The refrigerant R22 is one of many currently in use in refrigeration and Air Conditioning equipment which is classified as an Ozone Depleting Substance (also known as an HCFC refrigerant), and which comes under the EU ODS Regulations. These regulations were recently revised and additional obligations have been placed on owners regarding leak checking, record keeping and labelling.
In addition the Commission has provided some definitions related to the recovery and reuse of ODS refrigerants in stationary RAC and heat pump equipment. These are summarised below.
CONTINUED USE OF HCFC’s
The phase out dates remain unchanged:
From 1st January 2010 it is illegal to use virgin HCFCs to service RAC equipment. This ban applies even if HCFC was purchased before the ban date. It is illegal to stockpile and use any supplies of virgin HCFCs after the end of 2009.
From 1st January 2015 it will be illegal to use recycled or reclaimed HCFCs to service RAC equipment.
Note: these bans refer to the “use” of HCFCs for servicing and maintenance. Customers can continue using RAC equipment containing HCFCs beyond the phase out dates provided that no additions of refrigerant are required.
Any company anticipating using reclaimed HCFCs to maintain systems after the end of 2009 should contact their refrigeration supplier to discuss how to meet the anticipated demand. Due to the impending deadline on the use of virgin HCFCs, suppliers are likely to run-down their stocks of virgin gases before the actual deadline, so stocks may become limited before the end of December 2009.
RECLAIMED OR RECYCLED?
The new legislation includes an important distinction between “recycled” and “reclaimed” gases.
Recycled HCFCs are recovered HCFC that has been subject only to a basic cleaning process (this might include mechanical filtering and moisture removal). Recycled HCFCs may only be used by either the undertaking which carried out the recovery (in most cases the refrigeration contractor) or the undertaking for which the recovery was carried out (the owner). Recycled HCFCs may not be placed on the market – “placing on the market” means the supplying or making available to third persons within the Community for payment or free of charge. For example, the owner could use the recycled. HCFC in RAC equipment at other sites they operate from but they cannot sell recycled HCFC to a third party.
Reclaimed HCFCs are recovered HCFC gas that has been chemically reprocessed to a specified standard. Reclaimed HCFCs may be placed on the wider market and used by undertakings other than the original contractor and owner. Reclaimed HCFCs must be held in containers labeled as such, with information on the batch number and name and address of the reclamation facility. Reclaimed material has been reprocessed to a specified quality that is suitable for use in a refrigeration system whereas recycled material is of an unknown quality – it might contain contaminants that could impair the performance of a refrigeration plant.
Labelling of equipment using recycled or reclaimed HCFC
Where recycled or reclaimed HCFCs are used, the RAC equipment must be labelled to show:
The quantity and type of recycled/reclaimed HCFC added in the system, and
Other label elements set out in Annex I to Regulation EC/1272/2008
SUMMARY OF OTHER NEW REQUIREMENTS
Leak testing and rectification
These new operator (or equipment end user) obligations are broadly similar to those of the EC F gas Regulation:
to prevent and minimise any leakages and emissions of controlled substances.
to carry out the new leak testing requirements as in the table below:
Storage for recycling or reclamation
Before you recover HCFC refrigerant for recycling or reclamation you should consider the following points if the owner intends to store the materials on site:
The holder should ensure that cylinders used to store recovered/recycled HCFCs remain within their statutory pressure test validation period.
Recovered HCFCs pending recycling or reclamation are hazardous waste subject to the Hazardous Waste Regulations. Facilities storing recovered HCFCs must register with the Environment Agency as an exempt waste operation. Storage of recycled or reclaimed HCFCs does not require a permit.
System record keeping
Users of equipment containing over 3 kg of HCFC refrigerant must keep a record of the quantity and type of any gases removed or added, and of the company or technician carrying out the service or maintenance.
Undertakings using recycled or reclaimed HCFCs for service or maintenance must keep records of the undertakings which supplied the reclaimed gases and the sources of recycled gases.
WHERE TO GET MORE INFORMATION
Further advice on HCFC phase out strategies, solutions and decision criteria are available in the full information sheet “RAC 8—R22 Phase out” available from F Gas support. Additional leaflets on all aspects of the F Gas (HFC) and ODS (HCFC) Regulations are available at www.defra.gov.uk/fgas.
F Gas Support – UK Government have set up a free helpline to deal with individual queries about the F Gas Regulations and to provide a central resource for information, particularly for end users but also for anyone else affected by the F Gas or ODS Regulations. The following contact points are now in operation: