EU F-Gas Regulation Guidance Information Sheet 15: Fire Protection System Contractors
This information sheet is aimed at contractors that carry out installation, maintenance and decommissioning work on fire protection systems using HFCs. It is also useful for operators of fire protection systems that use 3rd party contractors to maintain their system.
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.
Fire protection system (FPS) contractors play a major role supporting operators of FPS 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 FPS contractors. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms.
2. Sector description
The fire protection industry make use of HFC fire extinguishing products in certain specialised building applications, where building contents have a high value and other fire protection systems (e.g. water based) could cause too much damage. In the UK most systems of this type use HFC 227ea (also referred to by trade names such as FM 200).
Detailed guidance on the impact of the 2014 F-Gas Regulation for end users in the FPS sector is available in Information Sheet 10.
Most operators of FPS make use of specialist contractors for installation and maintenance work. The skill and expertise of the FPS contracting industry is crucial, providing operators with various services through the life cycle of FPS 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 HFCs. 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 2 important new requirements that will change the advice that contractors give to their clients. These are:
NEW: HFC Bans
The 2014 Regulation adds a ban on HFC 23 from 1st January 2016 to an exisiting ban on PFCs. See Table 1 for details.
Table 1: Bans affecting FPS Equipment
NEW: Impact of the HFC Phase Down on the purchase of new equipment
When purchasing new FPS 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 virgin HFC supply. Equipment bought now may still be use when these cuts in virgin supply take effect. Irrespective of the bans described above, it makes sense to always purchase equipment using fluids with the lowest practical GWP to minimise the future impact of the phase down.
The fire protection industry is committed to the responsible use of HFCs in fire protection and always recommends minimising the impact on the environment by recycling material at end-of-life. There is a significant bank of HFCs in installed systems. As these systems reach the end of their natural life the fire extinguishant may be available for recycling
4. Contractor training and certification requirements
All HFC handling operations on FPS equipment containing HFCs must be carried out by suitably trained technicians holding an F-Gas ‘Competency’ certificate and working for an F-Gas Certificated company. This includes system installation, leak testing, HFC 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.
NEW: Qualified technicians must also be given “information on relevant technologies to replace or to reduce the use of fluorinated greenhouse 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 the Fire Industry Association (FIA) as the industry certification body who can issue a Company Certificate for FPS:
5. Contractor responsibilities to minimise HFC emissions
Under the 2006 F-Gas Regulation the legal responsibilities related to F-Gas emissions from FPS equipment were held only by the system operator.
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 FPS 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 system installation
All contractor staff carrying out installation work related to HFC handling must hold the appropriate F-Gas competence certificate and must take precautionary measures to prevent leakage. Technicians carrying out unrelated installation activities, e.g. electrical work, do not need a competence qualification. However, anyone doing work that could affect the activation of the FPS and give rise to possible leakage must be qualified.
All FPS 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 most FPS equipment the label will be provided by the equipment manufacturer that fills the cylinders of fire extinguishing fluid – however, the contractor should always check that the system is properly labelled.
7. Contractor responsibilities during maintenance activities
The 2014 F-Gas Regulation includes a number of requirements that affect the use and maintenance of existing FPS containing HFCs. The rules depend on the size of FPS being used. The regulations affecting existing equipment relate to (a) leak prevention and (b) record keeping. These requirements are described below.
Mandatory leak checks
Mandatory leak checks are required on all FPS 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 HFC is different. HFCs with a high GWP (e.g. HFC 23) will have a lower size threshold than HFCs with a lower GWP (e.g. HFC 227ea). Table 2 shows leak testing requirements under both Regulations. Example thresholds are given for HFC 23 and HFC 227ea.
Table 2: Size Thresholds for Mandatory Leak Checks
* Leak check frequency is halved if automatic leak detection system is installed
All stationary fire protection systems using HFCs contain considerably more than the lower threshold shown in Table 2, so they will all require a mandatory leak test regime. This is unlikely to impact the fire protection industry as there is already a strict 6 monthly maintenance regime for most systems. The Regulation recognises that most fire protection systems have regular maintenance and leak checks. The leak checking obligations shall be considered to be fulfilled provided the following two conditions are met:
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
NEW: For all fire protection systems containing 500 tonnes CO2e or more there is a mandatory requirement for an automatic leak detection system to be fitted. This 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 an impact on systems using high GWP fire extinguishing fluids. As shown in Table 2, for HFC 227ea systems the new threshold for automatic leak detection systems is reduced from 300 kg to 155 kg. For HFC 23 systems the threshold for automatic leak detection is even lower – at just 34 kg. This rule applies from 1st January 2015. Most systems are provided with an automatic leak detection facility as standard.
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”.
Automatic leak detection systems must be tested at least once every 12 months to ensure their proper functioning.
Operators of fire protection systems must keep records for each piece of equipment that is subject to a mandatory leak check (i.e. above the 5 tonnes CO2e threshold). The records that must be kept are similar to those required under the 2006 Regulation:
NEW: Records must be kept by the “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.
8. Purchase of bulk HFCs
HFCs shall only be sold to and purchased by certified undertakings. This means that HFC suppliers will require evidence that contractors are certified or qualified to make the purchase. You should contact your suppliers to confirm what new requirements they plan to introduce – it is likely to be evidence based on your Company F-Gas Certificate.
9. Contractor responsibilities for systems at end-of-life
Any fire protection systems containing HFCs that is being disposed of at end-of-life must undergo an HFC recovery process. Recovery must be carried out by a certificated technician.
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 HFC for reclamation as it may have a good residual value. If the old HFC 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.
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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