22 Legislation
Important measures designed to improve professionalism in the air conditioning and refrigeration sector are likely to be removed from the revised F-Gas Regulation, reports Graeme Fox
Europe braced for F-Gas compromise
A PROPOSAL to ban the current practice of pre- charging split air conditioning systems with refrigerant gas could be dropped from the final version of the reviewed F-Gas Regulation due to be enacted early next year. It is still possible that the European Parliament could dig in its heels, but manufacturers have been lobbying ferociously against the ban during the review of the Regulation because they say it interferes with their manufacturing process.
Other industry bodies are still trying to get a clause into the legislation that protects the principle of improving professional installation because the use of pre- charged units encourages DIY installation and so increases the danger of gas leakage. DEFRA has agreed to support a compromise motion from contractors’ bodies, including the Building & Engineering Services Association (B&ES), to restrict the supply of pre- charged systems to only those individuals able to demonstrate proof of professional qualifications.
Disappears
Currently manufacturers sell to wholesalers and at that point the unit, with its refrigerant gas charge, disappears into the supply chain. This makes it very hard to monitor what is happening to thousands of tonnes of F-Gas refrigerant. E-bay is also becoming a big problem. All manner of people are selling air conditioning through the auction website and many mislead buyers over their legal responsibility. There have been numerous examples of people buying air conditioning on e-bay; trying to install the units themselves and damaging the pipes so the whole charge is lost to
ACR News November 2013 atmosphere.
If the pre-charge ban is dropped, the European Commission will have to find another way of controlling the amount of gas in the market. The most obvious compromise would be to tighten up the supply chain and ensure unqualified people cannot get their hands on equipment containing environmentally harmful gases in the first place. Pre-charged splits are regularly sold to non- registered individuals and companies increasing the risk of refrigerant being lost. With a further possible amendment to the F-Gas Regulation being the imposition of a quota system, there has to be some way of keeping track of the gas circulating in the marketplace. The Air Conditioning and Refrigeration European Association (AREA), which represents contractor bodies throughout Europe, has suggested a change of wording in one key clause to try and address the issue of non- professional installations if the ban on pre-charging is dropped.
The proposed change applies to Article 9.3 of the Regulation with the additional paragraph: ‘3b. Non-hermetically sealed equipment charged with hydrofluorocarbons placed on the market shall only be sold to the end user where evidence is provided that the installation shall be carried out by an undertaking certified in accordance with Article 8.’ This amendment would also have no bearing on the manufacturing difficulties experienced by one or two manufacturers as it does not put any restriction on them placing pre-charged units on the market.
To be honest, it is not difficult for manufacturers to produce equipment without
refrigerant charge – many already do it on a number of product ranges anyway. By the same token, they could have voluntarily opted to refuse to supply unregistered suppliers and installers. There would be no reason to ban pre-charging if the supply chain was properly controlled.
Distributors in the UK were close to signing a voluntary agreement to only sell to F-Gas registered installers a couple of years ago, but this was dropped at the last minute over a spurious ‘restriction of trade’ challenge. The industry has tried to have condensing units reclassified as ‘containers’ to show that they contain F-Gas, but the legal department at the Commission put an end to that idea too.
Robust
Whoever buys this type of equipment has the legal responsibility to make sure whoever installs it is F-Gas registered. That has always been the case, but is very hard to implement without some control on the supply. Condensers are really not suitable for transporting gas – they are not robust enough and many arrive on site without their gas because it has leaked en route.
Although many people will be disappointed by the need to compromise, we should not be discouraged because we have made progress in a number of areas. Not least is the fact that environmental pressure groups are far more conciliatory these days. They now accept the need for practical measures to limit gas emissions rather than early blanket bans that would cause huge disruption to hospitals, food suppliers and other vital sectors. Another positive is the decision to raise the HFC restriction ceiling to 40 tonnes
CO2 equivalent. This is much more sensible than the original
stipulation as it means that small users will not be subject to the HFC ban.
Every engineer will also have to provide proof of qualifications, which means that only a certified technician/operative will be competent to charge a system that is ‘designed to contain F-Gas’. That operative will have to have formal qualifications in any refrigerant, and not just F-gas under the terms of the revised Regulation.
Mandatory certification will be put in place so refrigerant handlers will need to be re- tested every five years. ‘Top up’ training is the approach favoured by the European Commission to demonstrate competence across all the
refrigerants including CO2, ammonia, and hydrocarbons. It will be possible to reach the standard through e-learning and only a test failure will require the installer to take further training.
The Commission likes this approach because it is low cost, accessible and practical – so there is a good chance contractors will actually do it assuming member states allow the right level of flexibility in their certification systems. Our efforts to up our game means we can now negotiate sensibly with regulators in Brussels and ensure the voice of the installer is heard and recognised.
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