Respond to draft F Gas regulation implementation measures - 5/8/2008
Refrigeration and Air Conditioning industry asked to help shape registration schemes under new F Gas Regulation consultation
ACRIB has produced a Briefing Document summarising the key issues within the consultation and a template for responding to the consultation which can be downloaded below:
More detail - At a press briefing held on 5th August the Air Conditioning and Refrigeration Industry Board, which represents key trade and professional associations in the sector, outlined the impacts of recently issued DEFRA draft legislation on the stationary refrigeration and air conditioning sector. The Board issued a call to action for the whole of the industry in response to the 11th July consultation on further implementation measures on F-Gases and Ozone Depleting Substances Regulations
The consultation and the draft Regulations reflect decisions that have been made at a European level over the past year few years. However significantly, DEFRA is now inviting views on establishing UK registration schemes which will influence the effectiveness of the application of these decisions in the UK. ACRIB is calling on the refrigeration and air conditioning industry to put forward a strong message of support on the critical issues of registration of companies and individuals.
ACRIB member organisations believe that only a fully integrated registration scheme will make these Regulations work in practice. This means company registration with regular audits and at least five yearly renewal, backed up by a single source low-cost individual registration scheme. This would reflect the current voluntary registration schemes which have had widespread support from industry to date, and which are managed for and by the industry by REFCOM and ACRIB. No other bodies have the past experience and understanding of the RAC sector to be able to satisfy the requirements of the Regulations in the time available.
“Have no doubt about it. This piece of legislation will have an impact on every one of the 5,000 businesses and 35,000 individuals working in the use of F Gas refrigerants”. Mel Bridges, Chairman of the ACRIB Education & Training Committee comments: “Whilst is likely to cost us in this industry up to £35 million in training fees, Government is hesitating to specify the rigorous management structures which will be needed to ensure that everyone complies with these requirements. This is not acceptable. For a small cost of up to £700,000 to introduce mandatory individual registration and an additional £35,000 for a more rigorous company registration we can be reassured that the costs are shared by everyone, not just those responsible companies and individuals who would comply anyway. These costs also have to be weighed against DEFRA’s anticipated benefits of compliance with the Regulations of up to £257million when savings possible due to reducing leakage and improving energy efficiency are taken into account“
ACRIB F Gas Implementation Group Chairman Mike Nankivell commented “We are seeing for the first time some hard numbers from Government in terms of cost implications, cost savings and environmental benefits of the training and registration aspects of these Regulations. The ACRIB F-Gas Implementation Group have scrutinised the consultation documentation and come up with some key pointers for industry to respond to. We are working closely with end users, contractors and other representative bodies to make the most of the opportunity to influence the final shape of the regulations by the 3rd October deadline”.
This consultation is a unique window of opportunity to influence the future of the RAC industry. Widespread industry support for the registration schemes must be received by DEFRA by 3rd October 2008 so that the legislation can be finalised for implementation in February 2009. The basic company registration scheme must in place by July 2009.
ACRIB wants to see 100% compliance with these Regulations to ensure that only responsible companies continue to operate and those who cut corners are prevented from undermining the sector. It sees the solution as an integrated registration scheme providing the benefits of:
- Accurate and up to date records of individuals and companies operating in the sector to prevent fraudulent operation and use of forged certificates.
- Single central databases for use by end users, employers and enforcement agencies to check the status of those working in the industry
- An essential communication route to everyone in the industry to ensure they are up to date with any future changes in refrigerant handling legislation and to prove compliance in the future.
Mike Nankivell concludes “Questions 15,16,19 and 20 in the Consultation document are crucial. We need a strong and concerted message from industry if an integrated company and individual registration scheme is to be achieved. Without an appropriate steer from industry in response to this consultation, we will find ourselves subject to a series of bureaucratic, ineffective and impractical solutions”
ACRIB has produced a Briefing Document summarising the key issues within the consultation and a template for responding to the consultation which can be downloaded below:
Notes:
1. See full DEFRA Consultation at : http://www.defra.gov.uk/corporate/consult/fgas-ozone/. This includes a consultation document, regulatory impact assessment from which figures quoted are drawn and the draft legislation.
2. Consultation Questions:
- Company certification for stationary refrigeration, air conditioning and heat pump equipment and fire protection systems
- Question fourteen: Views are invited on what body or bodies might be designated by the Secretary of State as certification bodies and on what type of certification scheme is preferred?
- Question fifteen: Do you have any comments on regulations 22 (certification bodies for companies), 23 (certificates for companies) or 24 (interim company certificates) or 25 (mutual recognition)?
- Question sixteen: Do you have any comments on how the company certification schemes should be operated (i.e. renewal or nonrenewal?)
- Question seventeen: Do you have any comments on regulations 29 (certification bodies for companies), 30 (certificates for companies) or 31 (interim company certificates) or 32 (mutual recognition)?
- Question eighteen: Do you have any comments on how the company certification schemes should be operated (i.e. renewal or nonrenewal?
- Personnel registration
- Question nineteen: Would you like the Government to propose regulations to require mandatory personnel registration in a future consultation?
- Question twenty: What reasons do you have for supporting or not supporting mandatory personnel registration?
3. Responses to the consultation must be sent by 3rd October to:
Stephen Cowperthwaite
Defra
Climate, Energy and Ozone, Science and Analysis Division
3F Ergon House
17 Smith Square
London SW1P 3JR
Tel 0207 238 3179
Fax 0207 238 3341
fgas@defra.gsi.gov.uk