remove working a/c from site-fgas reg

[gwm121]

1. A new split system is delivered from supplier anywhere to anyone with 1.6kg r410a gas in condenser, no fgas paperwork, this is completely legal.
2. A split system that has failed and will be disposed of (1.6kg r410a),..... An fgas qualified engineer recovers refidgerent to condenser of a split system to condenser, leak checks valves, it is legal to leave this on site, but if it is removed from site gas and oil has to be reclaimed and sent for destruction before condenser is disposed of and the person taking gas off site neds a waste mgmt lisence.
THE ABOVE I UNDERSTAND, HERE IS MY QUESTION
An fgas registered engineer, but without waste gas mgmt certificate, has a newish split 1.6kg r410, working but sometimes faulting due failed condenser fan motor and/or pc board. Due difficulty of working on condenser (and because this 2 year old system is no longer current so a replacement condenser cannot be obtained) the whole system is replaced with new, the refriderent recovered to condenser by fgas qualified engineer with a view to taking back to workshop, repairing board/fan, and re installing system at another customer.
Is it legal to do this without waste gas certificate...but with cat3 fgas certificate there doesnt seem to be a difference between moving a new condenser with gas, and this situation, .......though if it was to be disposed of it wouldnt be legal.... help someone please, im confused..

[Rob White]

1. A new split system is delivered from supplier anywhere to anyone with 1.6kg r410a gas in condenser, no fgas paperwork, this is completely legal.
2. A split system that has failed and will be disposed of (1.6kg r410a),..... An fgas qualified engineer recovers refidgerent to condenser of a split system to condenser, leak checks valves, it is legal to leave this on site, but if it is removed from site gas and oil has to be reclaimed and sent for destruction before condenser is disposed of and the person taking gas off site neds a waste mgmt lisence.
THE ABOVE I UNDERSTAND, HERE IS MY QUESTION
An fgas registered engineer, but without waste gas mgmt certificate, has a newish split 1.6kg r410, working but sometimes faulting due failed condenser fan motor and/or pc board. Due difficulty of working on condenser (and because this 2 year old system is no longer current so a replacement condenser cannot be obtained) the whole system is replaced with new, the refriderent recovered to condenser by fgas qualified engineer with a view to taking back to workshop, repairing board/fan, and re installing system at another customer.
Is it legal to do this without waste gas certificate...but with cat3 fgas certificate there doesnt seem to be a difference between moving a new condenser with gas, and this situation, .......though if it was to be disposed of it wouldnt be legal.... help someone please, im confused..

Be aware that if you leave the system on site the owner still has
a duty of care to prevent leakage, but you are correct with it being
legal (for the time being anyway ) because it is less than 3 Kg.

The removal of a condensing unit with a refrigerant charge inside is,
as you state a grey area.

In my opinion (I will get conformation on this for you) In my opinion if
the refrigerant is pumped down and the unit is being removed with a
view to repair it, then I think that is ok and does not require a waste
transfer licence. The refrigerant is only classed as a waste if it is being
removed for recycling or destruction.

Regards

Rob

.

[Kev The Tool]

The refrigerant is only classed as a waste if it is being
removed for recycling or destruction.

if you are scrapping the unit the gas is waste if your'e repairing it then it is not waste.

i hope this clears it up

kev

[gwm121]

Thank you Rob, and kev.
Yes your reply clears it up succictly, except for what paperwork to leave with customer....
I was told by refcom official recently that all aircon systems both under OR over 3kg gas had to have an associated commissioning report left with customer proving leaktight before gasssed, and referring to old system and what was done with gas. This would mean leaving paperwork with customer telling them we had intention of making use of old system .Am I correct here...what paperwork is legally left with customer regarding old unit in your opinion? ... "grey area" is an apt description in my opinion...

[Rob White]

Thank you Rob, and kev.
Yes your reply clears it up succictly, except for what paperwork to leave with customer....
I was told by refcom official recently that all aircon systems both under OR over 3kg gas had to have an associated commissioning report left with customer proving leaktight before gasssed, and referring to old system and what was done with gas. This would mean leaving paperwork with customer telling them we had intention of making use of old system .Am I correct here...what paperwork is legally left with customer regarding old unit in your opinion? ... "grey area" is an apt description in my opinion...

When a new install goes in you leave all the documents with the customer and
you are supposed to leave a commissioning document and a pressure test certificate.

These two documents are what you produce. You can get templates from the web or
maybe DEFRA but basically you are just signing a piece of paper with the information
about how high you pressure tested it and for how long.

That then gives the customer some written proof that the system is gas tight and working ok.

Those documents could be done on the back of a cornflakes packet if you wanted, as long
as all the required information was covered.

More often than not it includes information

Date of install
Name of installer
Pressure tested level for strength test & duration
Pressure tested level for gas tightness & duration
Depth of vac
Duration of vac
Witness signatures
Basically "who, what, where and why"

Regards

Rob

.

[install monkey]

also a copy of f gas records and disposal sheets are to be kept in the office as reference for when the fridge police visit and carry out audits

[gwm121]

Instal monky.. you have confused me after from previous replies i though I undesrtood..
WHEN.....
A new system is installed and the old system with an electronic fault, suspected fan motor and/or pc board, (fan only runs at low speed giving cond coil over 67 degrees in cooling fault code) is removed with its 1.6kg r410 recovered to condenser and taken back to workshop to be repaired and used again.

So as I understand this from Rob and kev, and Refcom, the new unit has to have a logbook raised at installation left with customer stating the usual comisssioning info, and the old unit (gas reclaimed to condenser and leak checked by fgas reg eng, just like when new) can be taken to our office with no waste management paperwork, and with a log book attached to unit showing eng/gas recovered to condenser/date. (and rechecked for leak withi 1 month)
So the customer would have ONLY paperwork relating to new unit, (log) we would have the old unit with logbook attatched... have I got this right.....

My confusion recently has been compounded as at a refcom audit we sere told there is no difference in the records to be kept by a customer whether system has under or over 3kg, refcom said categorically a logbook had to be kept with records of commisioning (as rob kev confimed above) servicing, and on each servicing record gas out or in or "n/a"... the ONLY difference they said was the requirement for a legal annual check

nb.... The most extrordinary situation has arison where fujitsu has made their new 7kw asy24 wallmount utterly incompatable with the old (2 year old !) asy24 (LCC series), and no complete condensers or indoor units are avalable.. so if a complete condenser or complete indoor unit needs replacing a complete system has to be installed. This means the old lcc unit above is very valuable to us.