New guidelines help please....

[welsh__boy]

Hi,
I'm the service manager for a smallish engineering firm in South Wales. I'll say right away that I don't work directly on the refrigerant side of our work but have boys in my team that do.
A number of our engineers have recently gained the City and Guilds 2078 qualification and have informed me that the way we work on refrigeration is going to be more costly than before because of the guidelines which means more time will be spent on each job. Obviously we need to inform our customers of the reasons for the increased costs but I am finding it difficult to find any relevant literature on the internet with precise guidelines to pass on to our customers. For example, as I understand it, if one of my engineers finds a leak, he is now duty bound to find the leak and repair it, which involves the reclamation of the gas from the system, purging the system with oxygen free nitrogen, repairing the leak and then regassing the system. These extra costs will come as a shock to most customers so I was wondering if you could guide me in the right direction so I can prepare a document for our customers which is easy for them to understand, but which clearly states the legal guidelines and the implications if the work is not carried out.

Many thanks for you help (I hope!!)
Chris

[Abe]

Hi,
I'm the service manager for a smallish engineering firm in South Wales. I'll say right away that I don't work directly on the refrigerant side of our work but have boys in my team that do.
A number of our engineers have recently gained the City and Guilds 2078 qualification and have informed me that the way we work on refrigeration is going to be more costly than before because of the guidelines which means more time will be spent on each job. Obviously we need to inform our customers of the reasons for the increased costs but I am finding it difficult to find any relevant literature on the internet with precise guidelines to pass on to our customers. For example, as I understand it, if one of my engineers finds a leak, he is now duty bound to find the leak and repair it, which involves the reclamation of the gas from the system, purging the system with oxygen free nitrogen, repairing the leak and then regassing the system. These extra costs will come as a shock to most customers so I was wondering if you could guide me in the right direction so I can prepare a document for our customers which is easy for them to understand, but which clearly states the legal guidelines and the implications if the work is not carried out.

Many thanks for you help (I hope!!)
Chris


Chris

If you browse the threads under the Legal / Business Banner, also under the Refrigerants head, you will come across a wealth of information regarding these issues.

Then its a matter of collating in your own document which you can draft according to your business requirement/ needs

Good luck

[Argus]

Chris,

Abe is right there are several posts in the Legal section, and it?s worth a dig around.

But let?s look at your problem in a bit more detail. You are spot on getting your operatives qualified with C&G 2078 this is now a legal requirement in the UK for persons handling refrigerants - and so are they when they told you about repairs. The regulations insist on repairs done as soon as is practicable. By this they mean as soon as it can be done.
If you can do it now - now is when you do it. Not on Monday morning because you will be paying overtime on a Saturday, for example. Otherwise it is expected that the leaking part is on the system is isolated so that it cannot leak, until the repair is carried out. Further, for HFCs, the repair itself must be tested separately within one month, and whilst not laid down for HCFCs, it?s best practice.

I?m assuming that you are concerned with Fluorocarbons, not Hydrocarbons and certainly not Ammonia ? these latter two have their own safety rules.

You did not mention what type of equipment, fixed, mobile etc.
There are indeed new rules in law that will probably affect you. Also, as you are reclaiming refrigerant you must consider the new Hazardous Waste regulations because you may now a producer of waste. Get your company registered, if you aren't already.

I would suggest that you look at your operation across the various regulations and carry out a compliance analysis. This will help you to draw up information for your customers and better still enable record keeping, because all HFC equipment over 3 kg must now be regularly checked for leaks and have a log book.

.
________
Mercedes-Benz W136 (http://www.mercedes-wiki.com/wiki/Mercedes-Benz_W136)

[welsh__boy]

Hi Argus and Abe, thank you for the replies.

I should start this by saying we deal mainly with R134a, 404, and Isceon 49. We work on fixed commercial refrigeration, for example fridges, freezers, walk-in cold rooms, displays etc.

Just want to clarify a couple of things, firstly, if a leak is found and the engineer tells the customer it needs to be repaired immediately, but the customer refuses because of the costs involved, where do we stand? For example, if one of our Corgi guys found a gas leak on a gas appliance, he is duty bound to either repair the appliance or isolate it, no questions asked. Does the same apply for refrigeration?

Secondly, I recently registered with the environmental agency for our waste handling, it was my understanding after speaking the the environmental agency over the telephone that this would cover us for reclaiming the gases, but after reading some posts, it appears that I need to register the company to reclaim refrigerants from various sites.

Lastly, even though the information on this site is very helpful, informative and in most cases essential, what I'm trying to find are the actual guidelines to quote to the customer for reference. I have tried ACRIB's site, many pages on the governments sites, all appear vague. Don't get me wrong, we're not trying to bend the laws in any way, if it's a legal requirement then so be it, but we need to justify the costs with our customers, and believe me, some will question any increase and want a full explaination.

Again, many thanks in advance,
Chris

[Argus]

Firstly, all the refrigerants you mention are HFCs. You and your customers will be governed by the new F Gas regulation EC 2006 / 824.

(If you encounter R22, (an HCFC) you need to be familiar with EC 2000 / 2037, separate legislation.)

When you get the new regulation, read Article 3, that outline?s the ?operator?s? responsibility. Then you draw your customer?s attention to it.

It is his legal responsibility to:

?(a) prevent leakage of these gases; and
(b) as soon as possible repair any detected leakage?.

There it is, in law.

Within the next year, the UK govt will draw up separate UK legislation that will define the offences and penalties under this Regulation.

The legislation doesn?t go as far as telling you what to do in these circumstances? it never does. DEFRA may provide a guidance document when the UK SI comes out, but they are not bound to.

Corgi registered engineers act to isolate dangerous leaks because that is what it says in the gas safety legislation. I don?t think you have the legal powers to do the same for HFCs, but you should certainly put it in writing ASAP and withdraw your services if the customer refuses the repair or to isolate and make secure the leak until it can be repaired. Your defence then is due diligence. If the leak is in your customers working space occupied by his staff, he may also be contravening the H&S at work act. Additionally, running a hermetic system deficient in refrigerant can damage the equipment and cost much more in the long term.

My understanding of the waste laws is that you register your company and premises. Your engineers are deemed to be ?mobile collectors? until the waste is returned to your premises if your customer?s premises are exempt. However, if your customer produces more than 200 kg annually, you need to use his waste registration number that you should have on record. Work with the EA on this one.

Finally, there are no guides about refrigerants and the new regulations on line. You have to read all the documents and do it for yourself.

.
.
________
Lincoln Blackwood history (http://www.ford-wiki.com/wiki/Lincoln_Blackwood)