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neil sailes
26-05-2005, 03:32 PM
Hey all

Could anyone tell me how the law stands on reclaimation of HC refrigerants like R260, R600 and the care ranges.
Because they have no ODP hazard are the regulations as strict.
Also when reclaiming these refrigerants what is the best reclaim machine to use.

Thanks

Neil

botrous
26-05-2005, 04:52 PM
"In this final rule, the EPA has determined that second generation replacements, if they are non-ozone depleting and are replacing non-ozone depleting first generation alternatives, are exempt from reporting requirements under Section 612"
from : http://www.autocool-refrigerants.com/envirosafe_tech.htm

neil sailes
28-09-2005, 07:47 PM
Hi all.
Because the company has just put an order in for the R290 refrigerant I am looking for any litigation I could show the tech director of the company. Because if I can't he will ask me to vent it to atomosphere and I already have 26 units waiting for new R290 compressors, apart from the Health and Saftey factors that the refrigerant is heathier than air which makes it an asphixiant, also it means I will be letting a flammable gas into atomosphere, were I use oxy/acette brazing equipment. He says that I cannot produce a valid reason for the company to fork out 600 on a new reclaim unit that can work with H.C refrigerants.

neil

Argus
28-09-2005, 10:52 PM
.

Sorry Botrous, a mix-up in terminology here.

The EPA (Environmental; Protection Agency) is an American enforcement agency that has no jurisdiction in the UK (or Europe for that matter).

Neil, in the UK here are some pointers.

In the UK the similarly sounding, but completely different, EPA (Environmental Protection Act ? 1990) http://www.opsi.gov.uk/acts/acts1990/Ukpga_19900043_en_1.htm#tcon is the legal instrument that will govern the vent to atmosphere of refrigerants. The best place to start is section 33.

If you are prosecuted for illegal venting of anything, it will be by the Environment Agency, http://www.environment-agency.gov.uk/ unless you are unfortunate enough to injure or kill someone in which case it will be the HSE (Health & Safety Executive). http://www.hse.gov.uk/

Needless to say it is a very grey area, because having a GWP below 15, HCs are perceived to pose no distinct threat to the environment. The rules surrounding their retrieval are blurred.

You can gain valuable insights from CARE themselves, https://pgw100.portal.gases.boc.com/scripts/wgate/zcpwp_b2c/!?~login=pgwspecial and the Institute of Refrigeration http://www.ior.org.uk/ and ACRIB, (Air Conditioning and Refrigeration Industry Board) http://www.acrib.org.uk/ that both have guidelines on their safe use.

.
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neil sailes
29-09-2005, 07:32 PM
Thanks Argus
After coming of RE last night I did find a little information on the ACRIB site. But the regulations concerning H.C refrigerants is a bit bleek to say the least. I think that I might join the IOR I have a membership form around here somewhere, see what their tech notes say.

Neil

Argus
29-09-2005, 11:21 PM
Neil,


You may also talk to BOC / Dupont who have recently acquired the distribution of CARE products in the UK. John Rodriguez, who posts here sometimes works for BOC, and may be able to help you from a supplier?s point of view. I believe that they have user guidelines for HCs.

Since yesterday I have also had a look at EN 378. It?s worth reading Part 1 where L1 group refrigerants (flammable gases) are prohibited in use in direct A/C systems used for human occupancy. There are safety indicators in this standard.

If your firm is going to handle it, I suggest that it is prudent to survey the competencies of handlers and to draw up a health and safety risk assessment for the transport, storage and use of HCs. Your supplier will give you H&S data sheets (MSD Sheets) that you can give to your operatives and keep on file.

Check also that your premises are suitable for storage, fire protection is adequate and your building insurance and public liability insurance is suitable.

All best

Argus
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Johnny Rod
30-09-2005, 09:05 AM
I'll ask one of our guys who makes it his business to keep up on legislation. Not something I know about, but venting HCs isn't exactly safe, a lot of customers have it flared off where they have the facility on site, not sure about those that don't or where you are in an enclosed space.

Argus
30-09-2005, 09:37 AM
.......venting HCs isn't exactly safe, a lot of customers have it flared off where they have the facility on site, not sure about those that don't or where you are in an enclosed space.


Thanks, John

The issue of HC disposal is a grey area that needs some thought. Not something I'm too well up on either. The situation is clear for conventional refrigerants, but not specific for HCs.

Obviously it is unsafe to do anything like venting near cellars, underground areas etc.

The UK laws on hazardous waste changed this year.
All refrigerants are hazardous waste under the new regulations that came out this year. Section 1 - 14 in the Waste List itemises the CFCs , HCFCs, HFCs etc and solvents, but is not specific about HCs. (Are HCs classed as Halogenated Solvents? - if so then are covered.)

There is a schedule in the waste regulations that lists properties that would render substances hazardous and HCs would certainly fit in.
Waste oil is always a hazardous waste.

The point I?m making is that Neil?s legal duty of care (or anyone else?s for that matter) extends to safe and responsible disposal as well as safe use.

.
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Johnny Rod
30-09-2005, 01:38 PM
Hydrocarbons aren't halogenated but I am sure they will be covered under one of the sections - typically our waste guy has gone home about half an hour ago so will ask him next week.

A blanket for everything really is that operations should be risk-assessed, which includes the materials and the way in which they are used. Until that's done...

Will be back with the answers next week.

Argus
30-09-2005, 03:29 PM
Hydrocarbons aren't halogenated but I am sure they will be covered under one of the sections

Thanks - I didn't know that. Informative as ever. What is a definition of Halogenated gases? I thought that it was a compound containing Hydrogen? I should have paid more attention in school!

HCs as a refrigerant are not specifically mentioned in the Waste List, but there is a schedule of hazard properties in the Waste Regulations that would fit.
The main problem with handling the stuff as a waste regularly is the notification of premises and staying below the 200kg annual limit.


....our waste guy has gone home about half an hour ago so will ask him next week.



Anyone would think it's a Friday.....




A blanket for everything really is that operations should be risk-assessed, which includes the materials and the way in which they are used. Until that's done...



Couldn't agree more. I think that a risk and competence assessment is part of the employer's obligations under the H&S at Work Act.
It would be unwise not to.

.
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neil sailes
30-09-2005, 04:30 PM
Due to my employer making me redundant today ,because of lack of work.
Plus the way the company is run. They still have a few kilo's of R12 which I had been pestering for them to get rid of since I had been there (nearly four years), and it took the company two years for them to rent a reclaim bottle for me. So they also have a lot of old bottles full of spent refrigerant, that I had to reclaim in.
So I think in the end the R290 refrigerant will probably be vented to atomosphere.

Neil

frank
30-09-2005, 08:32 PM
So I think in the end the R290 refrigerant will probably be vented to atomosphere.
No doubt your local Environmental Health Officer would be interested in this fact

neil sailes
01-10-2005, 11:10 AM
Hi Frank.

I need a reference first.

Neil

Brian_UK
01-10-2005, 11:47 PM
...I need a reference first....No I don't think so Neil, as you have been made redundant there shouldn't any comebacks on you for reporting a potential problem to the Environmental people.

You could always do the call as a "concerned individual".

Argus
02-10-2005, 11:48 AM
It's the Environment Agency who will do the inspections.

http://www.environment-agency.gov.uk/subjects/waste/

Local contact points are at the bottom of the page.

Any CFC, R12, R11 R502 stored, but not in use in systems in the UK, is considered waste. Since July this year, all refrigerant waste is termed Hazardous Waste and requires licenses and notification of premises where it is held or stored.

Pain in the neck, I know, but it?s the law in this country.

Venting this stuff is just like fly-tipping ? they hate it.

Your ex-firm is probably in breach of something??

.
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Johnny Rod
03-10-2005, 03:42 PM
Seems to be a bit of a grey area this one, not a definite answer yet.

In reply to Argus, halogenated materials contain chlorine, fluorine, bromine and/or iodine. I don't know of any refrigerants with iodine in them, Halons contain some bromine, and we know the rest about CFC/HCFC/HFC/FCs. Apart from the ozone-depletion problem, incinerating these materials at too low a temperature gives rise to dioxins which are very toxic (e.g. Agent Orange was a dioxin), which is why burning PVC is a bad idea, and why it costs a lot to dispose of old refrigerant.

Like Argus says, new regs mean a lot more material is now classed as hazardous, but I think there are probably still lots of firms that have yet to apply for their new documents under the new rules.

Argus
03-10-2005, 05:12 PM
Thanks for the reply, John.

Chemistry is not my long suit, so to speak, so that was very helpful.

If your colleague has any insights into the safe and legal (in the UK) disposal of HCs, I would be grateful to hear them.

There are a number of alternatives I can think of;


Vent them off. Not a good idea in my opinion as they have a habit of collecting in still atmospheres at low level. Additionally, what do you do with the oil? Unsafe and unsound.

Flare them off. Again, consider the oil, unless you can arrange to atomise it in the flare. To do this safely you will need the equipment to do it, somewhere designated to do so and a fire safety policy ? I don?t think you can let a sheet of flame go from the edge of the roof or in your firm?s yard.

High temperature incineration?

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neil sailes
03-10-2005, 06:51 PM
Hi Argus.

I think I will contact the enviroment agency by the end of the week. The problem about being a concerned individual is that the refrigerant is pretty well hidden. I will have to give the enviromental people a good description of were it is. Thinking about it as well they have at least 75 kilo's of reclaimed contaminated refrigerant they they don't seem to want to dispose of.

Neil

Argus
03-10-2005, 07:01 PM
........the refrigerant is pretty well hidden. I will have to give the enviromental people a good description of were it is.




I expect they will be able to find it.

They will start with a demand to see all the relevant records, etc. I believe that they have the right of entry if they suspect an offence.

Be very careful with your facts.

You will still need to work when the dust has settled and this is a small industry with a big grapevine.

.
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frank
03-10-2005, 07:37 PM
they have at least 75 kilo's of reclaimed contaminated refrigerant

So we're not talking about vast quantities then. This is only just over a large cylinder. But, that said, it can't be vented.

neil sailes
04-10-2005, 10:14 AM
You are right Argus.

I'm not feeling so bitter now. The best thing for me to do would be to contact the M.D of the company and tell him that he is still storing the refrigerant. Because the level of communication in the company is not so good he probanly does even know that he has got it. If I email him and tell him he can kick sum ass and get it sorted without it getting dirty. Especially if he thinks he will have to pay out a few grand in fines.

Neil