EU F-Gas Regulation Guidance Information Sheet 14: Refrigeration, Air-Conditioning and Heat Pump Contractors
This information sheet is aimed at contractors that carry out installation, maintenance and decommissioning work on refrigeration, air-conditioning and heat pump systems (RACHP). It is also useful for operators of RACHP systems that use 3rd party contractors to maintain their plant.
This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6.
Contractors play a major role supporting operators of refrigeration, air-conditioning and heat pump (RACHP) equipment. They have to comply with a number of requirements under the F-Gas Regulation. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.
The F-Gas Regulation is an important piece of legislation that will result in significant reductions in the emissions of F-Gases. These are very powerful greenhouse gases, with global warming impacts that are several thousand times higher than CO2 (per kg of gas emitted). All EU Member States agree that it is important to reduce emissions of these gases.
This Information Sheet describes the requirements that apply to RACHP contractors. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms.
2. Sector description
The RACHP sector covers a wide range of equipment and end users, ranging from small domestic and commercial systems to large industrial plant. Key sectors of the RACHP market include
Detailed guidance on the impact of the 2014 F-Gas Regulation on each of these sectors is available in Information Sheets 1 to 6.
Most operators of RACHP equipment in these sectors make use of specialist contractors for installation and maintenance work. There are over 5,000 RACHP contractors in the UK, ranging from large companies with UK-wide capability to very small businesses working in a small geographic area. The skill and expertise of the RACHP contracting industry is crucial, providing operators with various services through the life cycle of RACHP equipment.
The F-Gas Regulation places legally binding obligations on contractors to ensure that they help end users minimise the use and emissions of high GWP refrigerants. It is important that contractors comply with the Regulations that apply to them and also that they are aware of other relevant parts of the F-Gas Regulation so that they can provide their clients with appropriate advice.
3. Advice regarding purchase of new equipment
Contractors often provide important advice to their clients about purchase of new equipment. In the 2014 F-Gas Regulation there are 3 important new requirements that will change the advice that contractors give to their clients. These are:
NEW: HFC Bans
The 2014 Regulation includes a number of HFC bans as summarised in Table 1. Contractors should be aware that these bans “do not tell the full story”. You must make clients aware of the phase down and the service ban (see below) – these also have a significant influence on selecting new plant.
NEW: Impact of the Service Ban on purchase of new equipment
Purchasers of new commercial and industrial refrigeration equipment must be aware that a “Service Ban” will affect certain existing systems using HFCs with a GWP above 2,500 from 2020. The ban applies to systems containing more than 40 tonnes CO2 equivalent (10 kg for HFC 404A). To avoid future problems you should advise clients purchasing plants above this size threshold to select only refrigerants with a GWP below 2,500, with immediate effect. The service ban is discussed in more detail in Section 7, below.
NEW: Impact of the HFC Phase Down on the purchase of new equipment
When purchasing new RACHP equipment your clients should also consider the HFC phase down. This will reduce the quantity of HFCs that can be sold in the EU – by 2030 there will be an 80% cut in HFC supply. Equipment bought now will still be operating when deep cuts in HFC supply are in force. Irrespective of the bans described above, it makes sense to always purchase equipment using refrigerants with the lowest practical GWP to minimise the future impact of the phase down.
Table 1: Bans affecting RACHP Equipment
4 All start dates are January 1st of year specified
5 This ban includes both refrigerant and foam blowing agent
6 This ban includes both refrigerant and foam blowing agent
7 Exemption for equipment cooling products below -50oC
8 The primary circuit of cascade systems can use an HFC with a GWP up to 1,500
4. Contractor training and certification requirements
All refrigerant handling operations on RACHP equipment containing HFC refrigerants must be carried out by suitably trained technicians holding an F-Gas handling certificate and working for an F-Gas certificated company. This includes plant installation, leak testing, refrigerant recovery, maintenance and end-of-life decommissioning. The training and certification requirements are based on those already specified in the 2006 F-Gas Regulation.
Existing individual F Gas qualification certificates remain valid in accordance with the conditions under which they were originally issued. This means that those who hold certificates with an expiry date (CITB J11-J14) will need to be re-assessed and an updated assessment is now available.
NEW: The certification requirements have been extended to include technicians working on refrigerated trucks (>3.5 tonnes) and refrigerated trailers.
NEW: Qualified technicians must also be given “information on relevant technologies to replace or to reduce the use of fluorinated green house gases and their safe handling”. No further assessments are required, but all technicians should be aware of relevant information about the use of alternatives. It is expected that standard information will be prepared and then circulated via Certification Bodies.
Company Certification is required by all contractors carrying out installation and maintenance work. This applies to sole traders as well as limited companies. The process is unchanged from the 2006 Regulation. Defra has designated three bodies that can issue an RACHP Company Certificate: Refcom, Bureau Veritas and Quidos.
5. Contractor responsibilities to minimise refrigerant emissions
Under the 2006 F-Gas Regulation the legal responsibilities related to F-Gas emissions from RACHP equipment were held only by the plant operator (usually the owner).
NEW: In the 2014 Regulation there is an explicit legal requirement for contractors to share this responsibility. Article 3 of the Regulation states that “The intentional release of F-Gases into the atmosphere shall be prohibited where the release is not technically necessary for the intended use.”
The Regulation then states that contractors “carrying out the installation, servicing, maintenance, repair or decommissioning of RACHP equipment shall be certified and shall take precautionary measures to prevent leakage of F-Gases”.
This is an important new requirement about which contractors may need to inform a client, if they are being asked to do something that does not comply with the Regulation.
6. Contractor responsibilities during plant installation
All contractor staff carrying out installation work related to refrigerant handling must hold the appropriate F-Gas handling certificate and must make precautionary measures to prevent leakage. Engineers carrying out unrelated installation activities (e.g. electrical work) do not need a refrigerant handling qualification. However, anyone doing work that could affect the refrigerant circuit and give rise to possible leakage must be qualified – e.g. an engineer setting a high pressure cut-out device should be qualified – if this was set incorrectly it could give rise to a leak.
All RACHP products that contain F-Gases (including HFCs) shall not be placed on the market unless the F-Gases are identified with a label. The label shall indicate the following information:
For some pre-charged RACHP equipment the label will be provided by the equipment manufacturer. However, for all RACHP systems that are filled or topped up with refrigerant during installation, it is the responsibility of the installation contractor to ensure that a suitable label is attached, stating the total amount of refrigerant in the system.
7. Contractor responsibilities during maintenance activities
The 2014 F-Gas Regulation includes a number of requirements that affect the use and maintenance of existing industrial refrigeration equipment containing HFC refrigerants. The rules depend on the type and size of industrial refrigeration equipment being used. The regulations affecting existing equipment relate to (a) leak prevention, (b) record keeping and (c) the Service Ban. These requirements are described below.
Mandatory leak checks
Mandatory leak checks are required on all RACHP equipment above certain size thresholds.
Under the 2006 F-Gas Regulation, the thresholds were set in terms of the physical quantity of refrigerant in the system – those containing more than 3 kg required a regular leak check. NEW: Under the 2014 Regulation the requirements are similar, but the size thresholds are defined in terms of tonnes CO2 equivalent. These new CO2 equivalent (CO2 e) size thresholds mean that the kg threshold for each refrigerant is different. Refrigerants with a high GWP (e.g. HFC 404A) will have a lower size threshold than refrigerants with a lower GWP (e.g. HFC 134a). Table 2 shows leak testing requirements under both Regulations. Example thresholds are given for HFC 404A and HFC 134a.
The new CO2e thresholds will require some systems below the old 3 kg threshold to be regularly leak tested. As shown in Table 2, the size threshold for HFC 404A is only 1.3 kg. Contractors should check which of the systems they maintain are affected by the new CO2e size thresholds. Most of the leak checking rules apply from 1st January 2015, continuing the similar requirement in the 2006 Regulation. For systems with less than 3 kg, the 5 tonnes CO2e threshold only applies from 1st January 2017.
Table 2: Size Thresholds for Mandatory Leak Checks
* Leak check frequency is halved if automatic leak detection system is installed
** The threshold for annual leak checks of hermetically sealed equipment is 10 tonnes CO2e
If a leak is found during a mandatory leak check it must be repaired without undue delay and the leak test repeated within one month to ensure the repair was effective.
Mandatory automatic leak detection
For all RACHP systems containing over 500 tonnes CO2e there is a mandatory requirement for an automatic leak detection system to be fitted. An automatic leak detection system is defined as a “calibrated mechanical, electrical or electronic device for detecting leakage of F-Gases which, on detection, alerts the operator or a service company of any leakage”.
NEW: Mandatory automatic leak detection is a continuation of a similar requirement in the 2006 Regulation, although the size threshold is changed from 300 kg to 500 tonnes CO2e. This will have a significant impact on plants using high GWP refrigerants. For HFC 404A systems the new threshold for automatic leak detection systems is reduced from 300 kg to 127 kg.
This rule applies from 1st January 2015. The lower size threshold for HFC 404A will affect many large refrigeration systems as they often contain more than 127 kg. Table 3 shows the size threshold for automatic leak detection for a number of refrigerants used in RACHP systems. For most refrigerants, the new size threshold is lower than the 300 kg threshold in the 2006 Regulation.
Automatic leak detection systems must be tested every 12 months to ensure their proper functioning.
Table 3: Size Thresholds for Automatic Leak detection and the Service Ban
* Note: the service ban only applies to refrigerants with a GWP above 2 500
Operators must ensure records are kept for each piece of equipment that is subject to a mandatory leak check (i.e. above the 5 tonnes CO2e threshold). The records are similar to those required under the 2006 Regulation:
NEW: Records must be kept by the plant operator for at least 5 years. Where a contractor prepares records for the operator, the records should also be kept by the contractor for at least 5 years. The records shall be made available on request to the UK Government’s competent authority (i.e. the Environment Agency) or to the Commission.
NEW: Service Ban
An important new feature of the 2014 F-Gas Regulation is the Service Ban:
In the refrigeration sector this will mostly affect systems that use HFC 404A. The size threshold of 40 tonnes CO2e is equivalent to 10 kg of HFC 404A. The size thresholds for various other refrigerants are given in Table 3.
It is important to note that several refrigerants used as “drop-in” replacements for R22 have a GWP above 2,500 and are affected by the Service Ban. Some of these are listed in Table 3 (e.g. HFC 434A, HFC 422D).
It will be legal to continue operating systems affected by the Service Ban, but you will not be allowed to top up any leaks with virgin refrigerant. Contractors should advise operators of equipment affected by the Service Ban that they have 3 main options:
8. Purchase of bulk refrigerant and pre-charged systems
NEW: HFC refrigerants shall only be sold to and purchased by certified undertakings or undertakings that employ certificated personnel. This means that refrigerant suppliers will require evidence that contractors are certified or qualified to make the purchase. You should contact your refrigerant suppliers to confirm what new requirements they plan to introduce – it is likely to be evidence based on your Company F-Gas Certificate.
NEW: Non-hermetically sealed equipment pre-charged with HFCs (e.g. split system air-conditioning units) can only be sold to end-users where evidence is provided that the installation will be properly carried out by a suitably qualified contractor.
9. Contractor responsibilities for plants at end-of-life
Any RACHP equipment containing HFCs in either the refrigeration circuit or the insulation foam that is being disposed of at end-of-life must undergo an HFC recovery process.
All refrigerant must be recovered by a certificated technician before the plant is dismantled. Modern refrigerant recovery machines should be able to remove well over 95% of the refrigerant in an old system. Any insulating foam associated with these refrigeration systems (e.g. PU foam used for pipe / vessel insulation or in cold store panels) should be sent to a specialist recovery facility, where the foam can be crushed and the HFCs recovered.
All recovered F-Gases can either be:
Given the HFC supply shortage that will be created by the phase down process, it is worth trying to send the old refrigerant for reclamation as it may have a good residual value. If the old refrigerant is too contaminated it cannot be reclaimed and must be sent for destruction. It is important not to mix different gases in the same recovery cylinder – as this would render them unsuitable for reclamation.
Reclaimed refrigerant may be used in any refrigeration equipment, by any qualified person. Recycled refrigerant must always be used with care as it may be contaminated or of unknown composition. The use of recycled refrigerant with a GWP above 2,500 is restricted to either (a) the organisation owning the plant from which the gas was recovered or (b) the organisation that carried out the recovery.
This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs
This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.
To find out more about Gluckman Consulting visit www.gluckmanconsulting.com
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