Revised European F-Gas Regulation

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01 Background Current Position Fluorinated Greenhouse Gases Fluorinated gases (F-gases) are a family of man-made gases used in a range of industrial applications. Because they do not damage the atmospheric ozone layer, they are often used as substitutes for ozonedepleting substances. However, F-gases are powerful greenhouse gases (GHGs), with a global warming effect up to 23 000 times greater than carbon dioxide (CO 2 ), and their emissions are rising. F-gas Facts The three groups of F-gases are hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulphur hexafluoride (SF 6 ) F-gases account for 2% of the EU s overall GHG emissions, but F-gas emissions have risen by 60% since 1990 in contrast to all other GHGs, which have reduced some F-gases, especially HFCs, are relatively short-lived; others, in particular PFCs and SF 6, can remain in the atmosphere for thousands of years equipment or products such as foams containing F-gases can have long lifetimes. Maintenance and gas recovery at end-of-life of the equipment or products is therefore essential. To control emissions from F-gases, the European Union has adopted two legislative acts Uses y HFCs are the most common group of F-gases. They are used in various sectors and applications, such as refrigerants in refrigeration, airconditioning and heat pump (RACHP) equipment; as blowing agents for foams; as solvents; and in fire extinguishers and aerosols y PFCs are typically used in the electronics sector (for example for plasma cleaning of silicon wafers) as well as in the cosmetic and pharmaceutical industry. In the past PFCs were also used in fire extinguishers and can still be found in older fire protection systems Legislation To control emissions from F-gases, the European Union has adopted two legislative acts: the MAC Directive on air conditioning systems used in small motor vehicles, and the F-gas Regulation which covers all other key applications in which F-gases are used. The MAC Directive prohibits the use of F-gases with a global warming potential (GWP) of more than 150 times greater than carbon dioxide in new types of cars and vans introduced from 2011, and in all new cars and vans produced from 2017. y SF 6 is used mainly as an insulating gas, in high voltage switchgear and in the production of magnesium and aluminium. should include the allocation of responsibilities and arrangements for putting the policy into effect. All of the this type is commonly referred to as Planned Preventive PAGE 1 > BARBOUR SAFE IN OUR KNOWLEDGE

The newly revised European F-Gas Regulation, (EU) No 517/2014 of 16 April 2014 on fluorinated GHGs was published in May 2014. It repeals Regulation (EC) No 842/2006. The objective of this Regulation is to protect the environment by reducing emissions of fluorinated GHGs. Accordingly, it: y establishes rules on containment, use, recovery and destruction of fluorinated GHGs, and on related ancillary measures y imposes conditions on the placing on the market of specific products and equipment that contain, or whose functioning relies upon fluorinated GHGs y Where imposes possible, conditions access restrictions specific uses should of involve fluorinated the GHGs y establishes quantitative limits for the placing on the market of hydrofluorocarbons. Information The first F-gas Regulation was adopted in 2006 and succeeded in stabilising EU F-gas emissions at 2010 levels. The new Regulation, which applies from 1 January 2015, strengthens the existing measures and introduces a number of far-reaching changes. By 2030 it will cut the EU s F-gas emissions by two-thirds compared with 2014 levels. This represents a fair and cost-efficient contribution by the F-gas sector to the EU s objective of cutting its overall GHG emissions by 80 95% of 1990 levels by 2050. The expected cumulative emission savings are 1.5 Gigatonnes of CO 2 uivalent by 2030 and 5 Gigatonnes by 2050. The F-gas Regulation follows two pathways: y improving the prevention of leaks from equipment containing F-gases. Measures comprise: containment of gases and proper recovery of equipment; training and certification of personnel and of companies handling these gases, and labeling of equipment containing F-gases y avoiding the use of F-gases where environmentally superior alternatives are cost-effective. From 2015 the volume of HFCs, which can be placed on the EU market, will be subject to quantitative limits, which Smoke Control. will be phased-down over time. In addition, measures include restrictions on the marketing and use of certain products and equipment containing F-gases. Key Actions work should always be used in the exceptional circumstance that live working cannot be avoided. Permits should also be used for work involving isolation The main requirements of the new Regulation are: at a point remote from the place where the work is taking y extended containment provisions to include refrigerated units of trucks and trailers, switchgear with some derogations, organic Rankine cycles. The thresholds for leak checks will be expressed in CO 2 - equivalents to better reflect the environmental impact to be reduced y service and maintenance ban using high GWP refrigerants but the use of recycled and reclaimed gases will be allowed until 2030 y pre-charged equipment can only be placed on the market if it is accounted for in the quota system y placing on the market bans on HFCs of certain products and equipment such as refrigerators and air conditioners y cap and phase-down of HFCs. In any case, sockets within workshops Prevention should be protected of Emissions with residual current (Article devices 3) (RCDs). Fixed workshop machines such as pillar drills Obligations and abrasive of wheels the operator: should to be take bolted precautions down, include to prevent leakages. accessible The emergency operator stop shall devices also take and all be technically connectedand economically via a volt release feasible device. measures to minimise leakages. When Further a details leakage are is available detected, within is now Barbour an obligation Guide to have it Electrical repaired Services without and undue Fixed delay. Equipment. A certified operative must check a repaired leak within a month after the repair. Portable electrical equipment should also be inspected Obligations and tested in of accordance the contractor: with that a schedule contractors devised both by a operatives competent and person. companies Portable power must be tools certified should to ideally carry out be battery certain powered tasks or services or 110v CTE, (installation, supplied maintenance, via a servicing, transformer. repair, Where decommissioning, 240v tools are necessary, leak checking, they recovery) on should certain be used types only of refrigeration, in dry conditions air conditioning and supplied and via aheat pump residual equipment. current device. Precautionary measures must be taken to prevent leakages. Further details are available within Barbour Guide Electrical Equipment: Portable. Leakage Prevention and Treatment (Articles 4 and 5) i. Chemicals and Flammable Substances The containment measures based on regular leak checking have been extended and cover stationary refrigeration, Hazardous and flammable substances are frequently used for maintenance activities eg paints, thinners, adhesives, LPG. There are also chemicals used in powered equipment eg lubricants and water treatment chemicals. Basic principles should be applied ie: the storage and use of only those substances required, substances selected to be the lowest hazard alternative possible, kept securely in a minimum quantity and used by authorised and trained persons only, who are properly equipped with carefully selected personal protective equipment. Flammable liquids should be kept in a bespoke PAGE 4 > BARBOUR ENVIRONMENT, HEALTH & SAFETY PAGE 2 > BARBOUR SAFE IN OUR KNOWLEDGE

The operator must keep records for 5 years air-conditioning, heat pumps, fire protection systems, refrigerated trucks and trailers, organic Rankine cycles and electrical switchgear with SF 6. The frequency of leak checks will be based on GWP in CO 2 uivalents rather than tonnes of F-gas. This will potentially bring more equipment into the leak-checking regime, designed to encourage a switch to lower GWP alternatives. Conversion of thresholds: y 3kg 5 tonnes CO 2 y 30kg 50 tonnes CO 2 y 300kg 500 tonnes CO 2 Exemption: There are exceptions for switchgear with a tested leakage rate of less than 0.1%, as set out in the technical specification of the manufacturer and labelled accordingly or if equipped with a pressure or density monitoring device or it contains less than 6kg of F-gases. However, until 31 December 2016, equipment that contains less than 3kg of fluorinated GHGs, and hermetically sealed equipment containing less than 6kg of fluorinated GHGs and labelled such, will not be subject to leakage checking requirements. Thus: y equipment with more than 3kg but less than 5 tonnes CO 2 of refrigerant will no longer have to be leak checked from 1st January 2015 y equipment with less than 3kg but more than 5 tonnes CO 2 of refrigerant, will not have to be leak checked until 1st January 2017 (when the grace period comes to an end) y for any type of equipment with at least 3kg of refrigerant, the new thresholds will apply from 1st January 2015. Leak checks are based on the same frequency as that provided by Regulation EC 842/2006. Record Keeping (Article 6) Operators of equipment that must be leak checked regularly are obliged to establish and maintain records of: y quantity and type of fluorinated GHGs installed or added y quantities of installed fluorinated GHGs recycled or reclaimed y quantity of fluorinated GHG recovered y the undertaking which installed, serviced, maintained, and, where applicable, repaired or decommissioned the equipment y dates and results of the checks y the measures taken to recover and dispose of the refrigerant if the equipment is decommissioned. The operator must keep the records for 5 years and contractor must keep a copy for 5 years. d. Control of Contractors duties. Notifiable projects are those which involve more than 30 days, or more than 500 person days of con - struction work. Further details are available within Barbour Guide CDM and Construction Site Safety. PAGE 3 > BARBOUR ENVIRONMENT, HEALTH & SAFETY PAGE 3 > BARBOUR SAFE IN OUR KNOWLEDGE

Recovery (Articles 8 & 9) Until 1 January 2030, this provision does not apply to reclaimed fluorinated GHGs with a GWP>2500 used for the maintenance or servicing of existing refrigeration equipment, provided that they have been labelled in accordance with Article 10 (4a) to Article 9 (3) or recovered from such equipment. work should always be used in the exceptional Phase-down Steps (Articles 15 18 + Annexes V and VI) circumstance that live working cannot be avoided. Permits should also be used for work involving isolation The regulation introduces a phase-down mechanism involving a at gradually a point remote declining from cap the on place the total where placement the work is of taking bulk HFCs (in tonnes of CO 2 uivalent) on the market in the EU. (Base line: 2009 12 average placed on the market into the EU.) Year 2015 100% 2300 2016 17 93% 2139 2018 20 63% 1449 Where possible, access restrictions should involve the 2021 23 45% 1035 2024 26 31% 713 2027 29 24% 552 Average CO 2 2030 21% 483 The phase-down applies to all producers or importers of 100 tonnes CO 2 uivalent of HFCs. Excluded from the phasedown, but subject to specific labelling and reporting requirements, are those HFCs: y imported for destruction y used for feedstock applications y supplied for export out of EU in bulk y used in military equipment y used for semiconductors In any case, sockets within workshops should be protected with residual current devices (RCDs). Fixed workshop machines such as pillar drills and abrasive wheels should be bolted down, include accessible emergency stop devices and be connected via a no volt release device. y (from 1 January 2018) use for metered dose inhalers for the delivery Further of details pharmaceutical are available ingredients. within Barbour Guide Electrical Services and Fixed Equipment. Restrictions/bans on Placing on the Market (Article 11 + Annex III) Portable electrical equipment should also be inspected y Refrigerators and freezers for commercial use (hermetically sealed) and tested containing accordance HFCs with a a GWP schedule of 2500 devised or more by afrom 1 January 2020, and containing HFCs with a GWP of 150 or more competent from 1 January person. 2022 Portable power tools should ideally be battery powered or 110v CTE, supplied via a y stationary refrigeration equipment that contains or relies upon transformer. for its functioning Where 240v HFCs tools with are a GWP necessary, of 2500 they or more from 1 January 2020 should be used only in dry conditions and supplied via a residual current device. y centralised refrigeration systems for commercial use with a capacity of 40kW or more that contain or rely upon their functioning, fluorinated gases with a GWP of 150 or more, from Further 1 January details 2022, are available except in within the primary Barbour circuit Guideof a cascade system where a GWP of less than 1500 may be used Electrical Equipment: Portable. y multipack centralised refrigeration for commercial use with a rated capacity 40kW or containing or relying upon HFC 150 GWP from 1 January 2022 i. Chemicals and Flammable Substances y movable room air-conditioning hermetically sealed, movable between rooms by the end user and containing HFC 150 Hazardous and flammable substances are frequently used GWP from 1 January 2020 for maintenance activities eg paints, thinners, adhesives, LPG. There are also chemicals used in powered y single split air-conditioning systems containing less than 3 kg of F-gases that contain F-gases with a GWP of 750 or more from 1 January 2025. equipment eg lubricants and water treatment chemicals. Basic principles should be applied ie: the storage and use Military equipment is exempted from the bans under Annex III. of only those substances required, substances selected to Smoke Control. be the lowest hazard alternative possible, kept securely in a minimum quantity and used by authorised and trained persons only, who are properly equipped with carefully selected personal protective equipment. Flammable liquids should be kept in a bespoke PAGE 4 > BARBOUR ENVIRONMENT, HEALTH & SAFETY PAGE 4 > BARBOUR SAFE IN OUR KNOWLEDGE

Member States must notify the European Commission of their certification and training programmes, by 1st January 2017 Bans will not apply to Ecodesign equipment that has less lifecycle CO 2 uivalent emissions than equivalent equipment that meets Ecodesign requirements and does not contain HFCs. HFC Import Quota Reporting The Commission will allocate quotas for placing HFCs on the market for each producer and importer for each year beginning in 2015, applying the allocation mechanism laid down in Annex VI (Article 14, paragraph 5). A reference value will be calculated, based on the annual average volume placed on the market by each undertaking from 2009 to 2012. Each undertaking for which a reference value has been established will receive a quota corresponding to 89% of the value multiplied with the percentage indicated for the respective year. The remaining 11% of the quantity are allocated to new undertakings for which no reference value has been established. The Commission will set up an electronic registry. The registry will include producers and importers that have been allocated a quota as well as importers placing precharged equipment charged with HFC s on the market. A detailed traceability process has been established for the import of equipment containing HFCs. From 1 January 2017 RACHP equipment charged with HFCs shall not be placed on the market unless the HFCs charged into this equipment are accounted for within the HFC quota system. An annual declaration of conformity by equipment manufacturers/ producers, verified by an external auditor, is required. Training and Certification (Article 10) Personnel carrying out certain tasks on certain types of equipment must be certified or qualified. Relevant equipment includes refrigerated trucks (above 3.5t) and trailers. Undertakings (i.e. companies, but also self-employed contractors) carrying out certain tasks on certain types of equipment for other parties must also be certified. This now includes decommissioning. Certificates and training attestations issued before the new Regulation s application will remain valid in accordance with the conditions under which they were originally issued. Certification programmes and training must cover the themes already included in schemes under Regulation (EC) 842/2006, with one addition: information on relevant technologies to replace or reduce the use of fluorinated GHGs and their safe handling. Servicing The use of fluorinated GHGs with a GWP> 2500 to service or maintain refrigeration equipment with a charge size of 40 tonnes of CO 2 uivalent or more, will be prohibited from 1 January 2020. This provision shall not apply to military equipment or equipment intended for applications designed to cool products to temperatures below -50 C. Review y 1 July 2017: Report on Annex III, point 11b (the multipack centralised systems) to see if alternatives are available and viable y report assessing the quota allocation method, including the impact of grandfathering and the costs of implementing this Regulation in Member States and of a possible international agreement on HFCs y 1 July 2020: Report on Annex III, single split AC and the availability of alternatives y 31 December 2020: Report on the availability of HFCs on the Union market y 31 December 2022: A comprehensive report on the effects of this Regulation. Although the new Regulation does not name the alternative refrigerants, ammonia (NH 3 ), CO 2, hydrocarbons and hydrofluoroolefine are the main fluids affected. It is expected that the combination of the phase-down and the planned bans will result in an increase in use of alternative refrigerants and technologies to HFCs. References Air Conditioning and Refrigeration Industry Board (ACRIB): http://www.acrib.org.uk/fgas AREA Practical Guide on the application of the new F-Gas Regulation to refrigeration, air conditioning & heat pump contractors is available at: http://www.area-eur.be/system/ files/documents/area%20guidelines%20fgas%20-%20 Master%201%20%28FINAL%29.pdf Manage fluorinated gases and ozone-depleting substances: guidance for industry, Environment Agency European Parliament Regulation 517/2014 The Association of European Refrigeration Contractors (AREA): www.area-eur.be Member States must notify the European Commission of their certification and training programmes, by 1st January 2017. Date of Issue: October 2014 d. Control of Contractors duties. Notifiable projects are those which involve more than 30 days, or more than 500 person days of con - struction work. Further details are available within Barbour Guide CDM and Construction Site Safety. PAGE 3 > BARBOUR ENVIRONMENT, HEALTH & SAFETY PAGE 5 > BARBOUR SAFE IN OUR KNOWLEDGE

Disclaimer Barbour is a trading division and trading name of UBM Information Limited (UBMi). It has published this Guide in work should always be used in the exceptional order to help the promotion of good practice amongst knowledgeable and competent specialists in the subject circumstance that live working cannot be avoided. covered by this Guide. By using this Guide, the user Permits should also be used for work involving isolation acknowledges, accepts and agrees to the following: at a point remote from the place where the work is taking UBMi does not give any condition, warranty or other term, or accept any duty of care or liability, in connection with the quality or fitness for purpose of this Guide, or any loss or damage resulting from reliance on it, and it excludes all these. When deciding whether or how to act, the user should Where possible, always access obtain restrictions appropriate should professional involve theadvice and should not rely on any information, advice or recommendation in this Guide, however it has been expressed. The user is responsible for obtaining professional advice, and acknowledges that any defects in this Guide would be detected by a knowledgeable and competent specialist providing that advice. Any use of this Guide by any person is subject to UBMi s user terms for Barbour services, and by using it the user is accepting those terms, and agreeing to be bound by them, on behalf of the user and all other persons for In any case, sockets within workshops whom the user undertakes any work. should be protected with residual current devices (RCDs). Fixed workshop machines such as pillar drills The user waives (and agrees to waive) all claims for loss or and abrasive wheels should be bolted down, include damage which it might otherwise have against UBMi in accessible emergency stop devices and be connected connection with this Guide other than those arising out via a no volt release device. of a liability which UBMi has for personal injury (whether fatal or otherwise) resulting from negligence. Further details are available within Barbour Guide Electrical Services and Fixed Equipment. Portable electrical equipment should also be inspected and tested in accordance with a schedule devised by a competent person. Portable power tools should ideally be battery powered or 110v CTE, supplied via a transformer. Where 240v tools are necessary, they should be used only in dry conditions and supplied via a residual current device. Further details are available within Barbour Guide Electrical Equipment: Portable. i. Chemicals and Flammable Substances Smoke Control. Hazardous and flammable substances are frequently used for maintenance activities eg paints, thinners, adhesives, LPG. There are also chemicals used in powered equipment eg lubricants and water treatment chemicals. Basic principles should be applied ie: the storage and use of only those substances required, substances selected to be the lowest hazard alternative possible, kept securely in a minimum quantity and used by authorised and trained persons only, who are properly equipped with carefully selected personal protective equipment. Flammable liquids should be kept in a bespoke PAGE 4 6 > BARBOUR ENVIRONMENT, SAFE IN OUR KNOWLEDGE HEALTH & SAFETY