Preparing for the F-Gas Regulation — Graham Hendra.
The weight of legislation being thrown at air-conditioning is growing. Graham Hendra
explains what it all means and who is affected.The building services industry faces a whole raft of issues. They include an increasing shortage of skilled engineers, energy conservation and, of course, the impending F-Gas Regulation. There is an inordinate amount of new legislation facing the whole of the UK air-conditioning industry. It is not simple, and it has technical, legal and financial implications we all need to be aware of. The impending F-Gas Regulation has been inspired by the need to maximise our efficiencies and our environmental concerns in utilising air-conditioning systems and will have a big impact on designers, contractors and system owners. Any failure to comply could face draconian penalties. Legislation
The advent of the F-Gas regulation has been around in the Press for the last couple of years, accompanied by some scary headlines and some terrifying threats. This legislation is going to affect everyone in our industry. I believe it is a bigger issue than we all think. Some background detail would be helpful here. The UK’s annual consumption of refrigerant gases is 9000 t, and it is rising. Of that consumption, 60% is used to top up leaking systems. The main gases in question are R410A, R407C and R134a — and all have a very high global warming potential. For example, a kilogramme of R410A released into the atmosphere has the same global-warming effect as 1900 kg of carbon dioxide — which is equivalent to driving a car 10 000 km. So exactly is the F-Gas Regulations? It is EU legislation to try to reduce fluorinated or F-gases released into the environment to help reduce global warming. The main thrust of the regulation is: ‘All measures that are technically and economically feasible shall be taken to prevent and minimise the emission of fluorinated gases.’ System designers should therefore minimise refrigerant charge and ensure that systems are designed and installed to reduce the chance of refrigerant leakage by installing pipework so as to avoid damage that could lead to leaks. Contractors are bound to provide an inspection programme and a full and auditable record of refrigerant usage. Engineers have a duty to recover refrigerants, and the use of non-refillable containers will be banned. They must also ensure that people executing containment, inspection and recovery are adequately trained. Contractors must also ensure the charge is correct — nearly a third of air-conditioning systems in the UK are operating with a depleted refrigerant charge. Amazingly, a 15% loss of refrigerant can halve the cooling capacity of air-conditioning equipment and double the running cost. On average, refrigerant leaks add 11% to running costs. Inspection
Refrigeration and air-conditioning equipment will need ‘regular’ inspection. The frequency depends on the volume of refrigerant in each system. Every system containing more than 3 kg of refrigerant will need to be inspected annually. Systems containing 30 kg or more will need two visits a year. For example, three separate split systems on a site would be viewed separately so each system in a VRF installation is a separate entity. The frequency of the visits can be reduced if a system for detecting refrigerant leaks is installed.
| The owner of an air-conditioning system is responsible for keeping the records required by the F-Gas Regulation. |
The scope of an inspection has still to be finalised, but current thinking is that a visual inspection and a leak detection exercise of the most likely components to leak will suffice. This is the sort of testing which most engineers already cover in a full maintenance of the system. Full details of the inspection requirements will be available soon. To carry out inspections, the engineer will need to hold appropriate qualifications; this is a first for the refrigeration industry, which until now has been completely unregulated. The training requirements are still to be finalised but are expected to be either City & Guilds 2078 or a CITB safe-handling certificate. Both qualifications are simple to achieve and can usually be gained in some short and sharp, but thorough, training from a variety of suppliers. Once qualified the engineer will receive photographic identification and a certificate — and may need to produce them if the refrigerant system is audited. Inspectors will also need a qualification to carry out the work. The level of qualification is still to be finalised but will most likely be based on the guidelines laid down for handling ozone-depleting substances (2037/2000). The benefits
Training will be critical. Consider these figures. A qualified engineer typically releases 9 to 15% less gas while servicing. In the refrigeration and air-conditioning sector, 5000 to 8000 refrigerant handlers will need to be qualified. Of 15 000 to 20 000 working in the sector, 3000 are already qualified. It is estimated that once implemented the F-Gas regulation will reduce the leakage of refrigerant by about 1100 kg per annum —equivalent 1.5 to 2.5 Mt of carbon dioxide. In purely financial terms that saving is worth £8.5 million. What must the system owner do? Every system containing 3 kg or more of refrigerant will need a record or log book of the quantity and type of HFC used, in which should be entered details of refrigerant added or recovered and who carried out the work. The system owner is responsible for keeping this record and making it available to the relevant competent authority if requested. The end user will also be responsible for ensuring the person inspecting their system is qualified to do so. The system owner has a number of obligations to meet and is the person or organisation exercising actual power over the technical functioning of the equipment covered by the legislation. In most cases, the operator will be the unit’s owner. However in landlord-tenant relationships the details of the air-conditioning responsibilities should be covered in the building lease. The owner must ensure he has a record of all refrigerant on site and how much has been used and by whom. If necessary, the report shall be made available to the relevant authorities. The owner also needs to ensure that anyone working on the system is adequately qualified; here comes that ID card again. The Environment Agency will appoint inspectors to administer and enforce the regulations. Their powers will include the right to enter any business premises to make an inspection, demand any records necessary for any examination or investigation and to take copies. Failure to comply will be deemed an offence. It shall be an offence to intentionally obstruct an authorised person in the exercise or performance of their powers, furnish to an authorised person any information which he knows to be false or misleading and fail to produce a record when required to do so by an authorised person. A person guilty of an offence will be liable to a fine or even imprisonment. Timetable
The regulation comes into force on 4 July 2007. By July 2008, all details of qualifications, inspections and testing will be provided by the Government. Engineers will need to be qualified from July 2009 to handle refrigerants and carry out inspections. The industry needs to be looking to the manufacturers which have prepared thoroughly for this coming — in terms of products with ease of installation, improved performance, reduction in refrigerants and greater provision for training. Graham Hendra is technical manager with LG’s air-conditioning division in the UK.