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F Gas Review: 3kgs References

I've given some thought to my last blog - I had great difficulty in keeping it brief and probably ended up cutting out some important information. When reader Steve Walker promptly posted a comment about the 3kg references being removed completely I thought a follow up blog just on that topic would be a good idea.

First, the actual text of the Regulation as published in the European Journal (very much abbreviated obviously to the relevant paragraphs for the purpose of this blog!):

Commission Regulation (EC) No. 303/2008
Article 2

Scope

1. This Regulation shall apply to personnel carrying out the following activities:
(a) leakage checking of applications containing 3 kg or more of fluorinated greenhouse gases and of applications containing 6 kg or more of fluorinated greenhouse gases with hermetically sealed systems, which are labelled as such;
(b) recovery;
(c) installation;
(d) maintenance or servicing.

2. It shall also apply to companies carrying out the following activities:
(a) installation;
(b) maintenance or servicing.

When we look at Article 2 - the scope of the regulation it looks fairly straight forward. It is hard to see how the UK government interpreted this to have 3kgs relating in any way to installations, maintenance or servicing. It is clear that for these items the Regulation should apply regardless of refrigerant charge. The only mention of any refrigerant charge weight is in relation to leakage checking. Seems pretty clear to me!

In fact the only reason there is any mention about refrigerant charge weight is in relation to the frequency of inspections required - annually, six monthly or quarterly, etc. It seems to me that the UK interpretation of the F Gas Regulation not only misses the biggest opportunity to raise standards across the board in our industry - even though the RAC sector has been screaming for mandatory registration of operatives and companies since I was learning how to evacuate a split system - but they also seem to be ignoring the spirit of the Regulation.

A lot has been said already by me and others about the change of government we have just had, and the shortcomings of the last lot, but let's pray for some common sense to prevail when the present government's civil servants take delivery of the industry representations on the F Gas Review.
View User Profile for GraemeFox 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 18 June 2010 12:41:50 Categories: Fox's Tales

Comments

By Peter Wright
18 June 2010 12:46:50
It was may intention in my comment in response to this article to point out that there have been major changes in the Aircon & Heatpump markets which have created a requirement for adaptions to the existing regulations; now would be a good time to look at them closely.
The world market is being supplied with low cost domestic units about which suppliers assure customers that they are both able and legally entitled to fit.
Some changes have been made to allow kitchen companies to handle Natural Gas; there seems no reason why competent people shouldn't be able to demonstrate their abilities and have levels of F-Gas Certification restricted to evacuating, leak testing and fitting pre-flared piping on pre gassed low volume systems with higher levels for pipe make-up, and topping up systems using appropriate guages.
There is a ready & valuable market for established companies to service, repair, validate, leak test & otherwise assist domestic, installations. These services currently seem as non existent as training Centres for F-Gas.
I had some discussion with Training Organisations on Certification, but the trouble here is that the training organisations are bound to a single and exhaustive standard and are bound to test for all of it and enforce it. They may not adapt their courses. They reasonably point out that if there was any failure by any of their trainees, they would lose their licences to train; so the situation is locked by regulation.
Most of regulation is about leakage avoidance, and this at any cost.
Manuals for the equipment I have, say that gas should be released through the system while open at the end until a white cloud of condensing gas is emitted to ensure the system is flooded and all air expelled. I'm sure everyone has now died of fright, however this is today the manufacturer's manual is very real.
All the same, an entirely different set of regulations daily permit the release of R22 and R134A in 'Air Duster' aerosols and in various paint, BB and other guns which is equally bizzare. One would't like think of the quantities of R134A released due to car accidents!
Scientist argue that these refrigerant gasses are used because they are inert, environmentalists say they destroy ozone and curiously point at the solar sub-particle bombarded magnetic poles but not, apparently, at the equator nor anywhere else.
Germany has decided to have a 10 year moritorium on Climate Change action as the models have not been working out in practice. My pals in Particle Physics tell me the climate models were going wrong from the very early days but the politicians were on board and couldn't quit. Effects on Saturn, Jupiter and Mars show that the heat output from the sun is increasing to a predicted sunspot maximum in 2013 and we are aware that the polar ice caps have come and gone many times without human or the internal combustian engine's assistance.
My own interest stems form physics and the Carnot Cycle and how I can possibly take advantage of it. It is paramount to realise that Heatpumps do, as a practical reality create 3kW or better in heat delivery when supplied with 1kW of electrical power. This heat transport system doesn't break ths laws of Thermodynamics that Thompson (Kelvin) enumerated but in fairness he searched for Carnot's book in Paris to unravel the truth. The theromdynamic alternative is to lose 70% of power in conversion losses through devices like fan heaters which yield about 300W of real heat for the same 1kW of electricity.
The item I was designing revolved around extracting heat from the atmosphere at 5C-8C as the optimal point. Extraction efficiency falls off as temperatures depart from the point while freezing of the outdoor end equipmemt would take place in lower temperatures which has to be addressed. It all works out nicely on paper and I looked as the various gasses that I might employ. Ammonia looked nasty, Butane and Propane readily available, but are hydrocarbons and explosive if leaked (as already reported I see in the guise of R600A). Research led me to R134A which wasn't marvellously efficient while R410A was very good but required high pressures which are awkward to handle and looks impossible for open drives that I wanted to use. I reasoned that in winter 5C would be a good central point. It doesn't get much colder than -5C (for long) where efficiency wouldn't be too bad, nor is much heating required above +15C either. The best outcomes look like they would be achieved using two gasses in two cascaded stages, or perhaps the same gas in two stages using different pressures to obtain two optimum points, to step up temperatures. I believe Mitsubishi is developing units on this basis at present.
More research revealed that making up heating coils is not commonplace, is conducted on a volume basis, and one-offs would be more expensive than the cost-saving obtaianable from a prototype.
The good news turned out to be that there are plently of air conditioning units which include heat pumps that have become available recently that could be employed for practical evaulation.
At 9C ambient the system consistenly produces 55C. Now for the rest of the world would wake up.
Greece offers Eur 500 for anyone to throw out their aircon units and replace them with new ones with heatpumps. Here in the UK, no-one has even heard of a heatpump.
I have little doubt that the future of heating in Britain is in this technology and hope that my comments will filter back to the European Regulators
An unexpected downside to my endeavours is that I have accidentally and innocently acquired a posse. In the circumstances I've been compelled to change my name and can be contacted in future as Armin Sellafield.
By Chris Alexander
18 June 2010 12:45:50
Hi Guys,

As many of you know my company is in the process of training the persons that are to shortly enforce these regulations. We have already trained over 300 trading standards officers in the Air Conditioning Energy Assessments Regulations (Energy Performance of Buildings Directive) and we have been asked to follow up this training with further training on the fgas regulations which we are now starting.

The understanding we have on the law is the same as Graemes and that is what the CPS have told us is their stance- ie the leak checks are only for systems with more than 3kg or more of refrigerant, but that the regulations in respect of recovery, servicing or installation apply to ANY system no matter what amount of refrigerant they contain.

What is clear to me, is that there WILL be effective regulation of companies. Trading Standards Officers have been briefed on how to check both the Fgas register and the refcom register etc and will be checking to see if those carrying out SRAC work in their areas are suitably registered.

As for there being a shortage of courses available to do the 2079 qualification I disagree. I recently took on another two engineers and who had 2078 and wanting to get them upgraded I manage to get them on an outside course within 2 weeks.

The message has to be perfectly clear;

IF YOU ARE NOT QUALIFIED AND REGISTERED, and if you are carrying out air conditioning installation servicing or maintainence, they YOU CAN EXPECT to be prosecuted.

Sorry if that sounds harsh, but thats the way of the world now- and after all - we have been expecting these regulations for the last twenty years or so to my memory.

Good luck and stay safe.

Chris

By Michael
18 June 2010 12:44:50
Mr Duckett,
I suggest you read Mr Wright's comments again as you've got it all wrong!
By Kenneth Duckett
18 June 2010 12:43:50
1) For someone breaking the law, Mr Wright, it is a brave man who publicly announces his law-breaking in this way, and even braver if you have used your correct name too. Normally, a law-breaker will only boast in front of other law-breakers or those who do not know the laws. However, most reading this webpage will be engineers or managers who are well aware of the basic laws, at least, and will be raising an eyebrow at your revelation.

In the air-conditioning & refrigeration industry, like most industries, there are technical levels of engineer competence, and there are relating laws/regulations. These are quite separate and different matters, of course, but both apply.

You might be technically able to install an air-conditioner that works (we assume you carefully verified the system was free of moisture and your pressure test was adequate for the working pressures in the system, which is very doubtful), but your technical abilities are just the half of it. Have you broken the law? That s the key question, isn t it?

As a car-example: you might be able to drive a car perfectly well but, when you drive it on the roads, are you breaking the law with no driving test, road tax, insurance, MOT, etc. Your competence level would mean absolutely nothing at all when hauled up before the beak.

Similarly, if you continue to install, maintain, or repair aircon systems without the legal compliances, YOU will wind up explaining yourself to the beak. And your estimation of personal competence will mean nothing at all. The court will want to know about your compliance with the relevant laws.

It may be the case that there are still many professional engineers that have not yet obtained their Safe Handling of Refrigerants Assessment and somehow their circumstances allow them to continue working without passing the assessment. Nevertheless, the legal squeeze will continue and, like computerised MOTs and camera-detection systems in police cars, eventually there will be no escape for the unqualified fridge worker.

And justifications concerning the nearness of training centres, and whether there is any real basis for making these laws and regulations in the first place will not help your defence at all.

2) As for the government missing the biggest opportunity to raise standards across the board in our industry, I think this is a little off target. The problem that we are trying to solve is NOT simply to raise standards for the sake of raising standards; it is surely all about preventing damage to the environment. Reducing that damage tends to involve raising standards but lets not all loose track of things and confuse the issue with raising standards as the target. That would be foolish.

All these extra regulations and requirements have a price tag that adds to the cost of the product, and as the product gets ever more expensive, in the biggest recession since a long time ago, the customer is less willing to buy. I am sure you can work out the following consequences, which hits everyone in the industry one way or another.

And I think we have had enough of these raising of standards in the industry for the time being. There are enough laws and regulations for us all to catch up with already without requesting even more be composed and applied on us. I hate being controlled but can understand the need for some regulation; I certainly would not want to go pestering authorities to burden me with further regulations.

If the existing laws and regulations were simply applied fully, with all the law-breakers like the one above made to comply, and all the ACR companies properly F-gas registered, you would have done a superb job of reducing the environmental damage from refrigerants.

Having said that, there is one important upgrade that has been strangely missed, or carefully avoided, concerning handling of refrigerants: that is to prevent imports and sale of aircon/fridge equipment, containing any refrigerant. (The condensers could have a holding charge of nitrogen instead.) Any engineer wanting to install the equipment would obviously have to buy refrigerant from a refrigerant distributor and the distributors are already restricting sales to safe-gas engineers and F-Gas companies. Easy to control/enact; strange it has been overlooked as an obvious control measure. It would prevent all the Mr Wrights from continuing to break these laws.
By Peter Wright
18 June 2010 12:42:50
I have fitted a couple of splits effectively and economically with standard 'engineers care' and ability.
Having enquired about obtaining F-Gas certificates I find there are no local training or certification centres.
For small splits I'll never braise anything, nor do anything more than evacuate, leak check and release pre-stored R410a.
There is no certificate that would cover this degree of involvement.
The training problem is that the certification people need to make a living at it, and for them, it isn't economic to do a 50 competence check on capable people.
Most people haven't heard of a Heat Pump, Ozone holes exists at the poles due to sub atomic bombardment down the magneic lines of force and have always been present; discovering them doesn't make them new and hazardous.
There is little CO2 in the seas and without carbon there is no life. Most carbon ends up at the bottom and so the only CO2 available is absorbed at the surface, and is in great demand.
Clouds cut out the sun effectively while heat produces them. Natural systems look homeostatic to me.

Comments are closed on this post.
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