Industry body ACRIB outlines what service engineers need to do next to meet the terms of the F-Gas regulations
The latest development in the long saga of the F-Gas regulations took place in July 2008 when the Government issued draft proposals for the new F-Gas qualifications for refrigerant handling and the suggested arrangements for registration of companies.
Although the legislation itself is not new, the proposals issued in July do make it clear how the European Regulations are to be interpreted for the UK industry.
The drafts themselves are a bit weighty (46 pages of consultation questions, a 110-page assessment of the costs and benefits,and two sets of regulations themselves amounting to 45 pages).
But in essence what they are saying for service engineers and contracting companies boils down to nine points:
- If you are carrying out leak checks you have to comply with the Commission standard procedure for leak checking
- If you are responsible for installing new site assembled equipment containing F-Gases, you must ensure it is correctly labelled.
- If you don’t have an existing refrigerant handling qualification (C&G 2078 or CITB) you are working illegally and you and your company will be subject to a statutory fine.
- If you do have an existing refrigerant handling qualification, you can continue to handle F-Gas refrigerants legally up to July 4th 2011 in the UK (but not the rest of Europe)
- City & Guilds and CITB are developing new qualifications (C&G 2079 and CITB J11) to meet the new requirements and these are specified in the draft regulations. There will be four different types of qualification depending on the type of work you do. However most engineers are likely to need to take the Category 1 qualification, which will allow you to work on any size equipment throughout Europe.
- There will be around 35,000 people who will need to gain the new F-Gas qualifications, so you can’t afford to wait until 2011 to re-qualify. (The new qualifications named in the legislation are expected to be available in October/November this year).
- If you are running a business you must make sure all of your refrigerant handling staff are qualified, in order to gain your interim company certificate by July 4th 2009. The government hasn’t decided who will issue the certificates yet, but it is considering a basic version of the existing REFCOM company scheme.
- If your company does not have a company certificate, it will not be able to carry out installation, maintenance or servicing work or purchase F-Gas refrigerant after July 4th 2009.
- Failure to meet these legal requirements will lead to the company or individual being fined, and prohibition notices on equipment could be served by the enforcing authorities (these are the local authorities in most cases, but the Environment Agency will be responsible for some sites).
Of course at this stage this is only a consultation exercise. The final legislation will be put in place around February 2009. But the drafts are a clear indication of how the government plans to enforce the Regulatio, so you cannot afford to ignore them.
If you feel strongly about the issues and questions in the consultation you should send your response form back to the Government, as there may be a chance to influence this if sufficient people make the same points – particularly in the areas of how the company registration scheme should operate and whether there should be a national individual register of qualified operatives.
At the moment, the Government is still not convinced it needs to introduce mandatory registration for individuals – such as the ACRIB Card scheme which provides a national searchable database to verify qualifications and a wallet-sized photo identify card for operatives. A demonstration of support for the introduction of such a scheme from industry is going to be necessary if we are to get full enforcement of the training requirements in practice.
You have until October 3rd to make your views known. To make life easier, the Air Conditioning and Refrigeration Industry Board (ACRIB) has issued a sample response letter and a more detailed summary of the new draft legislation at www.acrib.org.uk . You can also phone ACRIB on 0208 647 7033 for more details.
The table opposite summarises the current F-Gas legislation requirements and where you can get more information. The leak testing and refrigerant recording requirements are legal duties of the “operator” which is your customer – they are not the legal duty of the service engineer.
However only qualified service engineers can undertake this work legally. There is still a lot of confusion about who should hold the records of refrigerant use and the format that this should take, but a sample record and guidance is available from F-Gas Support to help operators and contracting companies check that they are meeting their legal obligations properly.
(The information above relates to stationary refrigeration air conditioning and heat pumps – there are separate qualifications being established for those involved in other sectors specified such as Mobile Air Conditioning.)
|F Gas Requirement||When did this come in?||How should this be done?||Need further guidance?|
Operators of equipment must prevent leakage, ensure leak checks are carried out and repair any leaks as soon as possible as well as arranging proper refrigerant recovery Operators must ensure systems are checked for leaks:
· At least annually if more than 3kg charge (hermetically sealed more than 6kg)
· At least once every six months if over 30kg. If they have an automatic leakage detection system they need only be checked every 12 months.
· Automatic leakage detection systems must be installed on applications with 300 kg or more, and these systems should be checked every 6 months.
· If a leak is detected and repaired, a further check must be carried out on the repair site within up to one month to ensure that the repair has been effective.
|4th July 2007|
· Only by qualified personnel (current requirement is City & Guilds 2078 or CITB until 4th July 2011)
· Following the standard leak check procedure set by the Commission.
Penalties are already in place for equipment operators who fail to comply (Statutory Instrument 41 of 2008). Government is now consulting on proposed new qualifications City & Guilds 2079 and CITB J11. The consultation closes 3rd October 2008 and the new legislation is likely to come into force in February 2009. Operatives must have obtained the new qualification by 4th July 2011.
For guidance on current mandatory qualifications see:
The Commission published the leak test procedure as Regulation 1516/ 2007. For guidance see:
Operators must maintain records of refrigerant and leak testing activity in equipment with a charge of 3kg or more. Records to be made available to the competent authority on demand.
Relevant information specifically identifying the separate stationary equipment of applications containing more than 30kg of F Gas must be maintained by the operator.
|4th July 2007|
System records should contain:
· Quantity and type of F-gases installed, added or recovered
· Name of company or technician carrying out servicing
· Dates and results of leakage checks and rectification work carried out.
|DEFRA have produced a sample record sheet at http://www.defra.gov.uk/environment/air-atmos/fgas/pdf/rac-logsheet.pdf|
|· EU sales of non-refillable containers and non-confined direct evaporation systems are prohibited.||4th July 2007||· Equipment cannot be first placed on the market after 4th July 2007 (disposables filled before 4th July 2007 can still be sold)|
Legislation is now in place as Statutory Instrument 2008 No. 41 The Fluorinated Greenhouse Gases Regulation 2008