Meeting the regulations

Whatever your current level of awareness of the new EC Regulation on F-Gases may be, the fact is that it applies to almost any building with an air conditioning system that utilises refrigerant and coolants to reduce the interior temperature, especially common in larger workplaces and offices.

Mike Bird, Managing Director of breathegroup and its air conditioning division, breathe air, outlines the main points that may affect your business and premises.     The main objective of the new Regulation (Regulation [EC] No. 842/2006 of the European Parliament and of the Council) is to address the levels of emissions caused by the use of so called F-Gases in HVAC systems, via containment and prevention of such releases. As raised by the Kyoto Protocol, the regulation aims to introduce responsible handling of such gases during use, recycling and end-of-life recovery, as well restricting and even punishing unnecessary use in certain situations.
F-Gases refers to any types of fluorinated gas which is used as a coolant in modern systems, the most common option following the phasing out of CFCs and HCFCs, HFCs. Although they are favoured for their stability, non-flammability and energy efficiency, especially in relation to ammonia and hydrocarbons, they still have high global warming potential (GWP). In order to keep this to an absolute minimum, the new regulations aim to restrict the amount of refrigerant released into the atmosphere.
Restrictions on usage

The tracking of the amounts of refrigerant released is covered in several key sections of the legislation. The first section was introduced following a meeting by the EC Environment Council in October 2004. It endorses tighter restrictions on F-Gas usage, to include the introduction of regular system inspections and an emphasis on end-user duty of care to closely monitor all equipment that uses more than 3kg of refrigerant charge, i.e. most companies that occupy large premises with sizeable HVAC systems.
Heightened responsibility will be placed on these end users to monitor their own systems, plus culpability for any infringements. Already in place since 4 July 2007 are ‘standard leakage checking requirements’ (Art. 3.7), which are the required basis for operators to use: “All measures which are technically feasible and do not entail disproportionate cost” to prevent leakage and repair any detected leakage.
This means that checks must be carried out by certified personnel, with the following frequency, dependent on the quantity of F-Gases used in the particular system:

  • 3kg or more: at least once every 12 months – except for hermetically sealed systems containing less than 6 kg.
  • 30kg or more: at least once every 6 months (or 12 months with an appropriate leakage detection system).
  • 300kg or more: at least once every 3 months (or 6 months with an appropriate leakage detection system – which is anyway mandatory). Additionally, for 300kg or more units, leakage detection systems must be checked at least once every 12 months.

Additionally, for all units containing more than 3kg, a log book must be kept, indicating the quantity and type of product, quantities added when necessary, and the quantity recovered during servicing, maintenance and final disposal. Other relevant information is also required, like the identification of the servicing company or technician, plus dates and results of the subsequent checks.
Recovery and disposal

Where applicable, the responsibility for the recovery of F-Gas after use, either for recycling or disposal purposes is also the responsibility of the end user, to an extent that it is technically feasible and does not entail disproportionate cost. Subsequent to these requirements, EU Member States are required, by 4 July 2008, to establish or adapt their own training and certification requirements, and give recognition to the certificates issued in another Member State. By 4 July 2009, these states must also ensure that the relevant companies can only take new deliveries of F-Gases if their relevant personnel are so certified. These certified personnel will be required to fulfil a number of requirements, including:

  • Reporting – to be carried out on an annual basis, and is applicable to producers, importers and exporters.
  • Labelling – including refrigeration, air conditioning, and all other F-Gas containers must be clearly and appropriately labelled.

Responsibility

The regulations also place stringent guidelines on the installation of systems in new buildings and replacement systems in existing buildings, requiring building contractors to provide detailed proof that refrigerants are being handled responsibly as a prior condition of their appointment to a contract.
Although once construction and installation is completed, responsibility will lie with the occupant (end-user); contractors will have to make sure that all requirements are completely fulfilled, not least to avoid missing out on securing new contract wins. Although no concrete date has been specified when the exact standards will become mandatory, any installers adhering to them in advance are certain to gain an edge.
Current legislation

Much of the new legislation on refrigerant gases refers to systems and substances that have been in use for several years, particularly HCFCs and other alternatives to F-Gas. This includes:

  • The banning of the use of HCFCs in all new refrigeration or air conditioning equipment produced after 1 January 2001.
  • The use of virgin HCFCs will be banned in the maintenance of existing refrigeration systems from 1 January 2010.
  • The use of all HCFCs, including recycled materials, will be banned from 2015.


Of course this phasing out of alternative substances means that F-Gas control will become increasingly important for EU member states and the businesses that occupy offices with coolant systems, particularly with such a heavy emphasis on self regulation and internal responsibility.
 
It is unlikely that regulation will remain at the current levels either, with an expected rise in requirements to build in sustainable alternatives to HVAC system usage, such as the incorporation of natural ventilation and use of heat cells or external photovoltaic materials for heating purposes.

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