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3kg threshold confusing F-gas compliance

Companies are failing to gain full certification in compliance with the F-Gas Regulations due to confusion over the 3kg threshold.

According to certification body Refcom, employers working with refrigerants mistakenly believe that they do not need to hold a full company certificate if they work only on small systems below the 3kg limit. As a result, they are not applying for full certification in compliance with the F-Gas Regulations, despite the deadline for full certification having passed on 4th July. 

Refcom secretary Steve Crocker said: “This is a serious misconception that needs to be clarified. The bottom line is that the 3kg limit is only applicable to leak checking. A company undertaking installation, servicing or maintenance on stationary RAC equipment containing or designed to contain F-Gases (less than 3kg or not) must hold a company certificate. Failure to do so is a breach of the F-Gas Regulations. It’s that simple.”

Businesses need a Company Certificate if they employ personnel to undertake installation, servicing or maintenance on stationary RAC equipment that contains or is designed to contain F-Gases, regardless of the equipment’s system charge.

If personnel undertake installation, servicing or maintenance activities on RAC equipment (containing less than 3kg of F-Gas), the individual needs to hold a minimum of a category II qualification. The higher Category I qualification would also cover them for this work.

A category III qualification is not sufficient for any service and maintenance work on equipment and only enables the holder to undertake recovery activities on RAC equipment. A category IV qualification only enables the holder to undertake non-invasive leak checking activities on any size of system.

Mike Creamer, managing director at training company Business Edge, says: “With the passing of the July deadline, the heat is on for those who’ve missed the bus and aren’t qualified to handle refrigerant.

“Some could be in great difficulty over this. Let’s make it clear, they are technically breaking the law by trading illegally. We’ve been receiving calls every day from companies who realise this and now understand why they have to become F-Gas compliant.

“The wider picture is very interesting. Will wholesalers now refuse to sell refrigerant to those who haven’t F-Gas Certification? If they do, could this lead to a shortage of people in the industry able to work.

“Will systems requiring service and repair suffer downtime? Is the end user aware there could be a problem here? There are many unanswered questions.”

A Company Certificate is not required if only recovery work or leak checking activities are undertaken or “to any manufacturing and repairing activity undertaken at manufacturers’ sites for stationary refrigeration, air conditioning or heat pump equipment containing fluorinated greenhouse gases.” 

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