Issue 18
Technical news for the Institute of Refrigeration Service Engineers’ Section
Premises codes and
removing waste refrigerant
from customers’ sites
The Environment Agency advises that
there are two ways technicians can
operate to remove recovered refrigerant
from a serviced site:
Welcome to the December mailing
from the Service Engineers’ Section.
In your mailing you will find:
• Fundamentals on Using the PH
Diagram
• Good Practice Guide on Brazing
to minimise Leakage
• Good Practice Guide on
Refrigeration Piping
This is the final mailing for 2009.
Renewal notices will be going out in
March 2010 and we have an
interesting year ahead planned with
more on the use of p-h charts to
improve system efficiency, a range
of
material
on
industrial
refrigeration systems and useful
pipework good practice guides.
Service Engineer members get free
access information from the new
Air Conditioning and Heat Pump
Institute by downloading bulletins
from www.ior.org.uk. – register
on the website now to ensure you
don’t miss out.
One-Off Removal
You do not require a premises code if
you are removing less than 500 kg of
recovered refrigerant in a 12 month
period as a one-off operation from a
specific site eg to a wholesaler,
refrigerant distributor or reclaimer.
However you must:
a) keep the refrigerant separate from any
other recovered refrigerant.
b) keep a detailed record of all the
hazardous waste removed by you or any
other person from that site in any 12
month period
If the amount you remove is likely to
reach or exceed 500kg you (or the site
owner) must obtain a Premises Code for
that specific site before you remove any
recovered refrigerant.
Operation as a Mobile Service
You can operate as a hazardous waste
Mobile Service which allows you to
collect amounts less that 500 kg from any
site you service, collecting all the
recovered refrigerant together and
handling it as a single quantity, but only if:
a) You have a Premises Code for your
own business site, before you start.
b) You produce a Consignment Note for
each site visited, detailing the amount
recovered and removed from that site
and quoting your own Premises Code.
c) You keep a detailed record of all the
hazardous waste you remove from each
site in any 12 month period.
If the amount you remove is likely to
reach, or exceed 500kg you must then
treat the site as a totally separate
removal operation (see 1 above) and you
(or the site owner) must obtain a
From the Service Engineers’ Section of the Institute of Refrigeration at www.ior.org.uk
Premises Code for
that specific site
before you remove
any
further
recovered refrigerant that amounts
to 500kg or more from that site in
the 12 month period.
Registering
with
the
Environment Agency for a
Premises Code
You must inform the EA if you
intend to operate as a mobile
service to obtain a Premises Code
for your business before you start.
It is illegal to operate a mobile
service without one and there is a
risk of prosecution.
For more details see the ACRIB
guidance note “Do I need a
premises code?”
Are your trainees getting
adequate supervision?
Under the F Gas Regulations
trainees can carry out work on
system containing or designed to
contain F gases for a maximum
period of two years, provided that
they are enrolled in a training
course which will lead to F Gas
certification.
The trainee must be able to prove
that they are actually taking a
training course ie have put their
name down to take or start a
course on a specified date.
It is an industry recommendation
that these trainees should be
supervised in person at the location
where the work is being carried
out. In some cases there will be
constant supervision and in others
it may be reasonable for
supervision to be intermittent, but
December 2009
regular. The certificated company
carrying out the relevant activity
should have processes in place to
establish what they consider to be
a “reasonable” level of supervision
for the activity being carried out.
For trainees the level of supervision
recommended is high. A trainee
requires
constant
on
site
supervision especially in the early
stages of training. As the trainee
becomes more experienced they
can be given larger tasks to carry
out by themselves, but the
supervisor should always be on
hand to provide guidance and sort
out problems.
Working safely with
flammable substances
The Dangerous Substances and
Explosive Atmospheres Regulations
2002 place an obligation on
employers (including the selfemployed) to carry out certain
duties such as the recording of
procedures, decisions and findings
about what substances are in use
and what the risks of explosion are,
plans to deal with accidents, training
of personnel and zoning of areas
when carrying out work.
The types of activities covered by
DSEAR includes anything that
involves the exposure of people to
flammable substances in the
workplace. This can also apply if you
are working on hydrocarbon,
ammonia
refrigerating
systems
including the use of acetylene for
welding.
For more details see download the
new Guidance Note 19 from the
IOR or view information at
www.hse.gov.uk/fireandexplosion/dsear.
htm
R22 Phase out – the
deadline is here
Many businesses in the UK will be
affected by the R22 ban so its worth
repeating the new obligations which
come in from 1st January 2010 under
the EU Ozone Depleting Substances
Regulations which were revised in
2009.
Can I still use of HFCs after 1st
January 2010?
• from 1st January 2010 it is illegal to
use virgin HCFCs to service RAC
equipment. This ban applies even if
HCFC was purchased before the ban
date. It is illegal to stockpile and use any
supplies of virgin HCFCs after the end of
2009.
Are there any other special
requirements
for
using
HCFCs?
Cylinders and equipment containing
recycled or reclaimed HCFC must
be labelled. The Equipment labelled
should show the quantity and type
of HCFC contained in the system.
• from 1st January 2015 it will be illegal
to use recycled or reclaimed HCFCs to
service RAC equipment.
How
often
do
system
containing HCFCs need to be
leak tested?
This has changed:
Sysems with an HCFC charge of
3kg or more must be checked for
leakage at least once every 12
months; (this does not apply to
equipment with hermetically sealed
systems, which are labelled as such
and contain less than 6 kg of
HCFC)
Bans refer to the “use” of HCFCs for
servicing and maintenance. Customers
can continue using RAC equipment
containing HCFCs beyond the phase out
dates provided that no additions of
refrigerant are required.
What is the difference between
Reclaimed
and
Recycled
refrigerant?
Recycled HCFCs are recovered HCFC
that has been subject only to a basic
cleaning process (this might include
mechanical filtering and moisture
removal). Recycled HCFCs may only be
used by either the undertaking which
carried out the recovery (in most cases
the refrigeration contractor) or the
undertaking for which the recovery was
carried out (the owner). Recycled
HCFCs may not be placed on the market
– "placing on the market" means the
supplying or making available to third
persons within the Community for
payment or free of charge. For example,
the owner could use the recycled. HCFC
in RAC equipment at other sites they
operate from but they cannot sell
recycled HCFC to a third party.
Reclaimed HCFCs are recovered HCFC
gas that has been chemically reprocessed
to a specified standard. Reclaimed
HCFCs may be placed on the wider
market and used by undertakings other
than the original contractor and owner.
Reclaimed HCFCs must be held in
containers labelled as such, with
information on the batch number and
name and address of the reclamation
facility. Reclaimed material has been
reprocessed to a specified quality that is
suitable for use in a refrigeration system
whereas recycled material is of an
unknown quality – it might contain
contaminants that could impair the
performance of a refrigeration plant.
From the Service Engineers’ Section of the Institute of Refrigeration at www.ior.org.uk
Systems containing 30kg or more
must be checked for leakage at
least once every six months;
Systems containing 300 kg or more
must be checked for leakage at
least once every three months
What additional information
needs to be kept for HCFC
systems ?
Users of equipment with over 3 kg
of HCFC refrigerant must keep a
record of the quantity and type of
any gases removed or added, and of
the company or technician carrying
out the service or maintenance.
Undertakings using recycled or
reclaimed HCFCs for service or
maintenance must keep records of
the undertakings which supplied the
reclaimed gases and the sources of
recycled gases.
Are there any restrictions on
storing of recovered
refrigerant?
Facilities storing recovered HCFCs
must register with the Environment
Agency as an exempt waste
operation. Storage of recycled or
reclaimed HCFCs does not require
a permit.
For more details on the ODS
Regulation requirements and
revisions contact F Gas Support at
www.defra.gov.uk/fgas
December 2009