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Fox's Tales
by Graeme Fox Graeme Fox is an RAC contractor based in Dundee. He is a director at AREA (Air Conditioning & Refrigeration European Contractors' Association) and a member of the Institute of Refrigeration. |
What do we want from the F-Gas Review?
10/06/2010 14:42:57The review of EC842/2006 (F-Gas) isn’t until 2011 but the work of the interested parties – industry stakeholder groups, trade association bodies and lobbyists – has already begun in earnest.
The ACRIB F-Gas Implementation Group has started the dialogue in the UK already on what successes and failures have been observed so far. On the continent, in each member country, the same process is starting up – although in some cases, where full implementation hasn’t actually happened yet, the process of implementation has simply become the review consultation.
At AREA, the Air Conditioning and Refrigeration European Contractors’ Association, we started the work on formulating an AREA F-Gas Review position last October. Earlier this month we had our annual spring general assembly in the beautiful city of Krakow in Poland and one of the main agenda items was to discuss the current and on-going F-Gas position in each member’s country.
The really encouraging aspect of this discussion is the realisation that, although a few countries have still not fully implemented the Regulation, everyone is fully on board with the principles embedded in the legislation and everyone wants to improve the effectiveness of the Regulation.
But what is the principle behind the legislation and how can it be improved? Some have really lost sight of this crucial point.
The purpose of the F-Gas Regulation was to minimise fluorinated greenhouse gas emissions, not to work towards getting rid of fluorinated gases all together. Some have tried to persuade the Commission that the Regulation hasn’t worked and that the only way to reduce emissions is to ban the use of the gases. What utter nonsense.
Ask the technical people across Europe and the message will be the same: There is a large portion of the RAC & HP applications for which, not only is there no practical alternative, but the most energy efficient heat transfer fluids are HFCs. Let’s stop talking about theoretical modelling and go back to looking at evidence and knowledge-based criteria.
Having said that, we all know we need to reduce leakage from refrigeration systems. Some of the existing leakage comes from known issues – joints prone to leaks such as flare nuts, valve stems, etc – but a great deal comes from the “unknown”, i.e. the cowboy sector. As a responsible sector we can deal with the former by lobbying for manufacturers to supply less equipment with flare nuts, thereby requiring installation by people with relevant skills. But the latter has to be addressed by government: the cowboys will only be driven from our industry by effective policing of existing and future regulations.
The 3kg threshold is a bone of contention. If you read the text of the Regulation, the term 3kgs is only mentioned in relation to whether or not annual leakage inspection is carried out – yet our last government interpreted it in such a way that, if a system has less than 3kg charge it doesn’t come under the scope of F Gas and doesn’t show up on the radar anywhere. End result: certain manufacturers deliberately brought out systems with a 2.9kg charge! Or am I just being cynical?
A few pointers as to what AREA wants from the review:
Removal of flare nuts, to be replaced by brazing stubs;
Mandatory registration of all operatives handling or working with refrigerants;
Revisit the 3kg limits written into the Regulation.
Anyone care to add to this list? Now is your opportunity….
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F Gas Review
By Steve Walker
I personally feel that the 3kg cap for F Gas purposes should be complely removed, therefor Any and ALL systems will have to comply with the regulations. There will be no arguments as to who should and shouldn't need to keep records and have checks carried out. Even playing field for all.
By Anonymous
Thanks for the comment Steve, I agree totally with your sentiments - a level playing field for all contractors.
The only concern would be to exclude small domestic fridge freezers as this would impose disproportionate costs on householders. However, this would limit us to around 100gms so all other RAC systems would come into the scope.
Keep reading the blogs, I'll follow up this one very soon with a more detailed look at the misinterpretation of the 3kgs reference.
Thanks again for reading and commenting.
Graeme
F Gas Review
By Steve Walker
I personally feel that the 3kg cap for F Gas purposes should be complely removed, therefor Any and ALL systems will have to comply with the regulations. There will be no arguments as to who should and shouldn't need to keep records and have checks carried out. Even playing field for all.
By Anonymous
Thanks for the comment Steve, I agree totally with your sentiments - a level playing field for all contractors.
The only concern would be to exclude small domestic fridge freezers as this would impose disproportionate costs on householders. However, this would limit us to around 100gms so all other RAC systems would come into the scope.
Keep reading the blogs, I'll follow up this one very soon with a more detailed look at the misinterpretation of the 3kgs reference.
Thanks again for reading and commenting.
Graeme
