Legislation Updates

Distributors who source refrigerant from companies that produce in the EU or import refrigerants do not need to pre-register and/or register their substances, but they will need to ensure that the companies they purchase from intend to pre-register/plan to register the refrigerant components. In these circumstances, distributors will be downstream users under REACH. REACH requires registration of individual substances and this means that the components of blended refrigerants need to be registered. Blended refrigerant does not need to be registered, just the individual components. Recycled refrigerant will need to be registered. The Regulation 2006/1907/EC concerning the registration, evaluation, authorisation and restriction of chemicals (REACH) was finally adopted by EU Member States in December 2006. It has entered into force on 1 June, 2007. The European Fluorocarbons Trading Council provides helpful guidance on REACH and Refrigerants which can be downloaded from the link on the title above.

This Guidance Note explains your obligations under the Hazardous Waste Regulations (as revised April 2009) and provides a sample consignmentnote for you to customise. It has been approved by the Environment Agency. The contractor is the PRODUCER and CONSIGNOR of the Recovered Refrigerant (which is officially hazardous waste) and has the responsibility to ensure that the material is handled correctly and in compliance with the regulations, the required CONSIGNMENT NOTE is prepared and accompanies the material when it is moved from the site where it was produced and the appropriate records are provided and kept.

This guide is intended to help anyone who manages or controls air-conditioning plant understand how the Directive and Regulations work in practice, how to apply the Regulations, what their responsibilities are and when air conditioning inspections are required. Free download at http://www.communities.gov.uk/documents/planningandbuilding/pdf/889248.pdf

A list of key dates for compliance with F Gas and ODS Regulations (correct as at 13.3.08)

This leaflet provides an outline of the key requirements of the Regulation related to new training and certification of personnel involved in refrigerant handling of F Gas Refrigerants. The new requirements come in from July 2008.

This European Regulation has been in force for some time but has tended to become forgotten as the industry has focussed on the new F-Gas regulations. There is some critical timing associated with the ODS regulation and it is important that all those involved with the distribution and use of HCFCs including R-22 are fully aware of the issues and take action now.

The main focus of the Regulation is on containment and recovery of F gases, together with harmonised restrictions on the marketing and use of F gases in applications where containment of F gases is difficult to achieve or the use of F gases is considered inappropriate and suitable alternatives exist. This guide has been produced by the British Refrigeration Association to inform the refrigeration user supply chain on their obligations under the Regulation as known on 4th July 2007. The guide covers the following aspects of the Regulation: • Requirements for Leak Prevention and Detection • Reporting • Minimum Training Requirements • Second Leak Check Requirement Following a Repair • Definition of Operator Plus a BRA recommendation: • Storage of Unused Refrigerant at Customer’s Site And • References • Appendixes

The EPBD requires inspection of all air conditioning systems over 12kW rated output installed in buildings. By January 2009 all systems over 250kW must have been inspected. Systems over 12kW must have had their first inspection by January 2011. The inspections will give building owners information about the performance of their equipment and identify energy saving opportunities. CIBSE, in association with other bodies including ACRIB has pubished a guidance document, endorsed by the Department for Communities and Local Government, offeringa recommended procedure for these inspections. The guide can be purchased from the CIBSE bookshop at www.cibse.org

The UK Ozone Depleting Substances Regulation was published in June this year (SI 1510/2006) to implement the requirements of the European ODS Regulation which came into force back in 2000. The UK Regulation requires that anyone servicing, maintaining or dismantling refrigeration, air conditioning and heat pump equipment containing ODS refrigerants needs to hold appropriate qualifications (City & Guilds 2078 or CITB refrigerant handling equivalent).

The EC Regulation on Ozone Depleting Substances (2037/2000) was published in 2000 and affects the manufacture and use of refrigeration and air conditioning equipment and is relevant to all users, designers, equipment manufacturers, installation and maintenance contractors. Common Ozone Depleting Refrigerants include: R22, R401A, R401B, R402A, R402B, R403A, R403B, R408A, R409A, R409B, R413A (Ozone depleting CFCs such as R12 and R502 cannot now legally be handled other than for disposal). The Regulation introduced a ban on the use of virgin HCFCs from 1st January 2010 and a ban on the use of all HCFCs including recycled materials, from 1st January 2015.