The leaked F-Gas review document contains a number of significant ‘wins’ for contractors’ association AREA, according to Graeme Fox
While there are always areas for improvement, the findings of the leaked F-Gas review provides real benefit to our members, thanks to some significant changes in the control of placing refrigerant gases on the market.
Of course we can’t be 100 per cent sure that these changes will make the cut when the official review document is released later this year, but logic tells us that the leaked changes are pretty close to the mark. So a ban on pre-charged split systems, mandatory certification for alternative low GWP refrigerants, and the addressing the 3 kg issue, together with a focus on transport refrigeration, are all welcome in terms of improving standards.
In particular, the mandatory training certification issue addresses a concern that alternative refrigerants (to HFCs) come with safety concerns such as flammability, toxicity, and high pressures. Flammability, in particular, concerns contractors. If we are going to be forced to use flammable refrigerants, we are concerned about the insurance costs in particular, together with the health and safety implications.
Without addressing areas such as leakage, and by bringing in gases that have lower environmental concerns, the irresponsible side of the contracting industry will take the attitude that the gas is fine, and ok to leak. AREA is neutral on the selection of refrigerants, but if you’re going to ban HFCs in some sectors, you need to make sure you have a properly trained workforce when dealing with dangerous gases and enough suitable tools and equipment to carry out the legally necessary work. There is a real lack of recovery equipment, electronic leakage checking tools and other electronic service tools that have been certified as OK to use with flammable gases. How are we supposed to comply with the legal requirements of the regulation if there are no tools available to carry out these requirements?
The issue of pre-charged equipment is another significant point. The authorities thought when they wrote the original regulations, that by making it illegal to take delivery of gas it would stop the cowboys getting hold of refrigerant. And this would stop them installing AC and heat pump equipment.
What they failed to appreciate was that a large percentage of gas in split-systems isn’t sold in bottles, it comes pre-installed in AC and HP systems. Furthermore, pre-charged AC systems, particularly in Southern Europe, can be bought in supermarkets, where there is no regulation regarding who installs it, so how do you ensure it’s professionally installed? A ban cuts off these loopholes in one easy step
The manufacturers, voiced through the European Partnership for Energy and the Environment (EPEE), are obviously against this, but let’s be clear, the EPEE doesn’t represent the RAC industry’s interests, it represents the manufacturers’. The EPEE has come out very strongly against a ban. However, we’ve answered all their questions on the subject and they come back with more issues, and some of them are laughable. They’ve even claimed that stopping pre-charging at the factory would lead to 2 per cent emissions instead of 0.5 per cent.
Manufacturers have no way of determining leakage rates in the field without contractor input and they’ve never even asked us for these figures. But we’ve calculated based on one member country’s figures that, even if we were to accept the EPEE’s emission rates, then the overall emissions would be seven times less per annum.
The argument over having to test a unit using a charge before you sell it without doesn’t hold weight. Manufacturers do not test every system at the factory fully, they test hat the compressor works, the fan turns and the electrics communicate – they don’t need a refrigerant charge for this. Every contractor I know has had ‘dead on arrival equipment’ so they can’t test units thoroughly.
However, for all the potentially positive changes in the F-Gas review, there are also a few things that don’t add up. The new 2150 GWP rule specifically discounts R404A, which has been prone to heavy leakage. In almost every application there are now suitable energy efficient alternatives, and the sector is already moving away from this gas.
Back door ban
One of the remaining problems is that one of the bans refers to servicing and maintenance for F-gases above 2150 GWP from 1st Jan 2018, yet you can still sell equipment of these gases up to 2020. So if you have a R404A system in a commercial kitchen bought in the past year, for example, in six years’ time you will not be able to do any service and maintenance on it, which means the system becomes less efficient. They are trying to force a ban through the back door.
A phase-down, and not a phase out, is the right choice as emissions are coming down, these extra steps aren’t designed to make the regulations harder, they’re designed to make them more effective as it stands.
Things are changing for the better, and if the commission continues to be progressive in its thinking things will continue to do so.