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Legal Obligations for Checking F-Gas Equipment for Leaks
Posted by: Richard Firth on: 6 July 2021
Businesses using stationary refrigeration, air conditioning and heat pump (RAC) systems are under legal requirement to acquire F gas certification. F gas is short for fluorinated gas and the equipment used for the functions listed above can some of the largest sources of greenhouse gases. The specific used in RAC systems include hydrofluorocarbons (HFCs)and perflurocarbons (PFCs). Examples of these gases include HFC 23, HFC 134a, HFC 152a, PFC 218, R 218 and Refrigerant 218.
It is important that the operator of one of these machines go through the appropriate legal steps in order to ensure safe installation, usage and elimination of F gases. Current F gas certification is required, but the government also requires active leak checks. The operator is typically defined as the owner of the equipment and oversees the technical functioning of the equipment, unless these privileges have been transferred to someone else. Some of these functions include the day-to-day running or function of the machinery, supervision of its components and the ability to modify the technology or the F gas quantity coming from the machine. Someone renting this equipment may not have autonomy over the equipment the same way an operator would, but they may also be responsible for leak checks, depending on the rental agreement. Operators are under legal obligation to prevent leakages and check for leaks regularly. Stopping leaks is the responsibility of both the user of the machinery and the technicians who install, repair and eventually eliminate the equipment. This is to prevent any disproportionate costs that would be shouldered by the business. Discovered leaks should be repaired as soon as possible, and checking for leaks will require certified personnel and is dependent on the type of system and CO2 equivalent of the F gas refrigerant being used.
Depending on the amount of F gas in the machinery and its global warming potential (GWP), leaks should be checked for at least once every 3-12 months. If the machine contains less than five tonnes of CO2 equivalent, then there is no need to check for leaks; anything between five to less than 10 tonnes should be checked every 12 months, unless the machine is hermetically sealed. If it is sealed, then there is no need to check for leaks as well. Machines containing 10 to less than 50 tonnes of CO2 equivalent should be checked every 12 months; 50 to 500 tonnes checked every 6 months; and more than 500 tonnes should be checked every three months. Calculation of the CO2 equivalent can be done using online calculators that take into account the quantity of F gases in the equipment and the GWP of the F gases in the system. As of 1 January 2017, any business using equipment that contains less than 3 kg of F gas or is hermetically sealed and contains less than 6 kg of F gas has to be leak tested if the CO2 equivalent is greater than 5 tonnes. Automatic leak-monitoring technology can be added to the machinery in question in order to extend the time between leak checks. By using automatic leak-monitoring technology, the period between leak checks doubles. This technology must be fitted to equipment with a containment charge of less than 500 tonnes of equivalent CO2 and must be checked every 6 months.
Records on all systems using F gases should be meticulously kept and organized. These records should include the amount and type of F gas being used in a certain machine, a calculation of the equipment charge based on the CO2 equivalent in terms of tonnes, the personnel responsible for maintaining and servicing the device and the results of every leak check, including the date the machinery was checked. Both the business using the equipment and the business responsible for servicing the equipment are required to have copies of these records.
Both f-gas engineers and the company involved need to be signed off in order to proceed with installation, service and maintenance of the machine containing F gas. Engineers will need certain certificates before being allowed to operate with F gas-containing machinery, and these include a City and Guilds FGAS and ODS Regulations Certificate, CITB Refrigeration Certificate or an acceptable equivalent. Business owners should make note of the certificate numbers of their engineers in order to have proof that they have enough personnel to provide F gas services. There is no need for the person physically delivering the F gases to be qualified, unless they are the same person performing the installation and maintenance work.
As of 31 October 2019, action is needed for businesses operating within the Republic of Ireland and have certificates to work with F gases or other ozone depleting substances. The Irish government has been working with businesses and employees to attain equivalent certificates that can be used in accordance with Rol. This process is completely free of charge.
Once business owners have done this, they should submit written evidence of the company’s F gas handling procedures and any equipment they may use to minimize emissions during work. With these documents, a foundation for F gas certification can be made and audited at any point in time. Renewal for F gas certification is available every three years.
Businesses that specialize in the installation, repair and maintenance of F gas containing products must have the relevant certification before being allowed to work. Within the United Kingdom, the designated certification bodies include Refcom, Quidos and Bureau Vitas. In order to receive company certification, the company must be able to demonstrate that the workers involved with F gas machinery are adequately trained and competent. This includes having the proper equipment and procedures available and having enough personnel to carry out the work involved.
For businesses that import, export, reclaim or produce more than one tonne of F gas per year, they must send a report to the European Environment Agency. For those in Northern Ireland, they must send an additional report to the Northern Ireland Environmental Agency; those based in Scotland should send an additional report to Defra. Report submission to the European Environment Agency can be done online.
If F gas is removed from any system, it should be properly recovered by the proper personnel during servicing and decommissioning. The F gas recovered should be disposed of correctly and not recycled or reclaimed. Non-refillable containers and storing of F gases is strictly banned, and it is illegal to place non-refillable containers on the market, unless it was manufactured before 4 July 2007. If a leak is found, it must be repaired immediately and only if technically feasible. Repeat testing is should be to see if the repair was adequate enough to stop the leak.
All F gas utilizing equipment should be labelled appropriately. This label should be visible and easy to interpret, and should ideally be placed close to a service point. The label should include the equipment that contains F gases, which F gas is being used and the charge size. As of 1 January 2017, the label should also include the CO2 equivalent of charge and the GWP of the gas contained.
Other alternatives to F gas are available, but these gases do have restrictions of their own that may need to be considered. Some things to take into consideration include the overall environmental impact, energy efficiency and factors related to health and safety. Alternative refrigerants include ammonia, carbon dioxide and hydrocarbons like butane and propane. As F gases are being phased out for these alternatives, they will become less available on the market.