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Legal
The F-Gas plan
You may not realise that the equipment you deal with contains
an F-Gas. If it does, you may need to take action or start
devising a replacement plan, writes Hywel Davies
D
o you use, maintain, install or manufacture maintenance contract, responsibility stays with the
equipment that contains an F-Gas, or do you owner if they have day-to-day control of the system.
have clients who do? Anyone with stationary The greatest area of complication is in multi-tenanted
refrigeration, air conditioning or heat pump air-conditioned buildings, where it is important to
equipment containing gases such as R404A and refer to the lease – which may specify which party is
R408A is affected by the F-Gas Regulation and needs responsible for the operation
to have a plan for complying. Perhaps your clients and upkeep of the system.
could use your help to prepare for it? Therefore, such operators have
Operators have
F-Gases are a family of gases similar to hydrocarbons, a legal duty to have the equipment
with fluorine replacing some hydrogen atoms. They checked regularly for leaks, by a legal duty
were developed over many years because they have qualified people. Companies
to have the equipment
excellent refrigerant properties. What wasn’t realised employing personnel who handle
until much later is that these hydrofluorocarbons refrigerant must ensure that they checked regularly for leaks,
(HFCs) are powerful greenhouse gases (GHGs) have appropriate qualifications.
by qualified
that contribute to global warming if released into The UK environment department
atmosphere. And some are ozone-depleting substances (Defra) has designated Refcom people
(ODPs) too. the mandatory certification body
Since the Montreal Protocol of 1987, manufacture, required by the UK Fluorinated
use and handling of ODPs, including CFCs, HCFCs Greenhouse Gases Regulations.
as well as HFCs, all widely used in refrigeration, air The frequency of F-gas inspection depends on the
CFC
conditioning and heat pumps, have been increasingly amount of refrigerant in the system. Systems with
Chlorofluorocarbons.
Historically used in
stringently controlled. The EU Ozone Regulation 3kg to 30kg require annual inspection (the minimum
refrigeration, foam blowing
of 2000 set a timescale for the phase-out of CFCs size rises to 6kg for hermetically sealed systems.
and aerosols. Now completely
and HCFCs. And the 2006 EU F-Gas Regulation Systems with 31kg to 300kg (sealed or otherwise) banned under the EU Ozone
introduced strict inspection rules for operators of such need six-monthly checks, and systems over 300 kg
Regulation (2037/2000).
equipment containing more than 3kg of HFC. need quarterly checks, although fitting an approved
HCFC
This regulation defines the operator as “the natural or automatic leak detection system halves this. Any air Hydrochlorofluorocarbon.
legal person exercising actual power over the technical conditioning system over 12kW effective rated output
Similar uses to CFCs.
functioning of the equipment and systems…”. This also requires regular inspection by an accredited
Already phased out in many
applications under Ozone
includes: inspector under Part 4 of the Energy Performance
Regulation, totally banned in
• Free access to the system to supervise its components of Buildings (EPB) regulations. Under the EPB
EU by 2015.
and their function; regulations, systems must be inspected every five years
HFC
• Control over day-to-day operation , eg, ability to switch (in some cases in Scotland every three years).
Hydrofluorocarbon An F-Gas,
it on or off; and The F-Gas and Ozone regulations limit the availability
with similar uses to CFCs
• Power (including financial) to decide on technical of replacement supplies of some refrigerants, so that and HCFCs. Regulated by EU
modifications (eg, replacement of a component, recycled refrigerant, if available, may be the only option
F-Gas Regulation (842/2006).
installation of leak detectors) and to have checks or – and only for a limited period. It may be prudent to
For details of the REFCOM
repairs carried out. begin to plan for the replacement of older systems. scheme go to www.refcom.
If all these powers are contractually devolved to Operators need to have a plan for the management and
org.uk/contact_refcom.html
a third party, then authority and responsibility will replacement of these assets over the coming years. l
For details of air conditioning
inspectors go to www.
also be deemed as transferred. If the powers are
cibsecertification.co.uk/
only partially transferred, responsibility stays with
Hywel Davies is technical director of CIBSE
technical@cibse.com
ccw/consultants/
the original operator. Even with a comprehensive airconditioninginspectors
22 CIBSE Journal May 2009 www.cibsejournal.com
CIBSEmay09 pp22 legal.indd 22 4/30/09 5:41:46 PM
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