New Regulations on F Gas

[Argus]

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Those following the European F Gas regulations will know that further detailed implementing regulations were in the offing.

Some of these implementing regulations with relevance to this industry are now available, published in the Official Journal in late December:

1. LEAKAGE CHECKING
Under the F-Gas Regulation 842 - 2006, in Article 3: the Commission was required to establish standard requirements on leakage Checking. They should have completed all this last July but it was delayed.
A new regulation to add detail to the existing requirements in Article three was published in the Official Journal.
Regulation 1516/2007 for Stationary refrigeration, air conditioning and Heat Pumps covers the exact requirements. It is unlikely to be further enacted in UK law, though I would expect a UK statutory Instrument (SI) to be drawn up in due course that outlines the offences and penalties in the UK

The regulation details the procedures that qualified personnel must use when checking for leaks and the methods they must follow. It also details what must be done to repair a leak and how it must be documented. It enables technicians and their companies to know what constitutes a satisfactory approach to leakage checks

2. LABELLING:
Regulation 1493/2007
Manufacturers and those selling RAC equipment containing F Gas must, from now on, ensure that they are correctly labelled.
The Labelling Regulation sets out the exact format and requirements of the label, and where it must be put. These regulations about labels only apply to new products being put on the market and not to existing installed equipment. The entry into force is set for 1st April 2008.

3. LEAKAGE CHECKING OF FIRE SYSTEMS
Another, Regualtion1497/2007 covers leakage of PFCs in Fire Protection Systems. (Not of immediate interest for RAC technicians, but it’s part of the F Gas regulations and in there nonetheless).

4. REPORTING:
Chemical manufacturers of F gases, importers and exporters are now required to provide regular reports of quantities. Regulation 1494/2007 sets out the format for data to be submitted by Producers, Exporters and Importers every year to the European Commission.

5. QUALIFICATIONS:
Finally, and most importantly, minimum competence qualifications for training are still outstanding due to a problem with the legal base. It seems that there are on-going issues with the transitional period that must be allowed for those in the trade already to gain the qualifications and to ensure that all the transitional arrangements are acceptable in all the member states.



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[Brian_UK]

Thanks for the update Argus.

[Pooh]

I cant say anything more at this time but watch this space for info on qualifications. The issue is at present not legal as such but which if any qualifications meet the requirements, hopefully should be able to say more by the end of the month.

Ian

[Argus]

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Agreed.

But if the lawyers have reverted to discussing the legal base of a regulation that is already in effect, past experience teaches me not to expect anything soon.


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[S_Line]

Has a method of leak testing been aproved ?
THe last info i had was Novemebr, but with no information on how to leak test systems over 3 K.G of refrigerant.

[Argus]

Has a method of leak testing been aproved ?

Yes it has.

The requirements are outlined in a new implementing regulation.

Please read the details in the first post in this thread.

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[S_Line]

details i have found here > http://www.berr.gov.uk/files/file42192.doc

its 2006 though

[Argus]

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If you are having problems finding it, I’ll post some up-to-date links

There are two government sources of F Gas information in the UK to bookmark.
What used to be the DTI and DEFRA. The DTI is now called BERR and their site is still the same, but renamed and rebadged. BERR does not seem to have kept their site up-to-date, and you are right, it still carries a link to the proposal document.

http://www.berr.gov.uk/innovation/su...page28889.html

http://www.defra.gov.uk/environment/...fgas/index.htm


Things have now moved on, the new legislation is complete (with the exception of the work on competence and certification) and this was the reason for my post.

The leakage checking procedures for stationary equipment were implemented in a new regulation, in mid December. It was published in the Official Journal on the 19th and takes effect 20 days later. Here is a link to the full legal text. It is fundamentally the same as the proposal, except that the relevant dates etc are filled in.

http://eur-lex.europa.eu/LexUriServ/...en00100012.pdf

It does not apply to transport refrigeration or to car systems.


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[S_Line]

Many thanks for that,

A question though, with regards to enforcing repairs of leaks.

Say for example, one of the Engineers attends a regular service of a unit, to find oil on a outside flare Nut, leak testing with a electronic instrument proves that there is a leak.

Engineer reports back to Office with service sheet.
The customer is contacted to say there is a leak, but what if the Customer dosent want it repaired ?

How can we enforce a repair ?

[Argus]

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Read carefully what it says in the F Gas regulation, Article 3.
It is entirely the legal responsibility of the operator of the plant. There's no argument.
The service company must firstly inform him preferably in writing, next it goes in the equipment's log book, then if he refuses, inform him that it's an offence and put that in the log book too. As far as the leak is concerned good practice demands that it is either repaired or neutralised until it can be repaired.
Doing nothing is not a legal option.

Read also article 13.
What usually happens in these instances is that the European Regulation is the law - it takes effect in all 27 member states. The enforcement, offences and penalties, is then outlined in each country who will set the penalties. We can probably expect to see a UK SI soon outlining the offences and penalties.



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[frank]

.inform him that it's an offence and put that in the log book too.

Are there any freely available examples of what an equipment logbook should look like and the information it should contain?

[Argus]

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Frank, go to the DEFRA web site:

http://www.defra.gov.uk/environment/...fgas/index.htm
have a noodle around.

Down load both the initial guidance – from September 2006:
http://www.defra.gov.uk/environment/...fgas/index.htm

and

The supplementary guidance from February 2007. A sample layout of the log book format is on page 17.
http://www.defra.gov.uk/environment/...rigeration.pdf
This is not cast in stone, but consider it as the minimum requirements. You can add more data fields to it to suit your company and client’s needs.

But, the regulation has been in force for almost 2 years. You must be doing this now.

At the risk of a personal plug, I do provide technical seminars on this sort of thing.


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[frank]

Thanks Argus.
It's nice to compare what we are doing with the suggested minimum requirements. Being out of the office for the majority of the time, it's difficult to spend any worthwhile amount of time searching and researching.

We are currently processing registration with safeContractor and now Besca, which leaves little time for the mandatory tasks within a busy office.

[Argus]

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Leaving the Moaning-Minnie Luddites for a moment, and apart from the obvious environmental / legal issues, this is probably the best business opportunity for service companies to have occurred in years.

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[Pooh]

Training Providers as well, I LOVE THE EU!

Customers are not going to be happy thou

Ian

[Argus]

Training Providers as well, I LOVE THE EU!

Customers are not going to be happy thou

Ian

Hard Cheese!

[Tony]

This came from ACRIB today:

"Latest news on the implementation of the F Gas Regulation - 16th January 2008
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New F Gas Training and Certification standards adopted by the Commission

- UK RAC industry prepares for mandatory assessment of workforce skills


The European Commission has now finalised its detailed requirements for the training and certification of engineers working on stationary refrigeration and air conditioning equipment under the European Fluorinated Gases Regulation – known as the F Gas Regulation.

Whilst most UK engineers have been assessed in refrigerant handling to the City and Guilds 2078 or CITB standard over the past 15 years, the new F Gas standard will be a much more thorough and wide ranging examination. It will include a range of observed practical assessments and a multiple choice examination which will test the knowledge of underpinning principles.

John Ellis, Past President of the IOR and Past Chairman of ACRIB who has reviewed the specification in detail comments “This is the first time that an assessment specification has been written into a Regulation on refrigerant handling. There is no doubt it will be tough to comply with but it would have been a lot worse without the work of ACRIB and DEFRA negotiating at a European level.”

Since the Commission finalised the requirements in December 2007, industry representatives through ACRIB have been working with existing awarding bodies (City and Guilds and CITB) to come up with a top-up qualification for those who already have refrigerant handling or S/NVQ qualifications. The new F Gas qualification is still under development and consultation, and will be presented to UK Government at the end of January. For details of your obligations as an employer of personnel handling f gases see the ACRIB F Gas Training Guidance Note.

Given that the whole of the existing workforce of up to 40,000 engineers will need to take all or part of the new assessment, one of the key briefs was for this to be as efficient as possible in terms of the time taken. It is expected that it will take approximately 4 hours for each candidate to be assessed by a qualified assessor. The level of training needed to get technicians up to the standard necessary to pass the assessments will depend on the prior qualifications, experience and knowledge of the individual. It is likely that this could be up to four days however, because much of the assessment is theoretical and covers principles of refrigeration required to assess performance of systems and their energy efficiency.

Jane Gartshore President of the IOR welcomed the work ACRIB is doing and said “We should not forget that whilst there will be a cost to industry, the F Gas training will also improve standards of competence throughout the workforce”

Training providers and colleges should be able to register to deliver the new qualifications being put together by ACRIB early in the Spring with the first assessments going ahead in early July, when the requirements for F Gas Personnel Certification were due to come in. However with the current limited provision of training and the significant changes and challenges that the new F Gas qualifications will present, it is expected that it will take some years to get the whole of the UK workforce re-certified. Only those who have taken the new F Gas assessment will be recognised as competent throughout the whole of Europe, so in order to work with F Gas refrigerants, the sooner the new certificate is obtained the better.

The Commission requires that all technicians should have obtained this new qualification by January 2009. However the UK Government will be consulting in the early summer on whether to allow a further three years (up to July 2011) for existing personnel to obtain the new qualification. ACRIB is pressing to ensure that the UK is granted an extension of the full three years to complete certifications. In the mean time , of course, the existing certificates C&G 2078 or CITB equivalent continue to be the existing national legal requirement for both F Gas and ODS refrigerant handling. The ACRIB voluntary register provides proof of competence through a register and card scheme.

These requirements will be enforced by a Statutory Instrument expected to be published early this year which will lay down penalties for infringement. A programme of enforcement is currently being prepared by Government based on an awareness campaign targeting the key business sectors responsible for emissions of F Gases and gaining high level commitment to meeting the requirements of the Regulation from these businesses.

The Commission also recently agreed the principles for a Company registration scheme. Companies employing certified personnel will need to be registered, but again the deadline may be extended until July 2011. If so, companies will need an interim certificate by July 2009. The Government will be consulting on possible arrangements for the issuing of these interim company certificates and the length of the transitional period.

Further information and Printable Guidance Notes are available from ACRIB on:
Obligations of Employers
Obligations of End Users
Leak Checking Requirements
System Record Keeping
Penalties and Enforcement
See www.acrib.org.uk"

[thermo prince]

Argus - thank you for the effort in putting these summaries together. Very useful.
Tony also for your additional material.

regards
TP

[Argus]

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There is some more new legal bumf to read..... the EU F Gas Regulations came into effect in 2006.

The UK Govt has just published the SI covering the offences and penalties with an explanatory memorandum:

The UK F Gas Regulations
http://www.opsi.gov.uk/si/si2008/pdf...0080041_en.pdf

and an Explanatory memorandum:

http://www.opsi.gov.uk/si/si2008/em/...0080041_en.pdf

I should emphasise that the EU 2006 F Gas Regulations are EU LAW ONLY and the new Statutory Instrument links here are UK LAW ONLY.

Other European States will have their own versions according to their own laws in their own languages.

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[Grizzly]

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There is some more new legal bumf to read..... the EU F Gas Regulations came into effect in 2006.

The UK Govt has just published the SI covering the offences and penalties with an explanatory memorandum:

The UK F Gas Regulations
http://www.opsi.gov.uk/si/si2008/pdf...0080041_en.pdf

and an Explanatory memorandum:

http://www.opsi.gov.uk/si/si2008/em/...0080041_en.pdf

I should emphasise that the EU 2006 F Gas Regulations are EU LAW ONLY and the new Statutory Instrument links here are UK LAW ONLY.

Other European States will have their own versions according to their own laws in their own languages.

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Thanks for the links Argus
I have to admit I read through them but was slightly baffled by facts and figures. So I will wait till it's drip fed on the forum by yourself and the other learned guys.
I have also deleted the thread I posted as it duplicated some of these details.
Thanks Grizzly