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Newsflash for end users

Leaking refrigeration and air conditioning systems cost more to run, damage the environment and are unreliable. But who is responsible for managing this problem?

End users of refrigeration or air conditioning equipment are responsible for complying with the fluorinated gas (F-Gas) and ozone depleting substances (ODS) Regulation because they are the “operator” of the system. The aim of these regulations is to reduce leakage of HFC and HCFC type refrigerants. In brief the F-Gas regulation requires that you:

  • Leak test systems with between 3 and 30 kg of refrigerant charge at least once a year, and systems with more than 30 kg twice a year
  • Fit permanent leak detection to systems with more than 300 kg of charge
  • Log leak tests and refrigerant usage on a system by system basis

Use suitably qualified engineers to carry out this work. The F Gas regulation also provides a minimum standard for leak testing - but many systems will require more frequent and more diligent testing. A more proactive approach to leak reduction can be cost effective and provides environmental benefits. FACT: A catastrophic leak of 300 kg from a retail pack has the same global warming effect as 43 minutes of electricity consumption by the whole of Wales.

Why leaks occur and how to reduce them

Leaks occur because of poor practice throughout the life of a system, in particular:

  • Inappropriate system design and the use of components which fail to contain the refrigerant
  • The use of mechanical joints
  • Poor brazing quality
  • Defective or insufficient vibration elimination
  • Unsuitable pipe routing, with insufficient support and clipping
  • Inadequate pressure testing during commissioning
  • Equipment which is old and/or located in an extreme environment
  • Insufficient or poor service and maintenance. There are opportunities to reduce leakage throughout the whole life of a plant, from its specification to design, build and maintenance, through to end-of-life decommissioning and disposal. In particular equipment owners should: Design systems in accordance with EN378:2008 and ensure they are compliant with the Pressure Equipment Regulations
  • Provide enough time for good quality installation and commissioning - this is vital to long term refrigerant containment
  • Ensure brazers are competent - the industry standard brazing qualifications include a brazed test piece which is cut open to examine penetration
  • Specify the pipe layout and routing accurately to ensure that pipe work is correctly supported and includes vibration elimination
  • Ensure that major components such as compressors and packs are mounted so that vibration is isolated

Specify a maintenance regime that includes thorough leak testing and the opportunity to identify potential future leakage risks. Life cycle costing is a veryuseful tool for comparing options for new systems and checking the cost effectiveness of replacing old equipment. The latter is especially important - for many older systems it is difficult to totally eliminate leaks.

The service and maintenance contract
An essential element to leakage reduction is employing the right contractor on the most appropriate contract to maintain your equipment. Contracts typically fall into four categories and their impact on leakage reduction needs careful consideration. The table below left separates refrigerant leakage from other requirements. Tip: Include refrigerant leakage reduction as a key performance indicator (KPI), and ask the contractor to demonstrate a strategy for leakage reduction. A guide entitled “Appointing and managing refrigeration contractors” is also available from www.ior.org.uk

The Service Contractor’s Responsibility
According to the EC F-Gas Regulation the person having control of the equipment containing the refrigerant (referred to as “the operator” and typically a company), is responsible for compliance. The Regulation defines the operator as: “The natural or legal person exercising actual power over the technical functioning of the equipment and systems covered by this regulation.” This includes:

  • Free access to the system, and the possibility to grant access to third parties
  • The control over the day-to-day functioning/running eg takes the decision to switch it on or off
  • The power to decide on technical modifications eg to have checks and repairs carried out. Therefore, responsibility usually is placed with the owner, even if there is a comprehensive maintenance contract in place. Service and maintenance contracting companies do of course carry some of the legal responsibilityfor helping to find, fix and prevent the escape of refrigerant to the atmosphere.
    Some examples include:
  • A legal obligation to employ only certified personnel to handle either HFC or HCFC refrigerants. Currently this is City and Guilds 2078/CITB equivalent, but by July 2011 all personnel will need to have achieved the new City and Guilds 2079/CITB. To provide simple confirmation of competence it is a recommendation that qualified engineers are also registered with ACRIB
  • Obtaining a company certificate and registration from July 2009 in order to purchase refrigerant legally
  • Providing a label clearly stating the type and quantity of HFC refrigerant used on new systems placed on the market
  • Recovering refrigerant from systems using certified personnel only and handling this as Hazardous Waste if no longer required by the owner. But importantly, contractors also have an important role to play in helping end users meet their own legal and environmental obligations by providing advice on areas such as:
  • The requirements of the F-Gas Regulation, including charge calculation, F-Gas labelling and the F-Gas log book
  • The requirements of the EU Ozone Regulation related to HCFC refrigerants
  • R22 phase-out options, if applicable
  • Compliance with safety standards and other industry related guides and codes
  • The environmental cost of the loss of refrigerant
  • The long-term financial cost of this loss such as increased call outs
  • The positive impact of potential savings opportunities