Hydrocarbons - is it law to recover them?

[topfridgeman]

Can anyone say for certain that it is illegal to blow off hydrocarbon refrigerants?

[nevgee]

Try this for size ........

"In a recent development in the debate on the interpretation of the WEEE directive regarding the proper treatment of refrigeration equipment containing hydrocarbons, an EU Environment Commissioner has verified that there is an unequivocal obligation to remove liquid hydrocarbons such as cyclopentane from end-of-life fridges and freezers. In the opinion of the Commissioner Mr. Stavros Dimas "the term "removal of all fluids" makes it clear that not only the gases mentioned in annex II, no. 2 are to be extracted from refrigeration equipment, but also any kind of liquid contained in the cooling circuits or insulation materials. This would apply even if a fluid was not mentioned in the list of substances under Annex no. 1." According to the Commissioner, there is therefore an "clear obligation to remove liquid hydrocarbons, such as cyclopentane, from fridges and freezers." For more information see: http://www.ral-online.org/html_engl/detail.php?id=179

I think the answer is a definate "yes" to your question ...sorry!

[Argus]

.



WEEE (Waste Electrical and Electronic Equipment) is primarily end-of-life legislation and the commissioner’s interpretation filled a gap of understanding on the disposal of HC based foams and material in small fridges and the like when they are scrapped.

The issue of waste HCs from working refrigeration equipment, large and small is dealt with in the UK Hazardous Waste Regulations, where ALL waste refrigerants are considered Hazardous Waste.

In these HW laws, HCs used as refrigerants are considered waste industrial solvents and disposed of accordingly – simple as that.

So the answer is yes, in both existing and disposed equipment.

Besides, HCs have a tendency to hang around in low lying spots, and the fire service will take a very dim view of people letting off potentially flammable mixtures willy-nilly, even small amounts outdoors.

They'll wipe the floor with you if they see you at it.



.

[topfridgeman]

Thanks very much. That is very interesting. Stavros Dimas of the EU said in his letter regarding hydrocarbon recovery:

"I would like to stress that the following remarks only reflect the opinion of the Commission services and are not legally binding. A legal interpretation of Community legislation is, under the Treaty, the exclusive competence of the European Court of Justice."


I haven't found any EU legislation as yet.

So it's the The Hazardous Waste (England and Wales)Regulations 2005 that seem to be the binding document.

I still haven't found it written that hydrocarbons must be recovered though, merely that you should ensure safe management of them. I know that sounds picky, but I hate it when people say to deal with it something properly, but then don't say what properly is. For example, it is arguably safe management to blow HC's off.

Does HRP receive hydrocarbons for disposal?

[Argus]

…………… Stavros Dimas of the EU said in his letter regarding hydrocarbon recovery:

"I would like to stress that the following remarks only reflect the opinion of the Commission services and are not legally binding. A legal interpretation of Community legislation is, under the Treaty, the exclusive competence of the European Court of Justice."

[SIZE=2]
I haven't found any EU legislation as yet.




It could take some time to decide and in the scheme of things, is small beer in the EU courts.
It is important that the commission has given an opinion as this sets a precedent, the courts will decide if a change is needed to the Directive. But I should stress again that this referred to an interpretation of WEEE, not Hazardous Waste, which has its own directive that is harmonised in UK law as the Hazardous Waste Regulations.


I suggested that you consider them as waste industrial solvents, which are the views, I believe, that the Environment Agency will take.
There is some detail on the classification of waste substances in the list of hazardous waste that accompanies the HW regulations that you have already found.

2005 No. 895 The List of Wastes (England) Regulations 2005

You need to read the two together.



For example, it is arguably safe management to blow HC's off.

Does HRP receive hydrocarbons for disposal?

There is a strong argument to suggest that it is not safe or legal to expel waste flammable material of any kind to the atmosphere. It depends on whether you want to take the risk.

You also need to consider the Health & Safety practices in your own company and the premises where you are working. HCs have a tendency to collect in low lying areas.

What’s been considered acceptable practice since time immemorial doesn’t mean that it’s acceptable or legal now.

I don’t know about HRP taking back waste, you’ll have to ask them what their policy is.
I believe that you will get a more definitive answer from BOC.
ACRIB also have some guidance on the subject on their website.

The technique of recovery is the same as you would use for other refrigerants, making allowances for the hazards of the material and the equipment needed.


.