Air Conditioning World
As the nights draw in so does the ban on R22
Nearly 20 years since global concerns about ozone depletion led to the first controls of HCFCs, we are now just a few months away from the total ban on the use and storage of R22 gases. EC Ozone Regulation (No. 1005/2009) comes into effect on 1st January 2015, and companies breaching the R22 regulations could face big fines, the shut down of their site, or both.
various implications of the ban. The panel comprised Martin Fahey of Mitsubishi Electric; Saleem Fazal of international law firm Taylor Wessing; Trevor Lake of chartered accountants and tax advisers LB Group; Graham Wright of Daikin UK and Kevin Groves of Ergro. Together they discussed the technical, logistical, financial and legal ramifications for businesses once the final deadline arrives.
been a lengthy countdown to this final date, with warnings and updates coming from public and private platforms alike to try to reach every corner of the industries affected by the deadline. It’s been a progressive deadline, but from January 1, it will actually be illegal to use any HCFCs to service refrigeration or air conditioning (RAC) equipment – so recycled or reclaimed HCFC may no longer be used.
There have been several “phase out” dates to work towards this total ban. Government advice along the way included DEFRA’s Guidance for Stationary Refrigeration & Air-Conditioning, which stated: “Given that most RAC systems leak to a certain degree, in practical terms this implies that any equipment that is of strategic importance to a busi- ness should not be using HCFCs by 2015 so all current users of HCFC systems must develop a plan to manage their operations without HCFCs. Doing nothing is not a sustainable option. Given the serious implications and
It’s folly to think waiting until equipment breaks down before replacing R22 is the answer
potential costs, businesses should follow a strategic approach.” For the past four years, firms have only been allowed to use recycled or reclaimed HCFCs to service and maintain RAC sys- tems – stockpiled virgin HCFCs have had to be returned to fluid suppliers for appropriate disposal. One year ago, leading HVAC company Ergro sponsored an R22 summit at the Royal Society of Medicine. The panel of experts there took an invited audience of building managers, consultants, architects and business leaders through the ins and outs of the
32 | September 2014 | ACW supplement to HVR
It’s initiatives like this that have gone a long way towards preparing a large majority of those affected, but it remains to be seen if there will still be pockets of ignorance where companies or – worse – their clients are left floundering. After December 31, 2014, any breakdown in the refrigeration circuit of systems currently using R22 will no longer be serviceable. This will mean that as soon as a unit breaks down the building that houses it will cease to be opera- tional – this will pose a huge risk to reputation and business continuity. There is now only a few months, a handful of weeks, to make necessary upgrades – and as the ban date approaches the demand on those companies with the expertise to make those upgrades is soaring.
Kevin Groves said: “It’s folly to think that waiting until equipment breaks down before replacing R22 is the answer. Although the down- time is kept to a minimum, the dis- ruption to business and staff working in hot conditions is far from ideal. We recommend assess- ing the likelihood of a breakdown by having equipment inspected before the ban, then putting in place a plan of action to bring it up to date if needed.” Well organised and informed companies have been working towards this date for years, know- ing that no new R22 plant has been made since 2003. They’ve been able to take full advantage of the energy savings and reduced CO2 emissions afforded by the upgrades they’ve made already,
and are well placed to exploit the benefits of the latest innovations available.
“Manufactures such as Daikin have developed products that make it easy to benefit from high- er efficiency lower CO2 emissions by allowing splits systems through to complex VRV projects to reuse the pipe work already installed on site. This not only reduces installa- tion time and cost but also leads to greater resource efficiency thus reducing waste. In some cases fur- ther benefits can be gained by keeping the original indoor units as well,” said Graham Wright. It’s not just company owners in the industry who need to be aware. Every year sees new land- lords and new tenants coming in to buildings that use RAC equip- ment, and it’s vital that everyone from the end user up is aware of the regulations, the reasons for them and the results of non-com- pliance. New plant needs plan- ning, not just in terms of internal practicalities but also the effects the work will have on neighbours, particularly in urban environments. It’s feasible that a landlord who has bought a relatively small prop- erty in the last six months might be unaware of the R22 require- ment, in among all the other more obvious aspects of ownership to which he or she has to attend. But for the remaining compa- nies who’ve not yet made a move towards the necessary work because they feel that they can’t afford it, there is hope, and it’s very much a case of finding out about what’s available. There is, for example, tax deduction of up to 100 per cent for managing system changes in line with the legislation, and capital allowance can also reduce the burden. Remember – it’s not just busi- nesses in the RAC industry that are affected by this imminent legisla- tion, it’s every business, every building, that houses some form of refrigeration or air conditioning equipment. It needs to be tended to now.
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