Steve Crocker of REFCOM looks at the implications for contractors of the forthcoming F-Gas regulations
WITH the F-Gas Regulations coming into force on July 4 2007, contractors need to be aware that they will be directly affected by Article 3 Containment, Article 4 Recovery and Article 5 Training and Competence.

The Containment Article ensures that the equipment operator is legally responsible for preventing leakage of HFC gases, for repairing any detected leaks within four weeks and that the repair to the leak is checked again after four weeks.

Under the Regulations, the operator is defined as the natural or legal person exercising control over the equipment and must ensure it is leak-checked by certified persons.

Depending upon its size and capacity, plant equipment containing HFC refrigerant must initially be leak-checked along the following lines: 3kg to 30kg charge – annually; 30kg to 300kg charge – six monthly; 300kg and over – three monthly.

Good non-leakage records will allow less frequent further inspections at half the previous rate. Recording of all system maintenance will be compulsory and each item of plant will have its own logbook and the operator charged with its upkeep. It will contain the type and quantity of refrigerant used and any quantities added or recovered during installation, commissioning, servicing, maintenance and de-commissioning. It must also hold details of the company carrying out the work and the personnel undertaking it, as well as the results of the leak-checking regime.

Article 4 Recovery ensures that only qualified and competent personnel carry out any recovery of refrigerant in order to minimise the chance of leakage.

They must use properly designed and maintained equipment to carry out the recovery work. All plant to be de-commissioned is to be fully evacuated and the recovery refrigerant collected and sent for reclamation or destruction.

Article 5 Training and Competence ensures that any refrigerant handler is suitably certified to undertake refrigerant transactions. The equipment operator is legally obliged under the F-Gas Regulations to ensure that this is the case.

There is to be mutual recognition across the EU member states for minimum standards governing both companies and personnel, regarding training programmes and certification. Without proper qualification and certification, companies and operatives will be unable to take delivery of HFC refrigerants.



Registration

At this precise moment, DEFRA/DTI are still considering options for company and operative registration and it is therefore difficult to predict what path they will choose. DEFRA/DTI seem to be in a position where they are reluctant to make any concrete decisions as they do not have the guidance of primary legislation and are compelled to follow what is written in the F-Gas Regulations.

The legal situation is proving difficult as the Regulations have been introduced along both environmental and ‘internal market’ routes. This means that all member states must do the same thing in controlling fluorinated refrigerants, but each member state cannot go further than the agreed common position regarding the methods and standards used to comply with the Regulations.

As a result of repeated changes in order to establish consensus across the EU, the Regulations have become poorly worded and fail to allow definitive methods to be employed that would guarantee wholly validated statistical data, proving that targets for leakage rates have been met.

What is certain is that both company and operative registration is the only valid way for the UK to be able to validate its claims that leakages of HFCs are being reduced, in line with quoted levels, by the UK Government - although these emissions targets are somewhat vague.

It is the belief of REFCOM that some form of company registration is going to be instigated – and as REFCOM is the only registration scheme before Government, and recommended by ACRIB, it is likely to be the scheme of choice. Operative qualification/competence levels are likely to be City & Guilds 2078 or CITB in Safe Handling of Refrigerants as well as ACRIB registration

Tracking software

In order to enable refrigerant users to easily keep track of its refrigerant, REFCOM has launched REFCOM 2007, a piece of software that has evolved from its Refrigerant Tracking Database. REFCOM 2007 has been upgraded to provide an even easier and more accurate means for users to log, track and record refrigerant movement between supplier, cylinder and plant – from commissioning and charging, through to subsequent recovery and final disposal. The upgraded software will prove crucial with the implementation of the new F-Gas Regulations and also covers related legislation, including the Hazardous Waste Regulations 2005.

Based on standards already aligned with proposed Government F-Gas initiatives and recognised by ACRIB, REFCOM provides the best scheme to ensure that companies remain ahead of the game and, most importantly, fully compliant with industry regulations.

REFCOM 2007 boasts an all over upgrade with several new features, including a backup facility to save entries as the user goes along and regular updates to ensure that the customer is constantly experiencing the product at its best.

Written with the future in mind, REFCOM 2007 software also allows for easy updates and bolt-ons to cope with new legislation. For the larger companies, the programme is now available with a multi-user license, enabling offices to link the programme across several computers at once.

REFCOM

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