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

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

Update on F Gas Regulation training

The ACRIB F Gas Implementation Group has been successful in highlighting to DEFRA the need for a reasonable period of time to be allowed for compliance with the new training and certification requirements. Indications from the DEFRA stakeholder meeting he

DEFRA confirmed at the Stakeholder meeting of 28th February that they are in the process of drafting legislation concerning the training and certification requirements. They are working closely with ACRIB on issues related to this. A draft is expected to be available for public consultation from June and the legislation likely to come in from February 2009.  
 
A Statutory Instrument SI2008/41 came into force on 15th February this year which listed the existing C&G 2078 and CITB Refrigeration Handling as the current legal minimum qualifications to handle refrigerants covered by the F Gas Regulation until new qualification schemes become available.
 
Whilst those holding existing qualifications (ie City and Guilds 2078 or CITB Refrigerant Handling) will be able to continue to work legally until 2011 employers would be well advised to ensure that their existing workers have achieved the new update qualification as soon as this becomes available. The training capacity in the UK is limited and there are approximately 30,000 individuals who will need to be reassessed to the updated qualification standard.   The next few years will allow employers to spread the time and cost obligations sensibly.
 
ACRIB is helping industry and training providers to be prepared well in advance of the deadlines and the updates to the existing refrigerant handling qualifications are now nearing completion. ACRIB, CITB and City and Guilds together with SummitSkills have held a number of meetings with DEFRA on this matter. The updated qualifications will be available soon this summer and will be based on a practical skills test and a multiple choice theory test. The National Vocational Qualifications (NVQs or SVQs) designed for trainees are being updated to take into account the F Gas Regulation requirements.
 
Training providers have yet to go through a re-accreditation process to ensure that they have sufficient knowledge and equipment to deliver the new qualification. ACRIB, with the awarding bodies, is developing strict standards of assessment for the new qualifications. It is in everyone’s interest that the new qualifications have a real and lasting impact on improving skills to reduce leakage and demonstrating that our workforce has met the minimum standard as specified in the Regulation.     
 
The ACRIB Register will be accepting the updated qualifications as evidence of competency to join the register when these are available.
DEFRA have now launched an F Gas Support Team which can take individual queries on the regulation at Fgas-support@enviros.com, help line 0161 874 3663.
 
 
A summary of key dates
  
9th 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.
 
4th 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 (can be downloaded at http://www.berr.gov.uk/sectors/sustainability/fgases/page28889.html) . This includes an obligation to check repairs made.
  • 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.
 
15th February 2008
GB Regulations (SI 2008 No. 41) are now in force naming the interim qualifications for working with stationary refrigeration/air conditioning equipment containing 3kgs or more of F gases as City and Guilds 2078 and CITB equivalent .
 
1st April 2008
New Products and new field assembled systems containing HFC have to  be appropriately labeled when they are first placed on the market. Instructions regarding the label format can be downloaded at http://www.berr.gov.uk/sectors/sustainability/fgases/page28889.html
 
Between now and July 2011
UK Government will need to establish personnel and company certification programmes to meet the new EU requirements as agreed in December 2007 by the Commission. 
  • A consultation on proposed GB Regulations will be issued by Government in early summer of 2008 specifying minimum requirements for personnel and companies. For existing workers, this is likely to take the form of an update qualification based on revised City and Guilds and CITB refrigerant handling assessments. This qualification is currently under development by ACRIB and should be available from July 2008.
  • Personnel holding an existing 2078/CITB certificate are likely to be “deemed to be certified” under the Regulation until they have achieved the updated national qualification.
4th July 2009
Only companies with certified personnel can take delivery of refrigerants covered by the FGas Regulation
 
1st January 2010
Under the EC (ODS) Regulation 2037/2000 - No virgin HCFC can be supplied or used for servicing existing equipment
 
4th 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.
 
1st January 2015
Under the EC (ODS) Regulation 2037/2000 - No recycled or recovered HCFC can be supplied or used to service existing equipment.  This date is currently under review by the European Commission and may be brought forward to 2012 for industrial process refrigeration.

Energy Performance of Buildings Directive - inspections of air conditioning equipment

Article 9 of the Energy Performance of Buildings Directive (EPBD) requires the “routine inspection of air conditioning systems”.  The relevant Government Department DCLG invited CIBSE and FETA to develop the UK methodology for carrying

The DCLG have now introduced the UK regulations ( SI2007:991 and SI 2007:1669) which make routine inspections of all AC systems over 12kW a legal requirement. 
 
Further guidance is anticipated from the DCLG shortly, but in the meantime the guidance to building owners is as follows:
 
  • Mandatory inspections are being introduced for all air-conditioning systems with rated cooling output greater than 12kW. This includes the combined output of one or more individual air conditioning units in the building.
  •  If your air conditioning system has a rated output greater than 250 kW, you must have had your first inspection by 4th January 2009.
  • If your air conditioning system has a rated output greater than 12kW, but less than 250kW you must have had your first inspection by 4th January 2011.
  • Thereafter, inspections will be required every 5 years.
  •  For new systems installed on or after 1 January 2008, the first inspection must have taken place within 5 years of the installation date.
  • The method for the inspections is in CIBSE TM44 http://www.cibse.org/index.cfm?go=publications.view&item=372

The DCLG are appointing approved bodies who will provide accreditation for those carrying out the assessments on air conditioning equipment.  At the moment the bodies are:

The DCLG website has further information at http://www.communities.gov.uk/planningandbuilding/buildingregulations/

Changes to SNVQ Refrigeration Qualifications - your last chance to comment - 7/2/2008

SummitSkills have been reviewing the national occupational standards that underpin the SNVQ qualifications – qualifications that shape the future of the industry as young people are trained and assessed in refrigeration and a

This is your last opportunity to influence the structure of the new qualifications.
Your input to and endorsement of the proposed new structures is required.  You will only have until the end of next week – Friday 15th February to make your views known.  I know this is short notice, but it is a one-off opportunity and if no significant response is received by our sector, SummitSkills will assume that the RAC employers are in complete support with everything proposed in the documentation. 
For those involved in the delivery of training ie colleges and training providers it is also important that you comment on these drafts as this again may be your one and only chance to do so before revised qualifications are developed by City and Guilds.
Responses must be submitted on line where there are specific questions on the titles and range of the units proposed, and a space for general comments.  Please use the General Comments area to raise any questions or concerns you may have.
1. In summary the draft papers suggests that the qualifications titles be changed to:
2. A specific number of units will make up each qualification with optional units in carbon dioxide, ammonia or heat pumps available at Levels 2 and 3
3. There is also scope to introduce a  Final Competence Assessment Unit (FCAU) as an assessment of competence in performance and knowledge.  The draft states that “this will not necessarily require a separate assessment, but could take the form of an assignment, or test”.  It is not clear how this would impact on the current structure which includes a Technical Certificate which is externally set and externally marked in an independent fashion.
The full draft for the R&AC units (20 pages) is available for download.  You can view more details of the consultation process and drafts for other sectors at the website www.summitskills.org.uk/nosreview 

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.

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.
| 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 

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."

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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