Legislation - R290

[Huttoftnick]

Hi

I am trying to find out if it against the law to work on a refrigeration circuit which contains R290? I hold no refrigeration qualifications, and would be looking at working on a 3200kg system. Would require to take regular oil samples, would i be allowed under law to do this?

If not, where is the legislation written, or is it only guidance?

Many thanks

Nick

[frank]

Are you joking?

[Huttoftnick]

I am getting grief from my management and I want hard evidence to put in front of them

[charlie patt]

Are you sure about the weight of system as I just want to make sure I'm no where near your site tell your boses to do there own dirty work this is a wind up I pressume

[Huttoftnick]

Unfortunately not, I can assure you the weight of charge is 3188kgs to be exact, we weighed every kilo in. I want a registered refrigeration engineer / firm to look after it, my management have other ideas when it comes to sampling oil, or topping up.

I have just spent three weeks drying the system out, after the said same thought they could fix the plant on their own, and meant we had lub oil contamination with a level of 22k ppm, yes that is 22k ppm.

It took three weeks, with a registered fridge firm, 3 vac pumps, plenty of OFN, eventually achieved 1 torr. New oil charge 1800ltrs, and new r290. Plant is running stable all pressures and temps stable.

I know what f-gas regs said, but my bosses tell me r290 is not a fgas, therefore the law doesn't apply.

[frank]

Your firm appears to be breaking the UK law. Report them to DEFRA

http://www.secop.com/products/compressor-basics/ac-compressors/1-secop-hermetic-reciprocating-compressors/12-refrigerants/124-flammable-refrigerants-r290-and-r600a.html

https://www.gov.uk/guidance/hcfcs-in-refrigeration-and-air-conditioning-equipment

[Huttoftnick]

Thanks, this is also my take on it, but the training side of it refers to fgas.

2079 is required with the HC bolt on, so I need to see it refer to r290 or hydrocarbon, not f-gases. Is that written down anywhere?

Thanks

[frank]

R290 when used as a refrigerant comes under fgas regs as far as I am aware. It has a GWP value of 3

Check out the last page http://www.linde-gas.com/internet.global.lindegas.global/en/images/Guide%20to%20F-gas%20regulations17_130947.pdf

[Huttoftnick]

Thanks, have to find that part now

[Brian_UK]

Yes, as R290 has a GWP of 3 it is included in the f-gas regulations.

With your charge of 3200kg your CO² equivelant is 9600 so you need competent personell to provide the 3 monthly leak checks at the very least.

Obviously anyone working on the system needs also to be competent.

Is this machine secret or can you tell us what it's purpose is?

[cadwaladr]

Who supplied the r290? to you because I suspect they are breaking f gas legislation but there again I could be way off the mark,if you have no certs then I am with Charlie I hope I am not in range of an explosion and hope none of my family and friends are too!

[Huttoftnick]

Yes, as R290 has a GWP of 3 it is included in the f-gas regulations.

With your charge of 3200kg your CO² equivelant is 9600 so you need competent personell to provide the 3 monthly leak checks at the very least.

Obviously anyone working on the system needs also to be competent.

Is this machine secret or can you tell us what it's purpose is?

Brian, many thanks, best pointer yet to show breach of legislation. The machine replaces a r22 one
Nick

[Magoo]

As a starter you should have at least a " Hazardous substance handlers " Certificate. Orica provide that training, along same lines for ammonia and chlorine handlers / operators.

[HVACRsaurus]

Is this machine secret or can you tell us what it's purpose is?

Prolly one of these joints http://www.coolingpost.com/world-news/more-users-given-r22-ban-exemptions/


Could it be they deal with Exatonnes of LPG as part of their process, but converting their chiller R22 to R290 is a can of worms?

[charlie patt]

I'm sorry I can't believe a company with 3200 kilo of flammable gas wants to cut corners on service this system must be the size of north devon if it takes 3200 kilo of 290 if it's on a equivalent 134 404 it would hold double that that's six hundred dumpy bottles to fill it ? This is a ticking time bomb to have unqualified techs working on this kit at this quantity this is not to be played with personally I would look for another job because if they asked you they may ask others and if your within a mile of this kit if it goes up look out

[joe-ice]

As far as i can tell halocarbons dont come under fgas legislation , f gas was designed to phase out hfcs and hcs would be considered as one of the alternative gases to replace them. It gives a vague mention of providing suitable training and awareness courses of alternative gases . I would assume someone working around that much r290 would already have done such awareness training . This is my understanding from the last time i read the fgas regs maybe they have been updated since .

[Grizzly]

Hi Joe
R290. or any other refrigerant.
Does not have to come under F gas to be restricted in its use.
Ammonia or Co2 are good examples.
However they and the use of all other refrigerants is regulated under the European Regulation EN 378.
This the bible as far as we are concerned and ignorance of it is no defence.
I SUGGEST NICK SAVES THESE POSTS!
An equipment owner is ultimately liable when and if things go wrong.

I an off to work now Nick.
When I get back I will try and find the relevant passages.

Basically you are totally correct to question the directives / implied instructions you are receiving!

Grizzly

[cduque]

Hi Grizzly,
I have to disagree with you in one point, EN is not an European Regulation, it is an european norm (or standard), only after being adopted as a Regulation (or a Directive and transposed to the national law) it has the force of law.
I don't know if in UK the EN 387 has been transposed to the national law but in most countries it continues to be a "good practice" to follow, but those who don't follow are not subject to legal persecution (if it has been included in the contract).
The F-Gas Regulation includes several points of the EN 387 but, as the name says, it applies only to fluorinated gases. R-290 doesn't include fluorine, so this legislation is applicable to other fluids.
Of course it doesn't mean that R-290 installations are not subject to regulations, they are, but not Regulation (EU) nº 517/2014.
I believe this is a task more to a lawyer than to an engineer...
Anyway such an installation has to have a licence or legal permit of operation, and on that permit the working, operation and maintenance conditions have to be well defined. It's flammable condition must be it's biggest restriction and condition to use, I think...
:cool:

[Rob White]

.

In the UK we BS (British Standard) all EN numbers and they then become regulations.
So we have BS EN 378 and such which is a UK'd verified version of the EN document.

The trouble in the UK is there is not an actual legal requirement for HC's it was covered with
the old 2078 exam that included HC's, the 2079 only specifically lists HFC's and HCFC's so
there is an inbuilt assumption that anyone who wants to work with R290, R600, R744 or
any of the other natural refrigerants must have a Refrigerant handling qualification.
The refrigerant handling qualification is the 2079 or the (CITB) J11 and they include the
use of HC's.

To work with HC's there is an additional qualification for HC's
To work with C02 there is an additional qualification for C02
and to work with Ammonia you need an Ammonia certificate.

If it goes wrong and you end up stood in front of a Judge in a Courtroom
just hope that your defense is better than the prosecution, because if it goes
wrong the first thing they will want to see is you qualifications to work.

Regards

Rob

.

[Magoo]

Well stated Rob.
If it goes wrong there will not be a lot left to prosecute, apart from a blast zone too big to imagine.

[cadwaladr]

I think this post is untrue,but let's assume it's true ,if I was involved I would be making a few phone calls anonymously first to the fire brigade,the companies insurance company and the hse asap!