such a label also needs to indicate that the product or equipment ‘contains fluorinated greenhouse gases covered by the Kyoto Protocol’. This should be clearly and indelibly stated with the quantity adjacent to the service points for charging or recovery. The form of the label to be used will be established by the EU commission and may require further information. It is hoped this information will be available well in advance of 4th July 2007.


Hermetically sealed systems will need to be labelled as such.

 

Information on the fluorinated greenhouse gases, including their global warming potential must be included in the instruction manuals provided for products and equipment.

 

PLACING ON THE MARKET (article 9)

 

A ban on disposable cylinders applies from 4th July 2007. The ban does not apply to cylinders filled prior to that date.

 

HFCs and PFCs are banned from use in new non-confined direct evaporation systems from 4th July 2007.

 

REVIEW (article10)

 

The EU Commission will publish a report by 31st December 2007 for air conditioning systems and refrigeration systems in modes of transport other than motor vehicles. If appropriate the containment provisions may apply from by 31st December 2008.

 

By 4th July 2011 the EU Commission will publish a full report based on the experience of the application of this regulation and may make proposals for revision of the regulation.

 

DEFINITIONS

 

‘Hermetically sealed system’ means a system in which all refrigerant containing parts are made tight by welding, brazing or a similar permanent connection which may include capped valves and capped service ports that allow proper repair or disposal and which have a tested leakage rate of less than 3 grams per year under a pressure of at least a quarter of the maximum allowable pressure.

 

‘Leakage detection system’ means a calibrated mechanical, electrical, or electronic device for detecting leakage of fluorinated greenhouse gases which, on detection, alerts the operator.

 

AUTOMOTIVE A/C (cars and car derived vans)

 

This sector is covered by the MAC directive 2006/40/EC which also entered into force on 4th July 2006. Fluorinated greenhouse gases, such as R134a, with a GWP 150 or greater are banned in New type vehicles from 2011 and the ban extends to all new vehicles from 2017. It is illegal to retrofit air conditioning systems to vehicles type approved after 2011 or any new vehicle after 2017. Vehicles fitted with R134a air conditioning systems prior to these dates can continue to use the refrigerant for servicing.

 

Service providers shall not refill equipment with R134a if an abnormal amount of refrigerant has leaked from the system, until the necessary repair has been completed.

 

Further reviews and other implementation measures for reducing emissions are required by this directive.


 

 

EC Regulation No 842/2006 on Certain Greenhouse Gases

The principal objective is to contain, prevent and thereby reduce emissions of F gases covered by the Kyoto Protocol.

Air-conditioning Engineers Required ASAP!

We urgently require service engineers, please visit www.denmanair.com for more information.

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Drop-In Replacements

The term "retrofit" refers to replacing the refrigerant in a system for a more environmentally-friendly fluid.

Drop-in replacements do not require an oil change, and may require little or no replacement of elastomers and seals.

BOC supplies a range of drop-ins for refrigerants which are or will be banned under environmental laws.

Refrigeration and Air Conditioning industry asked to help shape registration schemes under new F Gas Regulation consultation

ACRIB has produced a Briefing Document summarising the key issues within the consultation and a template for responding to the consultation which can be downloaded below:

More detail - At a press briefing held on 5th August  the Air Conditioning and Refrigeration Industry Board, which represents key trade and professional associations in the sector, outlined the impacts of recently issued DEFRA draft legislation on the stationary refrigeration and air conditioning sector. The Board issued a call to action for the whole of the industry in response to the 11th July consultation on further implementation measures on F-Gases and Ozone Depleting Substances Regulations
 
The consultation and the draft Regulations reflect decisions that have been made at a European level over the past year few years. However significantly, DEFRA is now inviting views on establishing UK registration schemes which will influence the effectiveness of the application of these decisions in the UK. ACRIB is calling on the refrigeration and air conditioning industry to put forward a strong message of support on the critical issues of registration of companies and individuals.
 
ACRIB member organisations believe that only a fully integrated registration scheme will make these Regulations work in practice. This means company registration with regular audits and at least five yearly renewal, backed up by a single source low-cost individual registration scheme. This would reflect the current voluntary registration schemes which have had widespread support from industry to date, and which are managed for and by the industry by REFCOM and ACRIB.   No other bodies have the past experience and understanding of the RAC sector to be able to satisfy the requirements of the Regulations in the time available.
 
“Have no doubt about it. This piece of legislation will have an impact on every one of the 5,000 businesses and 35,000 individuals working in the use of F Gas refrigerants”. Mel Bridges, Chairman of the ACRIB Education & Training Committee comments: “Whilst is likely to cost us in this industry up to £35 million in training fees, Government is hesitating to specify the rigorous management structures which will be needed to ensure that everyone complies with these requirements. This is not acceptable. For a small cost of up to £700,000  to introduce mandatory individual registration and an additional £35,000 for a more rigorous company registration we can be reassured that the costs are shared by everyone, not just those responsible companies and individuals who would comply anyway. These costs also have to be weighed against DEFRA’s anticipated benefits of compliance with the Regulations of up to £257million when savings possible due to reducing leakage and improving energy efficiency are taken into account“
 
ACRIB F Gas Implementation Group Chairman Mike Nankivell commented “We are seeing for the first time some hard numbers from Government in terms of cost implications, cost savings and environmental benefits of the training and registration aspects of these Regulations. The ACRIB F-Gas Implementation Group have scrutinised the consultation documentation and come up with some key pointers for industry to respond to. We are working closely with end users, contractors and other representative bodies to make the most of the opportunity to influence the final shape of the regulations by the 3rd October deadline”.
 
This consultation is a unique window of opportunity to influence the future of the RAC industry. Widespread industry support for the registration schemes must be received by DEFRA by 3rd October 2008 so that the legislation can be finalised for implementation in February 2009. The basic company registration scheme must in place by July 2009. 
 
ACRIB wants to see 100% compliance with these Regulations to ensure that only responsible companies continue to operate and those who cut corners are prevented from undermining the sector. It sees the solution as an integrated registration scheme providing the benefits of:
  • Accurate and up to date records of individuals and companies operating in the sector to prevent fraudulent operation and use of forged certificates.
  • Single central databases for use by end users, employers and enforcement agencies to check the status of those working in the industry
  • An essential communication route to everyone in the industry to ensure they are up to date with any future changes in refrigerant handling legislation and to prove compliance in the future.
Mike Nankivell concludes “Questions 15,16,19 and 20 in the Consultation document are crucial. We need a strong and concerted message from industry if an integrated company and individual registration scheme is to be achieved. Without an appropriate steer from industry in response to this consultation, we will find ourselves subject to a series of bureaucratic, ineffective and impractical solutions”
 
ACRIB has produced a Briefing Document summarising the key issues within the consultation and a template for responding to the consultation which can be downloaded below:
 
 
Notes:
 
1. See full DEFRA Consultation at : http://www.defra.gov.uk/corporate/consult/fgas-ozone/. This includes a consultation document, regulatory impact assessment from which figures quoted are drawn and the draft legislation.
 
 
2. Consultation Questions:
  • Company certification for stationary refrigeration, air conditioning and heat pump equipment and fire protection systems
  • Question fourteen: Views are invited on what body or bodies might be designated by the Secretary of State as certification bodies and on what type of certification scheme is preferred?
  • Question fifteen: Do you have any comments on regulations 22 (certification bodies for companies), 23 (certificates for companies) or 24 (interim company certificates) or 25 (mutual recognition)?
  • Question sixteen: Do you have any comments on how the company certification schemes should be operated (i.e. renewal or nonrenewal?)
  • Question seventeen: Do you have any comments on regulations 29 (certification bodies for companies), 30 (certificates for companies) or 31 (interim company certificates) or 32 (mutual recognition)?
  • Question eighteen: Do you have any comments on how the company certification schemes should be operated (i.e. renewal or nonrenewal?
  • Personnel registration
  • Question nineteen: Would you like the Government to propose regulations to require mandatory personnel registration in a future consultation?
  • Question twenty: What reasons do you have for supporting or not supporting mandatory personnel registration?
3. Responses to the consultation must be sent by 3rd October to:
Stephen Cowperthwaite
Defra
Climate, Energy and Ozone, Science and Analysis Division
3F Ergon House
17 Smith Square
London SW1P 3JR
Tel 0207 238 3179
Fax 0207 238 3341
fgas@defra.gsi.gov.uk

Respond to draft F Gas regulation implementation measures - 5/8/2008

ACRIB has produced a Briefing Document summarising the key issues within the consultation and a template for responding to the consultation which can be downloaded below:
More detail - At a press briefing held on 5th August  the Air Conditioning and Refrigeration Industry Board, which represents key trade and professional associations in the sector, outlined the impacts of recently issued DEFRA draft legislation on the stationary refrigeration and air conditioning sector. The Board issued a call to action for the whole of the industry in response to the 11th July consultation on further implementation measures on F-Gases and Ozone Depleting Substances Regulations
 
The consultation and the draft Regulations reflect decisions that have been made at a European level over the past year few years. However significantly, DEFRA is now inviting views on establishing UK registration schemes which will influence the effectiveness of the application of these decisions in the UK. ACRIB is calling on the refrigeration and air conditioning industry to put forward a strong message of support on the critical issues of registration of companies and individuals.
 
ACRIB member organisations believe that only a fully integrated registration scheme will make these Regulations work in practice. This means company registration with regular audits and at least five yearly renewal, backed up by a single source low-cost individual registration scheme. This would reflect the current voluntary registration schemes which have had widespread support from industry to date, and which are managed for and by the industry by REFCOM and ACRIB.  No other bodies have the past experience and understanding of the RAC sector to be able to satisfy the requirements of the Regulations in the time available.
 
“Have no doubt about it. This piece of legislation will have an impact on every one of the 5,000 businesses and 35,000 individuals working in the use of F Gas refrigerants”. Mel Bridges, Chairman of the ACRIB Education & Training Committee comments: “Whilst is likely to cost us in this industry up to £35 million in training fees, Government is hesitating to specify the rigorous management structures which will be needed to ensure that everyone complies with these requirements. This is not acceptable. For a small cost of up to £700,000  to introduce mandatory individual registration and an additional £35,000 for a more rigorous company registration we can be reassured that the costs are shared by everyone, not just those responsible companies and individuals who would comply anyway. These costs also have to be weighed against DEFRA’s anticipated benefits of compliance with the Regulations of up to £257million when savings possible due to reducing leakage and improving energy efficiency are taken into account“
 
ACRIB F Gas Implementation Group Chairman Mike Nankivell commented “We are seeing for the first time some hard numbers from Government in terms of cost implications, cost savings and environmental benefits of the training and registration aspects of these Regulations. The ACRIB F-Gas Implementation Group have scrutinised the consultation documentation and come up with some key pointers for industry to respond to. We are working closely with end users, contractors and other representative bodies to make the most of the opportunity to influence the final shape of the regulations by the 3rd October deadline”.
 
This consultation is a unique window of opportunity to influence the future of the RAC industry. Widespread industry support for the registration schemes must be received by DEFRA by 3rd October 2008 so that the legislation can be finalised for implementation in February 2009. The basic company registration scheme must in place by July 2009. 
 
ACRIB wants to see 100% compliance with these Regulations to ensure that only responsible companies continue to operate and those who cut corners are prevented from undermining the sector. It sees the solution as an integrated registration scheme providing the benefits of:
  • Accurate and up to date records of individuals and companies operating in the sector to prevent fraudulent operation and use of forged certificates.
  • Single central databases for use by end users, employers and enforcement agencies to check the status of those working in the industry
  • An essential communication route to everyone in the industry to ensure they are up to date with any future changes in refrigerant handling legislation and to prove compliance in the future.
Mike Nankivell concludes “Questions 15,16,19 and 20 in the Consultation document are crucial. We need a strong and concerted message from industry if an integrated company and individual registration scheme is to be achieved. Without an appropriate steer from industry in response to this consultation, we will find ourselves subject to a series of bureaucratic, ineffective and impractical solutions”
 
ACRIB has produced a Briefing Document summarising the key issues within the consultation and a template for responding to the consultation which can be downloaded below:
 
Notes:
 
1. See full DEFRA Consultation at : http://www.defra.gov.uk/corporate/consult/fgas-ozone/. This includes a consultation document, regulatory impact assessment from which figures quoted are drawn and the draft legislation.
 
 
2. Consultation Questions:
  • Company certification for stationary refrigeration, air conditioning and heat pump equipment and fire protection systems
  • Question fourteen: Views are invited on what body or bodies might be designated by the Secretary of State as certification bodies and on what type of certification scheme is preferred?
  • Question fifteen: Do you have any comments on regulations 22 (certification bodies for companies), 23 (certificates for companies) or 24 (interim company certificates) or 25 (mutual recognition)?
  • Question sixteen: Do you have any comments on how the company certification schemes should be operated (i.e. renewal or nonrenewal?)
  • Question seventeen: Do you have any comments on regulations 29 (certification bodies for companies), 30 (certificates for companies) or 31 (interim company certificates) or 32 (mutual recognition)?
  • Question eighteen: Do you have any comments on how the company certification schemes should be operated (i.e. renewal or nonrenewal?
  • Personnel registration
  • Question nineteen: Would you like the Government to propose regulations to require mandatory personnel registration in a future consultation?
  • Question twenty: What reasons do you have for supporting or not supporting mandatory personnel registration?
3. Responses to the consultation must be sent by 3rd October to:
Stephen Cowperthwaite
Defra
Climate, Energy and Ozone, Science and Analysis Division
3F Ergon House
17 Smith Square
London SW1P 3JR
Tel 0207 238 3179
Fax 0207 238 3341
fgas@defra.gsi.gov.uk

The objectives of the F-GAS Regulation


The principal objective is to contain, prevent and thereby reduce emissions of f-gases covered by the Kyoto Protocol. This Regulation will make a significant contribution towards the European Community's Kyoto Protocol target by introducing cost-effective mitigation measures and to prevent distortion of the internal market. The main focus is on containment and recovery of f-gases, together with harmonised restrictions on the marketing and use of f-gases in applications where containment of f-gases is difficult to achieve or the use of f-gases is considered inappropriate and suitable alternatives exist.

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