by Ray Gluckman
18 December 2008
Those using refrigeration and air-conditioning are the biggest users of F gases, a meeting of the F-gas Support team heard. The team was gathered to discuss plans to help companies across Great Britain comply with two European Commission Regulations - the F-gas Regulation 842/2006, which has applied since July 2007, and the Ozone Regulation 2037/2000 which has applied since 2000.
Defra established F-gas Support to help operators to understand their obligations and to help regulators to ensure compliance.
The EC F-gas Regulation concerns the use of certain fluorinated gases (F gases), which are powerful greenhouse gases. The F-gas family includes hydrofluorocarbons (HFCs) - typically used as refrigerants. Some examples of HFC refrigerants in common use and covered by the EC F-gas Regulation are R134a, R404A and R410A. Many users of air-conditioning will be affected by the regulation, as it covers much equipment currently in use.
The aim of this European regulation is to cut emissions of F gases by getting operators to take better control over their use and, in particular, to reduce rates of refrigerant leakage.
Today, F gases have many diverse applications across most sectors of the UK economy. It is even used as a propellant in medical inhalers for asthma sufferers. Research undertaken on behalf of Defra in 2007, found that stationary refrigeration and air-conditioning systems are responsible for more than 25 per cent of the UK emissions of
F gases, making them the largest single emitter of these gases.
The key obligations for the operator of affected refrigeration and air-conditioning systems are:
- Leak checks: regular checks for leakage - use of automatic detection on large systems
- Recovery: refrigerant recovery during plant servicing and maintenance and at end of life
- Records: good records kept for equipment containing 3kg or more of F gases
- Certification: companies employing personnel to work on F gas containing equipment need to be certified
- Training: use personnel with appropriate qualifications
- Other: certain other actions including labelling of new equipment and banning the use of non-refillable containers
Who is the operator?
According to EU guidance, the operator of F-gas containing equipment has:
- Free access to the system
- The control over the day-to-day running
- The powers to decide on technical modifications and checks or repairs
The greatest area of potential complication is in landlord-tenant relationships, eg in a leased air-conditioned office building. For individual areas or floors within the building, the responsibility for switching the air-conditioning on and off may reside with the tenant. However, the tenant may not also be responsible for the unit maintenance. In these circumstances you may need to refer to the responsibilities set down in the lease - this should normally specify which party is responsible for the operation and upkeep of any air-conditioning system and hence is legally the operator.
Older refrigeration and air-conditioning equipment often uses R22, a hydrochlorofluorocarbon (HCFC), which is an ozone-depleting substance (ODS). This is due to be phased out under the EC Ozone Regulation. Dates to note are:
- End of 2009 when virgin HCFCs can no longer be used for plant servicing and maintenance
- End of 2014. From this date, recycled HCFCs can no longer be used for plant servicing and maintenance
Both these bans apply to "use" for plant maintenance - so you cannot purchase material before the ban and stockpile it.
The obligations in the EC Ozone Regulation for HCFC use in equipment are similar (but simpler) to those for the EC F-gas Regulation.
Refrigerant leakage causes harm to the environment and to the owners' bottom-line profit. When an HFC refrigerant leaks, this contributes directly to global warming. The leak also leads to a reduction in efficiency - meaning more CO2 emissions from the extra electricity. The owner has to pay to replace the refrigerant, for the electricity, for the leak repair and, then may have to deal with unhappy occupiers. It is clear that a leak-tight system is preferable.
The penalties for failure to comply are set out in the GB Fluorinated Greenhouse Gases Regulations 2008 (Statutory Instrument No 41) which came into force on 15 February 2008. (This regulation will be revised in February 2009 to include the outcome of the recent consultation on training and certification.) Local authorities will normally be the regulators at non-industrial sites and they have full powers to demand to see evidence that the operator has been fulfilling their obligations.
Ray Gluckman is project director of F-gas Support at environmental consultancy Enviros
Overview of key obligations
Users of refrigeration and air-conditioning systems with HFC refrigerants which are F gases must meet EC Regulation 842/2006 and the GB Fluorinated Greenhouse Gases Regulations 2008 (Statutory Instrument No 41). The regulations require:
More information is available from F-gas Support. Visit www.defra.gov.uk/fgas