A wake-up call for manufacturers

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A wake-up call for manufacturers

My last blog certainly created a stir - a good number of responses from a variety of sources and several others contacting me directly rather than going public. I've also been in dialogue with a couple of the larger manufacturers as well as with EPEE, the European body representing manufacturers. The attitude towards the proposal seems generally pretty clear: large Japanese and American manufacturers are against the proposal; contractors and SME manufacturers are for the proposal.

I am scheduled to have a face-to-face meeting with some manufacturers' representatives next week to discuss their fears and our proposal, which should be interesting. Unfortunately I don't think it will be interesting on a technical level based on the arguments made to date.

From what we've seen and heard so far the arguments are based almost entirely on self-interested commercial concerns and complaints that these measures will result in costs being incurred by manufacturers. I don't remember these same manufacturers having much to say when all the real costs of implementation for the F Gas Regulation were falling on the contracting sector.

The acr contracting sector has had to retrain every operative, regardless of ability or experience, in order that they can obtain the new City & Guilds 2079 or CITB J11 certificates necessary under the terms of F Gas and its UK implementation regulation. While I don't have a problem with that fact – indeed I have long been an advocate of raising our general professional installation and servicing standards, as anyone who knows me will confirm – it is a bit rich for another sector of our industry to start bleating now because they may incur some costs themselves! To date the only actual cost incurred by manufacturers in implementing F Gas has been to provide a sticky label to clearly identify the total charge once installed. The other measures they have brought in, such as tinkering with the charge weights and development of smaller physical footprint of systems, have mainly come about firstly because of better efficiencies of R410A compared to R22 and, thus, smaller heat exchange coils necessary; and secondly as a means of avoiding their systems coming under the scope of the Regulation by designing a system that needs less than 3kg of charge for its entire pipe run.

Contractors have been accused by manufacturers and some consultants as merely trying to make work for ourselves. Allow me explain our position a bit more clearly:
Contractors don't generally mind what gases we work with. Ask any decent refrigeration engineer who has been around a while and they really aren't concerned about the more widespread use of CO2 or ammonia that have been around for years already. At the end of the day the choice of refrigerant isn't normally ours to make anyway - we work with whatever the manufacturers design their systems to run on.
We have, however, invested huge sums of money (during a major economic recession!) in retraining and certifying our field service personnel so that we can comply with F Gas. We have also been facing the end users and having to convince them to swap out their old R22 systems with new, more efficient HFC systems. We don't need to have to face them again in the near future and tell these same end user clients that they will have to phase out these systems too, particularly when this gas is actually so much more efficient than many of the alternatives in the air conditioning and heat pump sectors.
All sectors agree that F Gas is not very effective at present. Poor implementation across much of Europe has been as much about exploitation of loopholes as it has been about any lack of political will. AREA has looked long and hard at where effectiveness can readily be improved and the obvious conclusion was that the loophole surrounding the issue of preventing non-qualified installations needs to be closed. The manufacturers wouldn't agree to any move that might "interfere with their supply chain" - yes, those are the words they used! So the only logical solution is to stop pre charging systems.
Supply chains will be left as they are, refrigerant supply can be controlled easily, and the cowboy sector will be severely hampered.

A number of comments to my last blog, during private conversations I have had with various prominent industry people, and the results of numerous national surveys, not least of which the one carried out by this website, confirm this is what proper contractors actually want.

Isn't it about time that the large manufacturers started listening to their customers instead of always thinking they know best?

Graeme Fox is an RAC contractor based in Dundee. He is a director at AREA (Air Conditioning & Refrigeration European Contractors` Association) and a Fellow of the Institute of Refrigeration.

Posted by Graeme Fox 01 December 2010 17:37:47 Categories: Fox's Tales

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Comments

By Graeme Fox

01 December 2010 17:42:47

In answer to Mr Heaney and Mr Sloper:
Mr Heaney: I believe Mr Mitchell has already eloquently answered for me here, but I'd like to add that this isn't an attempt to create a "closed shop" - this is already in effect what we have, only the regulations have not been properly implemented or effectively policed across much of Europe thus far.
It is already illegal to install any system that contains, or is designed to contain, fluorinated greenhouse gases unless they are properly qualified and certificated - in the UK this means C&G 2079 or CITB J11 basically. All our proposal will do is make it easier for national Governments to police the regulation more effectively.
To Mr Sloper:
AREA is not proposing that the UK bans pre charged splits - that would be the domain of the HVCA RAC Group or the BRA. AREA is a Brussels based organisation, representing contractors from right across the continent - 19 countries at the last count. Our proposal was first mooted (coincidentally) by the Australian contractors some years back - only for the manufacturers to use the excuse that their market share wasn't big enough to make this idea economically viable. Maybe, with Europe and Australia combined, the Japanese manufacturers will reconsider this argument.
AREA did actually propose this simpler measure some months ago only for the manufacturer's association to slap it down because our proposals would interfere with their "route to market". Unfortunately the reality is that, despite the public calls for a fully effective F Gas Regulation, many manufacturers are simply protecting their own share of the market, wearing blinkers to the bigger picture.
The reality is that our proposal ticks all the boxes in making the regulation more effective and is very easily implemented by the lawmakers with very little additional legislation required.
We would like the manufacturers to take some responsibility and stop pre charging all of their systems, not just that which is exported to Europe - or Australia for that matter! Environmental responsibility doesn't just apply in the UK or Europe. They have the power to truly affect the supply chain in a long lasting, responsible manner.
Isn't it about time they stood up to be counted?

By Philip Sloper

01 December 2010 17:41:47

I wonder if AREA have considered the possible supply problems if UK equipment become "specials" becuase we are the only country in the world that will not accept pre-charged units? Maybe the equipment will be more expensive, maybe it won't (my experience is that "special specifications" always cost more), but I wonder where the orders for "UK specials" will be in the queue when the production lines are busy and the rest of the world is clamouring for supply? my guess is at the back! Surely that is not going to do AREA members much good.
The simple answer is not to supply the general public, as is the proposal in France.

By Kevin Thomas

01 December 2010 17:40:47

This is a very immotive subject by the look of it. I have also been in discussion with the major players in the UK market. My concerns are that we are adding more and more refrigerant to the systems we install significantly more than we were when we used R22. The way that the outdoor units are grouped to provide larger installations is also a concern. Back to the precharged scenario. Where the required trim charge is not added to the system pipe work at installation means the system is short of refrigerant from the start, which means its uses more energy, which also means the compressor is going to fail a lot sooner. This could be considered a good business model by some? At the end of the day with the risks involved the sale of equipment and the refrigerants that go in it must be regulated. there was talk of having to use you F Gas registration with the wholesalers. For the competant and responsible companies this is not an issue. Look at yourselves therefore and measure where you are in this industry by your own response to the question.

By Norman Mitchell

01 December 2010 17:39:47

All split systems have an element of bespoke installation, the pipes joining the outside to the inside unit. These need to be evacuated correctly just as any fridge installation requires the whole to be evacuated. It is alleged that manufacturers warranty claims were higher when dry Nitrogen was the holding charge, now with the legal requirement for CGLI 2079 or equivalent to handle the refrigerant, claims should remain at todays level or less. If pre-charging remains the norm then DG Environment and DEFRA should declare the components of a split system as refrigerant containers thus requiring the neccessary proof of competence to handle refrigerants to be able to legally purchase the gas in the refrigerant containing components. This is not a closed shop exercise, it is an environmentaly friendly way of ensuring our grandchildren have the quality of life we enjoy. AREA have been promoting this idea for some years now and I'm sure the legislators are catching on quickly now. All bona fide R&AC installation and service engineers must surely support this proposal?

By Dan Heaney

01 December 2010 17:38:47

Dear Sir, Your attempt to connect "pre-charged" systems with industry cowboys and thus to get such systems banned is no more than a blatent attempt to provide your members with a closed shop. You claim knowledge of cases where pre-charged units have been installed badly requiring rectification but there is no evidence that such poor installations occur more frequently than those installed by "qualified" personnel. Indeed it could be claimed that because pre-charged units are pre-charged under factory conditions, they are a lot safer and more reliable. It really is time that the industry accepted there is room for both pre-charged systems and bespoke installations and realised that each has its place in the market.

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