F-gases and compliance: What you need to know

Fluorinated greenhouse gases, referred to as F-gases, are a group of chemicals which contain fluorine. The most common F-gases in use within the UK and Europe are HCFs or hydrofluorocarbons. These gases have a number of applications but are mostly used as a refrigerant. This means that they are used in cooling equipment. HFCs are ozone friendly, energy efficient, generally non-flammable and of low toxicity. However, they have a relatively high Global Warming Potential (GWP); contributing to global warming when released into the atmosphere.

The European Union is aiming to reduce the environmental impact of fluorinated gases via regulation. This includes the UK, despite Brexit, which will be discussed further on. The first F-gas regulation EC 842, set in 2006, focused on reducing emissions mostly by preventing leaks in systems, and responsibly destroying older models.

What are HCFs?

HCFs are gases with refrigerant, propellant and foam blowing applications, with zero Ozone Depleting Potential (ODP) and a medium to high GWP. HFCs are the third generation of fluorine-based gases. They are known to offer a more environmentally friendly alternative to CFCs (chlorofluorocarbons)and HCFCs (hydrochlorofluorocarbons). HFCs are used in a wide range of specifically designed refrigeration and air conditioning equipment. They are also used as “drop in” retrofit gases for older CFC or HCFC equipment. HFCs are also used in selective propellant and foam blowing applications.

Why are the regulations important?

With the state of the environment, and a growing knowledge of the destructive impact of humanity’s carbon footprint, there have come calls for refrigeration solutions with a minimal impact on global warming. This has pushed the need for environmentally friendly refrigeration to the top of the corporate sustainability agenda. On top of this, legislation is taking a harder stance on refrigerant gases with high GWP.

What do these changes mean for the future?

Most refrigeration and air-conditioning (RAC) systems used in food and drink manufacturing contain HFC refrigerants. The most common are R-404A, R-134a and R-410A, which have a large impact on global warming when released into the atmosphere. For example, a 1 kg release of R-404A is equivalent to 3922 kg of carbon dioxide.

The EU F-Gas Regulation 517 of 2014 governs the use of F-gases in Europe and the UK and has a significant impact for users of HFCs. Owners of RAC systems in the EU and UK must ensure that their existing systems are compliant with F-gas regulations and that new refrigerants selected for equipment are up to standard.

The Montreal Protocol of 2016 put into place a number of international controls for the use of HFCs. This is to lead to a global phase-down in HFC use. Over the next 17 years, the quantity of HFCs that can be placed on the European market will be cut down by a series of steps. By 2030, only 20% of the quantity of HFCs that were sold in 2015 will be available.

The phase-down is the most crucial aspect of the F-gas regulations and will have a large influence on the use of refrigerants in all markets. This year sees the first major cut in HFC supply of about 40%. There is potential for a significant refrigerant shortage, which could lead to a large price increase in HFC refrigerants.

The phase-down will be based on the GWP of each HFC. As the phase-down progresses, using high GWP HFCs, like R-404A, should be avoided. There is plenty of evidence that the low-GWP alternatives, like ammonia, are prime substitutes and should be used instead.

Who is responsible for compliance?

The most recent legislation across the EU and UK means that all owners of refrigerating and cooling equipment are liable for prosecution if they are not compliant with regulations. All owners are responsible for minimising the emissions of refrigerants. Many industrial and commercial companies do not have the required in-house technical expertise, which makes the reliance on third-party evaluations especially high. Contractors, like Voltix Services, are then necessary to ensure compliance with legislation.

What to do to be compliant?

Operators of relevant equipment should first identify the refrigerating equipment on site. If your equipment does contain HFC or HCFC refrigerants, you must carry out an audit of what equipment is on site, as well as what type and quantity of refrigerant it contains. A qualified refrigeration engineer should be employed if there are none on site.

At existing HFC refrigeration plants, the most important step is to avoid leakage, which will reduce the demand for HFCs. When buying new equipment avoid high GWP refrigerants and, where possible, begin using ultra-low GWP options.

Most importantly you must:

  1. Prevent leakage
  2. Repair leaks as soon as possible
  3. Arrange the appropriate refrigerant recovery during servicing and disposal
  4. Ensure that only certified personnel carry out the servicing, disposal and leakage checks
  5. Maintain records of refrigerants and of servicing
  6. Carry out leak checks as per your schedule

If you are an equipment operator with a legal responsibility under these regulations, you should already be:

  1. Using only certified personnel to work on your HFC and HCFC equipment. This currently means that personnel must have a recognised national refrigerant handling qualification – either a City and Guilds 2078, or CITB equivalent. Updated qualifications are likely to be introduced later this year which will be recognisable throughout Europe.
  2. Checking leaks via an adequate leak check programme. Where leaks are identified, you must take steps to ensure that they have been rectified.
  3. Keeping records for all equipment containing over 3kg of HFC gases.

These records must include:

  1. Quantity and type of F-gases installed, added or recovered.
  2. Identification of the company or technician carrying out servicing and details of the Operator.
  3. Dates and results of leakage checks, specifically identifying separate pieces of equipment containing 30kgs or more of refrigerant.

Operators of equipment containing phase-out refrigerants need to consider alternative HFCs if they wish to continue operating this equipment. This may require replacing equipment or retrofitting equipment with alternative refrigerant. Voltix Services is able to recommend suitable options.

Looking Ahead

As of January 2020, there will be a ban on using new HFCs to service any equipment with refrigerants that have a GWP higher than 2500. This mainly affects R-404A equipment but is also relevant to plants using refrigerants such as R-507, R-434A and R-422D.

There is an exemption for equipment which contains less than 10kgs of R-404A, and for plants that cool a product to below -50°C. If you own equipment that is affected by the service ban you need to make plans based on one of three options:

  1. You can retrofit the existing plant with a GWP refrigerant lower than 2500. As an example, R-404A systems can be retrofitted with R-407F, R-448A or R-449A. This makes very few modifications to the existing plant and there is sufficient evidence that after a well-executed refrigerant retrofit, efficiency will improve.
  2. You can service the existing plant with reclaimed refrigerant. Note that there is no guarantee of availability.
  3. You can replace the entire plant with a new plant that uses a lower GWP refrigerant. It is important to acknowledge that the big phase-down step for 2018 comes two years before the service ban. High GWP refrigerants such as R-404A are likely to become very expensive this year, so retrofitting or replacing this equipment immediately is worth strong consideration.

Penalties for non-compliance

There are serious penalties for non-compliance in the UK. Statutory instruments allow enforcement authorities to serve notices of prohibition and/or enforcement on equipment, if the operator is not within the legal requirements. The prohibition notices will specify action that must be taken. A person found guilty of an offence under the Regulations is liable, on summary conviction in a Magistrates’ Court, to a fine up to the statutory maximum of £5,000, and an unlimited fine on conviction in the Crown Court.

Impact of Brexit

Until the UK leaves the EU in March of next year, organisations will need to be in line with present regulations. After this date, the Repeal Bill of 2017 will seek to convert the existing law into UK law. Effectively this means that F-Gas legislation will stay the same until such time as they are, or are not, changed. The technical aspects of the legislation should remain straightforward, in terms of leak testing, repairs and so forth.

The main issue would be how the UK retains the phasing down of F-gases in the marketplace; the driving force behind the current EU F-Gas regulations. However, this is something that the UK is currently looking at, as production and import quotas are set and monitored at EU level.

The UK is a signatory to the Montreal Protocol, and adopted the ‘Kigali Amendment’ in 2016, which creates new international controls on HFCs. It also introduces the global phase-down in HFC production and consumption. It is reasonable to assume that the regulations for the EU will continue for the UK as they stand currently. A final position is unlikely until the Brexit negotiations are well underway.

Voltix Services is an F-Gas registered company and we are committed to ensuring a safer future for the environment through the proper installation, servicing and management of gases. We handle gas safety and compliance with the utmost respect and have a team of Gas Safe registered experts ready to assist with all refrigerant gas needs. As has been outlined above, the UK and the EU are taking the future of F-gas usage very seriously, and compliance is already a critical issue. Contact our experts today and allow us to help ensure that you are exempt from liability as the phase-down continues.





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