Is this an earner or what ???

[Peter Croxall]

Hi guys,
I recently renewed my safe handling ticket and was told by the instructor, that under new European legislation proposals, all systems over a certain size will require AN ANNUAL PRESSURE TEST.

Well !!!!!........I'm all for making sure that our environment is protected and the industry should endeavour to reduce leakage of ALL refrigerants, BUT...I can't help but think that this is just another way to generate cash. I cannot think how the government can hope to enforce this law, (if it is accepted by the U.K.) Does anything like this exist in the States ?

How many clients would willingly accept that an engineer will have to pressure test their airconditioning/refrigeration systems annually. Especially with all the cost that this entails (reclaim, test and re-charge).

What if the system had no history of leakage, in his eyes, this would be just another example of a service company trying to "rip him off". I'm sure the client would soon be looking for a new company to service hie equipement. ( enter the cowboys ?) No slur on our American cousins...just a figure of speach.

The only way this could be enforceable, would be if the client's insurance would be invalid, if no current test certificate was available.

I know that this legislation sounds great at first glance, look how much work it would generate. But an industry trying to rebuild their reputation after the refrigerant replacement misinformation can ill afford more distrust from the people we are trying to serve.

AM I BEING PARANOID OR WHAT....or......HAVE I JUST GOT THE WRONG END OF THE STICK ?

[superheat]

I would think the fact that system is still fully charged would be test enough. They might be able to get away with reducing the acceptable leakage rate. It is just a bunch of lawyers making up rules when they know nothing about the facts. It is just another way the legitamant people will be made to suffer. They people that do not follow the rules will be given another advantage.

[Peter]

Hi Peter,
Not sure if this is what the instructor refers to but it is already European legisation that all fixed equipment containing CFCs or HCFCs with a charge of more than 3kg must be checked annually for leaks. it doesn't specify that it must be by pressure testing.
The onus is on the equipment owner to prove an annual leak test has been carried out, not the serivce engineer, but obviously you're not going to do it for free (I hope).
If you were asked to leak test a system you wouldn't carry out a pressure check.
Plant maintenance records are a good idea.

[Argus]

Your instructor is partially right. It says, "checked for leakage annually". It does not say anything about the charge quantity or pressures. Leak check, only. Most reputable companies are already doing this. The point is that the EC is determined to reduce the excessive leakage rate in the RAC sector, currently estimated at approaching 30%, probably more.

The regulation in question is EC 2037 / 2000, which is the implementation in EC law of the requirements of the Montreal Protocol.
Strictly speaking it only applies to ODS gases, that is chlorinated gasses that are defined in article 2 and it applies to all ODS in any application, not just as refrigerants.

Best read all of Article 16. In 16/5 the responsibility for compliance is on everybody associated with a system, including the technician, not just the owner / operator. It also lays down requirements for minimum qualifications. This is the reason for the studies going on about mandatory registration of refrigerant handlers.

Article 17 says that fixed kit shall be annually checked for leaks amongst other things. That's all. It seems to me that responsible owners and service companies will write their own specific method statements to suit their own particular operations. It also says that the member states shall define qualification
requirements for this, too. With the exception of Refrigerant Handling, I don't recall any of the above being tackled by the UK, so watch out for infraction proceedings.

The EC is now working on legislation to apply to Green House Gases, to comply with emission controls in the Kyoto Protocol. Nothing is published or decided yet so watch this space. This means HFCs, and will probably include, wait for it, annual leakage checks over 3 kg…..!.

The UK has no mandatory controls on refrigeration or A/C. In comparison to many other countries, it's open season for the cowboys.

Frankly, the sooner we get our act together the better.
The alternative is the way that Denmark and Austria are going, that is Prescriptive measures, not only on ODS, but HFC, too.
We won't be worrying about cost then.......m ost will no longer be in business.

You can download the Regulation, plus some guidance booklets from:
http://www.dti.gov.uk/access/ozone.htm

[Derek]

Pressure System Safety Regulations
UK Legislation

Fridge equipment above 25kW must have a Written Scheme of Examination. Must not be put into service until it has a WSE.

Competent person shall write and undertake examination !may! include re-proof test subject to the view of the competent person.

Also he !may! expect as HSE claim all PRV's to be tested anually. may define period at one year or more. Period must be reduced if fault/failure e.g corrosion identified.

Risk to environment High
Cost High
Benefit to industry questionable.


Institute to Refrigertion has just issued a nice guideline on PSSR.

[Peter Croxall]

Thanks for the info guys....

I GUESS I HAD THE WRONG END OF THE STICK THEN