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Leo1967
22-04-2009, 09:10 PM
Hi everyone,hope someone could help with this,the legal aspect of retrofitting.
In Italy it's so confusing nobody knows exactly what the rules are.......you can ask the authorities or whoever you want and everybody will give you a different version of things,obviously not in writing!
What is the maximum quantity of refrigerant you're allowed to transport inside a normal van with a normal driving licence?
I even heard that if you retrofit a unit,the old refrigerant (R22) should not be treated as refrigerant but as a special kind of dangerous waste,not as dangerous as asbestos but under the same safety regulations!!!Does that sound like italian bureaucracy or what???
I'll have to retrofit many units of various sizes around Italy and i was concerned about this as i knew we were allowed a max of 300kg of gas class 2.2 (not toxic and non flammable).
i thank you in advance bye

R1976
22-04-2009, 09:34 PM
Don't know about Italia but your in the EU so I suppose its all the same.

Here in the UK each company has to regisrer and pay the governments environment agency each year to be a registered carrier of hazardous waste for recovered refrigerants.

We also have to have refrigerant handling qualifications as a minimum to work with the refrigerants.

Fines can be imposed if this is not in place but I have never heard of anyone actually being prosecuted and the law is broken every day.

Abe
23-04-2009, 09:25 AM
Argus ( Moderator) is the specialist in this area, we await his response.

Leo1967
26-04-2009, 05:48 PM
thanks for your prompt reply and sorry for my late reply,needless to say i was so busy!!!
Down to business...according to EU law you can carry up to 300 kg of refrigerant in its original package (bottles or whatever) without the need of special licences or training.You should however carry a fire extinguisher(at least 2 kg).the bottles should be placed in an upright position and secured,they should be labeled and in the transport documents you should declare that what you carry is below the limit of the amount allowed .

now then,with used refrigerant here in Italy there's total caos as we (the State) didn't apply all the rules within the EU law.We asked companies who specialise in waste transport and off course they said we can only transport 30 kg so we should buy their services (i'm sure it'll be a billion euros per gram per km)
The problem we have isn't the handling as we're trained,it's the transport as special licenses and special vehicles are required(this according to someone)

Anyway if someone comes across some literature or web-sites can you please let me know? thanks

BTW Roma lost to Fiorentina 4-1 that should be illegal by EU law!!!

Peter_1
26-04-2009, 10:19 PM
In EN378-2008, this is described but every country can have more stringent rules.
But you also have the ADR rules.

Part 1, Paragraph 1.1.3.1 c. states that you may carry as an enterprise which is ancillary to their main activity;...., repairs and maintenance..in quantities of not more than 450 liters per packaging(!!) and you may carry several packages.

You may carry them in any position, '1.1.3.1 f. The load is fixed in cradles or other handling devices or to the vehicle or container in such a way that they will not become loose or shift during normal conditions of carriage"
Fuel must be carried upright.

Argus
27-04-2009, 08:49 AM
.............In Italy it's so confusing nobody knows exactly what the rules are.......you can ask the authorities or whoever you want and everybody will give you a different version of things,obviously not in writing!
What is the maximum quantity of refrigerant you're allowed to transport inside a normal van with a normal driving licence?



I can't comment on transport rules - not my field - but there are EU rules (ADR) that Peter has outlined. I think that this applies in the main to large bulk quantities, I.E. trucks. National rules may apply for small quantities in service vans, which is what the question seemed to be about.

In all EU legislation, the main parts are in the Directive which take precedence but require national Governments to transpose in to their own laws.





.....I even heard that if you retrofit a unit,the old refrigerant (R22) should not be treated as refrigerant but as a special kind of dangerous waste,not as dangerous as asbestos but under the same safety regulations!!!Does that sound like italian bureaucracy or what???
I'll have to retrofit many units of various sizes around Italy and i was concerned about this as i knew we were allowed a max of 300kg of gas class 2.2 (not toxic and non flammable).
i thank you in advance bye

The EU enacted a Directive some years ago on Hazardous Waste, its disposal and transport. They also made a list of hazardous waste substances and processes. You will be able to access a copy of this in Italian from Europa’s web site.

This will have been transposed into Italian law - no question - and it means that there will be rules on the disposal and transport of all wastes; the exact legal details and enforcement with penalties may vary from country to country, but they will exist.

The main part of the question though was about R22.

Apart from the fact that it’s being phased out within the ODS regulations (also affecting Italy), Within the EU, any quantity of any type of refrigerant that is removed from any system is Hazardous Waste, as is the oil. This also applies to HCs which are (in the Hazardous Waste List) classed as ‘Industrial Solvents’. This will also extend to insulation foams if they are blown with a hazardous waste substance.

I guess that you need to go back and read up on the Italian laws.

.

NoNickName
27-04-2009, 09:48 AM
Actually, there juridical status of the refrigerant, when pulled from a system, changes. It becomes toxic and dangerous waste, and as such only a proper waste-handling company can transport it.
Remember you can carry R22 in, but not out.

Peter: EN378 is not a directive, and as such it may or may not be enforced by European or National regulations. In fact, here there are more stringent safety codes now in force, and the total amount of refrigerant that can be transported varies from company to company and from vehicle to vehicle, depending on italian ATP/ADR approval.
They are quite fussy now, because of an accident happened to a refrigeration engineer some time ago, who loaded 4 or 5 cylinders of ammonia in the back of its truck. Unfortunately he didn't realise he filled the cylinders up to the rim, and as soon as he closed the door everything blew up to smithereens. He died in the accident.

Leo1967
27-04-2009, 10:36 AM
Peter: EN378 is not a directive, and as such it may or may not be enforced by European or National regulations. In fact, here there are more stringent safety codes now in force, and the total amount of refrigerant that can be transported varies from company to company and from vehicle to vehicle, depending on italian ATP/ADR approval...........

first of all thak you all for your time and effort........

Nonickname,this is exactly what i meant,if you ask the health authorities (asl) or municipal police (vigili urbani) or whoever they'll give you a different answer as how much reclaimed gas you're able to transport.I know now in administration they're signing a contract with a specialised company but still i would like to know as if i'll have to retrofit say a small machine it would seem silly to call someone to collect a couple of kgs of r22!

Thank you again

Leo1967
27-04-2009, 10:39 AM
by the way nonickname,i didn't hear about that accident,where did it happen?and where can i read about it? thanks

Peter_1
27-04-2009, 11:56 AM
Every country implemented the EN378 in national laws which becomes then compulsory.
Most countries didn't change that much about its content.

As far as I know, the ADR is European regulated and there can not be differences between the countries.

NH3 and HFK are also something completely different for ADR.

NoNickName
27-04-2009, 12:36 PM
by the way nonickname,i didn't hear about that accident,where did it happen?and where can i read about it? thanks

http://www.la7.it/news/dettaglio_video.asp?id_video=7854&cat=cronaca


Every country implemented the EN378 in national laws which becomes then compulsory.
Most countries didn't change that much about its content.


Enough said that some parts of PED directive are in contrast with EN378. When that happens, I always follows PED, because PED is law, EN378 is not.

Leo, you have to ask to the fire dept. of your city and the chamber of commerce.
If you don't have a suitable answer, contact http://www.frigoristiclub.com/ or http://www.assofrigoristi.it/