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.