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gwilliamson
30-07-2006, 12:26 PM
Whats the official line on R22. I know the sale of r22 units is not allowed in this country but what about the gas? Can we top up or re charge r22 machines with r22 or is there a drop in replacement?I am sure i've read all about this but cant remember for the life of me?
Thanks

Argus
30-07-2006, 01:21 PM
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No - not yet, but you need to do a little reading to understand the answer to your question.

The laws on HCFCs (R22 etc) are contained in The EU ODS Regulations, 2037 / 2000.
Read it here.
www.europa.eu.int/eur-lex/pri/en/oj/dat/2000/l_244/l_24420000929en00010024.pdf

You need to read the words carefully to understand what they say, not what you think they say.

The penalties and offences are laid out in a UK SI, 2002 / 528.
http://www.opsi.gov.uk/si/si2002/20020528.htm

Article 5 in 2037 / 2000 deals with HCFCs alone.
What you are referring to is the ?use? of R22, so go to Article 2 and read the definition of the word ?use? as it applies to this regulation.

It is not the sale of equipment that is banned ? it is the ?use? of HCFCs (R22 in this case) in equipment that is banned. There is a difference.

The regulation gives a series of dates where the use in equipment is banned and these dates are the manufacture times.
Therefore, for heat pumps for example, it is illegal to use R22 in a unit made on 1 January 2004; if you can prove that it was manufactured on or before December 31st, 2003 it is legal for sale.
This is in Article 5, - 1 ? ( c ) ? (iv).

Read on to the next paragraph, (v).It tells you that you can ?use? new or virgin HCFCs for service until the last day of 2009. After that you can continue to ?use? reclaimed HCFCs (either by you or someone else) until the last day of 2014. Thereafter they are illegal as refrigerants ? in the same way that R12 is now. The rules will be the same.

Go back to Article 2 and read the definitions of ?recovery?, ?recycling? and ?reclamation?.

That?s the good news. Now read the next paragraph. I?ll quote it here:

Before 31 December 2008 the Commission shall review
the technical and economic availability of alternatives to
recycled hydrochlorofluorocarbons.

Later in this section it goes on to say:

The Commission shall submit the result of the review
to the European Parliament and to the Council. It shall,
as appropriate, in accordance with the procedure
referred to in Article 18(2), take a decision on whether
to adapt the date of 1 January 2015;


As I see it that means that they will review the dates for the ?use? of refrigerant for service. The committee is working on this now, so expect those dates above to change.

As well as this I would consider and expect the price of HCFCs to rise drastically, because there are less quantities being released to the market, - elsewhere in the regulation are rules for the chemical producers to reduce thieir production, so add to that the laws of supply and demand.

I hope that this answers your question.
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gwilliamson
30-07-2006, 02:48 PM
wow...Many thanks.

mick2me
30-07-2006, 07:00 PM
Thats a pretty good interpretation of the regs, Are you sure your not in Law Argus?:rolleyes:

Argus
30-07-2006, 07:51 PM
.

Thank you, but nope, I just read the words.

I am a technical writer and trainer, but I began with a brush in one hand and a tea pot in the other before I picked up a set of gauges and a bottle of gas.


Old school training.


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mick2me
30-07-2006, 08:17 PM
.

Thank you, but nope, I just read the words.

I am a technical writer and trainer, but I began with a brush in one hand and a tea pot in the other before I picked up a set of gauges and a bottle of gas.


Old school training.
.

The problem with UK Regs about anything, is that the take some interpretation. Thats because they are written by lawyers, so that only lawyers can interpret them?

Argus
30-07-2006, 08:38 PM
The problem with UK Regs about anything, is that the take some interpretation. Thats because they are written by lawyers, so that only lawyers can interpret them?



The interpretation part will be done by the courts if it ever gets that far - that's what they are for.

Just clear your brain of pre-conceptions and read the words one at a time.

If you speak English, and know the A/C trade you have the same advantage as me. Plus, you have the advantage on the lawyers because they don't know anything about our business.

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