m&e sustainability

With the F-Gas and ozone depletion regulations now in force, the industry has to raise its game, says Graeme Fox* of the Heating and Ventilating Contractors’ Association (HVCA).

Regulation has arrived with a vengeance for the refrigeration and air conditioning industry, and we are now dealing with a series of tough legislative deadlines.

The first big date was April 9, 2007 when it became illegal to handle refrigerant gases – including the still widely used R22 – unless you held a recognised safety qualification. This is when the Ozone Depleting Substances (ODS) regulations came into force.

A large proportion of the full time RAC engineering profession – around 28,000 people – now hold either a C&G 2078 or its CITB equivalent: the Safe Handling of Refrigerants Certificate, but there are possibly as many as 30,000 general service and maintenance engineers who do not and a large proportion are probably unaware that they are breaking the law.

The next big date was July 4, when the F-Gas Regulation came into effect in the UK. It had already been applied across several other EU member states since the previous summer, but now it was our turn.

F-Gas enforces a ban on disposable refrigerant cylinders; calls for the labelling of all HFC refrigerant gas cylinders and applies strict rules for the containment and monitoring of all equipment with the potential to leak global warming gases into the atmosphere.

Leakage checking
Refrigeration and air conditioning equipment containing 3kg and above of refrigerant gas must be checked for leaks every 12 months, although hermetically sealed systems are exempt. For systems containing 30kg, checks must be carried out every six months or 12 months where an automatic leak detection system is in place.  And where the charge is 300kg and above, leak detection systems will be mandatory and must be checked and reported on every six months.

The servicing technician will have to be identified in the records of the building operator and the quantity and type of refrigerant involved must be logged. All servicing personnel will have to be fully trained to carry out this work to a level of competence that is far in excess of the basic safe handling requirements of the ODS Regulation. A good foundation in the theoretical knowledge of refrigeration systems and components will need to be tested and certified before an engineer will be deemed competent.
 
The service company also needs to be checked and registered as competent on a scheme such as REFCOM. Discussions are taking place with Government to determine exactly what level of registration will be agreed and a Government commissioned impact assessment is taking place with the cooperation of the relevant stakeholders.

For new systems with a total refrigerant charge of 3 kg or more, the contractor will be expected to provide a logbook that is easily accessed and regularly updated. Existing systems must have a logbook issued at the first performance test after the Regulation comes into force.

Refrigerant leaks will have to be identified and repaired as soon as practicable by a competent person and the system would only be put into service again following another check.

Waste disposal
Used refrigerant, which is not intended for re-use, should be dealt with as waste for safe disposal and only a person deemed as competent under the terms of the regulation will be able to take apart or rebuild any system.

From July 2008, detailed service records will have to be kept and from the middle of 2009, when the F-Gas Regulation is in full force, only companies with certified personnel will be allowed to buy HFCs. This has the potential to be the most significant change of all and we are waiting to see how serious the Government is about enforcing this.
 
At the moment, there are no restrictions on wholesalers who are able to sell refrigerant gas to anyone. This is a clear weak link in the system, which will hopefully be strengthened in 2009. If we are able to keep global warming refrigerants out of the wrong hands then we have a fighting chance of ensuring the new regulations do make a significant difference to climate changing emissions.

At the same time, we must ensure that only properly qualified contractors are working on air conditioning systems to tackle and avoid refrigerant leaks as well as delivering the most effective and energy efficient systems.

From January 2010 there will also be a ban on all “virgin” HCFCs meaning only recycled gases will be usable for service, maintenance and topping up systems and by 2015 even they will have been banned.

A heavy burden
All of these legislative changes might seem like a heavy burden for our sector – and they are – but they are also long overdue. The RAC industry has suffered from fairly lax regulation over the years, which has allowed too many unregistered and untrained firms to operate.

These new laws give us a chance to promote companies with high professional standards as well as doing our bit to tackle environmental damage caused by poorly engineered systems. A mandatory refrigerant handling scheme under the F-Gas Regulation will be an important step towards eradicating the 'rogue trader' from the industry once and for all, but it will also put pressure on the industry to bring its skills up to the mark.

We must demonstrate progress on reducing refrigerant leakage rates very quickly as we are confronted by a tight deadline. The European Commission is already preparing to review F-Gas and will publish a new version in 2011. This is tough. The Review will have to be based on leakage figures gathered in 2009 to give officials time to consider the measures in 2010 ahead of publication the following year.
That makes this year (2008) absolutely critical. 

We will have to get used to using less HFC, such as R407C and R410A, but they must remain an important part of the mix as they are the most energy efficient solution for many air conditioning applications – particularly split systems. They are clearly under threat and could be banned outright by the revised regulation if we can’t demonstrate improvements in our leakage rates.

This would be a tragedy as the Total Equivalent Warming Impact (TEWI) of HFCs should ensure their long-term use and it is simplistic and wrong-headed to judge them purely on global warming potential. HFC equipment tends to be less leaky in any case as it is relatively new.

The Law
The final responsibility for staying within the law lies with the end user, who must ensure that only qualified people work on their equipment. The Government is considering imposing £5,000 fines for any breach of the regulations, but you can be sure clients will be looking to pass on liability to contractors via new service agreements. Failing that, they are not going to be best pleased with any supplier who fails to protect them from penalties under the new laws.

In any case, working to higher agreed standards is better for everyone. Using properly trained personnel improves profitability for the contractor, as there are fewer system breakdowns, fewer callouts for unscheduled repairs, fewer warranty claims and reduced time is needed on-site for planned maintenance programmes.

There is an obvious crossover between the F-Gas Regulation and the EU’s Energy Performance of Buildings Directive (EPBD) as the necessity to meet tougher new energy efficiency targets under the latter means the industry must tackle refrigerant leakage under the former.

This should lead to an increased revenue stream for those rac engineers capable of doing this work. The Directive is also good news for firms that have suffered in the past from seasonal downturns in workload. The requirement for air conditioning inspections, also in force from next year, is an opportunity for the skilled people in our sector. The ideal time to do that work would be in the winter when things are traditionally quieter.

As a result of these changes there is a growing need for more expert guidance and many engineers are turning to the HVCA’s design ‘bible’ RAC80 – Design Specification for DX Packaged Air Conditioning Equipment in Buildings.

The updated version, launched in 2005, includes chapters on energy efficiency and indoor air quality and is proving invaluable to designers as they struggle to comply with the growing amount of regulation.

Ultimately, the legislation will become a fact of our everyday life, but if it is properly enforced and standards of professionalism are improved across the sector end users will have better and more robust solutions, which can only be good for everyone.

*Graeme Fox is the HVCA’s Refrigeration and Air Conditioning group representative on M&E Sustainability.