Extract of speech by Graeme Fox of European contractor’s group AREA, as presented by Marco Buoni at the IIR conference in Rome
In an industry with a liquid workforce, the current provision in the F-Gas Regulation for making sure that companies are registered and certificated is not good enough. What we need to do is set up and enforce an operative register of craftsmen too, to make sure that companies continue to only employ competent craftsmen and that end users only employ properly competent field technicians on their sites. The registers should also be made publicly available on the internet so that end users can easily check that the people turning up on their premises are qualified.
However, AREA does not believe that this measure alone will make the Regulation work as intended, because of a lack of end user awareness that they should ensure only certified personnel work on their systems, and because pre-charged small systems are still available to non-certified companies and personnel. Because of lack of effective policing in Europe, there have been numerous cases of small split air conditioning systems being supplied to non competent people, which frequently risks loss of refrigerant and potential environmental damage.
We believe there is a simple solution to this problem however.
First we need to remember that the legal requirement for installation and service by properly qualified and certificated personnel has no lower charge limit. Some countries seem to have confused this with the limit of 3kg refrigerant charge for annual leak checks. But this limit clearly only applies to leakage checking.
AREA have suggested putting restrictions on the sales network to make sure that only certified people and companies can actually take delivery of the systems. But we were met with complaints that we would be interfering with the manufacturers supply chain. We have suggested that the onus of responsibility be changed from the customer to the supplier as it is easier to check compliance.
And we have suggested that there is a total ban on pre charging the systems. Because by supplying systems without the refrigerant already charged in them it doesn’t matter who buys the product or carries out the basic installation. Non qualified people could, in principle, buy the systems themselves, and do some of the installation but they cannot put the system to work. For this they would need a properly qualified refrigeration craftsman. This craftsman would not charge the system without first checking the leak tightness as required by law, and would then properly evacuate the system to make sure there is no moisture content to cause oxidisation or corrosion. They would then only charge the amount necessary to make the system work efficiently. If there was some catastrophic failure, the minimum amount of refrigerant would be lost to atmosphere.
These simple solutions will help AREA’s member contractors to help the Commission make the F Gas Regulation work.
For full speech see attachment (right)