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The difficulty of adapting to new regulations

New rules from the start of 2015 have replaced current requirements covering F-gases. The biggest shift has been around maintenance schedules.

Regulation (EU) 517/2014 has revoked and replaced F-gas Regulation (EC) 842/2006, with the main change amending the thresholds for maintenance frequency. Previously, the criteria was based on the charge in kg of F-gas in an item of equipment, but this will now be based on the global warming potential (GWP) CO2 weight equivalent of the F-gas.

This has seen some equipment no longer requiring maintenance under certain circumstances, while others will require even more attention.

The Regulation has seen bans and restrictions of the use of F-gases in some refrigeration equipment, air conditioners, insulating forms and technical aerosols – among other new equipment – while there have also been changes to conditions on marketing products and equipment containing or relying on F-gases.

Other changes include a cap and phase-down for the placing on the market of HFCs, restrictions on the servicing and maintenance of equipment using the substance and rules regarding their containment, use, recovery and destruction.

Ensuring that existing maintenance schedules are still correct to identify any equipment that was not previously covered but is now is a good first step to dealing with the changes. A fully up to date F-gas register is necessary, listing all the equipment and systems containing F-gases that need to be checked for leaks.

The 3kg, 30kg, and 300kg leak check requirements have been replaced by different limits based on CO2 equivalent tonnes. The new requirements are for 5, 50 and 500 CO2 equivalent tonnes.

Companies have been advised to ensure all gas contents are identified, and where it is confirmed as an “R” code refrigerant, the actual chemical component needs to be noted – but firms need to bear in mind that the gas could be a blended gas. Having identified all the gases, businesses must consult Annex 1 and 2 of the Regulation for the calculations necessary to determine the GWP of the gas in question.

The aim of the new Regulation is to reduce F-gas emissions by around 80% of today’s levels by 2030 through encouraging the use of viable and climate-friendly alternatives where they are available. This may sound quite ambitious, but it is more than achievable when you consider such alternatives are already available for much of the equipment that currently uses F-gases.

The extension of the measures for regular leak checks have also been affected. Now their frequency will be based on GWP in CO2 equivalents, rather than tonnes of F-gas. This has brought more equipment into the leak checking regime, which is designed to encourage a switch to lower GWP alternatives.

The nature of determining the GWP of an F-gas can be highly technical, something that becomes increasingly complex when you have to factor in gas composition and blends.

Neil Howe is senior legal author with online environment and safety specialist Cedrec

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