21 January 2015
The European Commission’s F-Gas regulations have changed. The original legislation was published in 2006 as EC 842/2006 and put in place controls on Fluorinated Green House gases (F-Gases) as part of the EU’s commitment to the United Nations Framework Convention on Climate Change, Kyoto protocol. The new regulations were published in the summer of 2014 and come into force January 2015.
The original regulation, EC 842/2006, was an overarching document with supporting daughter acts and put into place the regime Europe has been working to in refrigeration and fire for the last ten years. This last statement is probably an over estimation as those who have been involved will know there hasn’t been the take up of the regulation that the Commission thought there would be, more on that later.
If for some reason this regulation has slipped past you here’s a brief reminder of what it is and was supposed to do.
What are F-Gases, these are a range of gases all of which contain fluorine e.g. Hydroflurocarbons (HFC), perfluorocarbons (PFC) and sulphur hexafluoride (SF6). All have a global warming potential (GWP) greater than 1 (1 being equivalent to the warming potential of 1 kg of CO2 over 100 years which was chosen as the base level).
Global warming is of course a bad thing and the legislation is aimed at containing, preventing and thereby reducing emissions of fluorinated greenhouse gases covered by the Kyoto Protocol.
These gases are used in a number of areas including car air conditioning, Air conditioning, Refrigeration, Building foam blowing – foam sealants, Novelty aerosols, Fire protection. The refrigeration/air conditioning market is the biggest user by far. Fire protection is a smaller but very important use of these gases and in reality is also non emissive.
The regulation puts requirements on the operators (owners) of systems containing F-Gases to ensure that they do everything possible to reduce leaks and so must only use appropriately registered companies using trained and certificated personnel to undertake the installation and carry out the leak checking and maintenance of those systems.
For fire protection we are talking about systems containing HFC 227ea (FM200), HFC 236fa (FE-36) HFC-23 (FE-13) and HFC 125(FE -25/NAF125) which cover most installed systems but other agents were used and may still be in those systems these were perfluorocarbons PFC-308(CEA-308), PFC-410(CEA-410), PFC-614(CEA-614).
In simple terms what this meant was that if a fire protection system contained, any of the above agents then the installation, service and maintenance, of that system had to be carried out by trained and certificated personnel employed by a certificated company. With regard to leak checking (called containment in the regulation), there were criteria for when this had to be done and again in simple terms if the system contained more than 3Kg of an F-Gas then leak checking had to be done at set intervals.
Things were slightly easier for fire protection since the regulation said that complying with the requirements of the existing standard ISO 14520 was seen as sufficient to meet the leak checking requirements.
Most importantly the 2006 regulation did not put any restrictions on placing HFC’s on the market it focussed on the containment of the gases.
As with all EU regulations EC 842/2006 had a built in review timetable and the review started in 2011 consultants were employed to review the implementation in national regulations of the main text and the daughter regulations on training and certification. The review showed that with a few notable exceptions (UK, Germany) very few EU member states had put in place the certification and training regimes. It also showed that if the EU were to meet their own targets for reductions in global warming gases something would have to change.
The process of revising the regulations was started and the end result was published this year as 517/2014 and it comes into force on 1 January 2015.
So what’s changed, well firstly and most importantly there is now a requirement to decrease the amount of F-Gases in the European market by up to two thirds of the 2010 emissions by 2030. This will be achieved by a gradual phase down on the use of F-Gases. The new regulation allocates quotas to individual producers and importers for the placing of F-Gases on the market. The quota system includes the amount of F-Gases in imported filled equipment not just imported/manufactured bulk gas. Also, the quantity exported in filled containers and bulk gas is deducted from the quota. The quotas will be based on the quantities of F-Gases that reported as having been placed on the marked during a reference period from 2009 to 2012.
The proposed reduction each year up to 2030 will be a percentage of average annual total quantity of F-Gases placed on the market during reference period. What this means is in 2015 it the same amount in 2016-17 it will be 91% of the 2015 amount and then going down in steps.
What does this mean for fire protection well simply there may be less HFC227ea, for example, around and it could cost more for virgin new material but there is a significant bank of recycled material which can be used for new systems and for recharges. The major F-Gas suppliers could divert their new material allocation form replaced materials to fire protection
In addition to this phase down certain F-Gases will be prohibited – i.e. banned – for fire protection there is only one that will be banned for new systems from January 2016 and that’s HFC 23 (FE-13) on a positive note there are very few if any systems containing FE-13 in the UK.
Training and certification that has not really changed, all companies involved in handling F-Gases (installation and/or maintenance) the company needs to be registered and the relevant personnel be trained and certificated.
As mentioned earlier, the regulations had a limit on the size of system that was covered by the leak checking requirements of the regulation and in 842/2006 it was based on the weight of the system as shown below.
3kgs up to 30kgs – every 12 months
30kgs up to 300kgs – every 6 months*
300kgs and above – every 3 months or 6 months if leak detection fitted
In the new regulation this has changed the requirements for leak checking are now determined by CO2 equivalent and start to apply if the system contains more than 5 tonnes so the criteria now becomes
5 to 50 tonnes of CO2 equivalent – every 12 months or 24 months if leak detection fitted
50 to 500 tonnes of CO2 equivalent – every 6 months or 12 months if leak detection fitted
Above 500 tonnes of CO2 equivalent – every 3 months or 6 months if leak detection fitted
Again if the fire protection system is inspected in accordance with the standards, ISO 14520 or EN 15004 then the requirements are deemed to be met.
The CO2 equivalent determined by the GWP of the gas times the mass of the system and this move to CO2 equivalent has moved the ball game significantly.
Under the previous regime the smallest system covered was 3kg, now if you look at the two most common agents FM 200 (GWP 3220) and FE-36 (GWP 9810) it’s immediately obvious this is no longer the case for FE -36 even a 1kg system is now covered by the requirements and FM200 a 2kg system. As you move to the higher requirement significantly smaller systems are now covered than previously. There is a phase in on the requirement for systems less than 3kg as the requirements are delayed until December 2016
This change means that systems previously seen as outside the scope of the regulation with regard to the leak checking are now in. For example small systems used on boats and other craft are generally based on 2kg FE-36 extinguishers, or police forces who moved from Halon to FE-36 for their personal protection are now covered as they used extinguishers around 1-2kg in size.
The good news is since UK was one of the EU Member States who were ahead of the curve in terms of training and certification there are many certificated companies available in the UK and the number of trained personnel was in the 2000 region at last count. So there is already a large pool of qualified personnel and registered companies to meet the challenge of more systems coming under the requirements.
The FIA as the training and certification body is working to update the training to reflect the new requirements.
In summary whilst the new regulation does provide a challenge it’s not unsurmountable, system owners (operators) should check with their service providers to confirm where they fit within the new regime, at the same time service providers and insurance companies should start to inform their clients of the impending changes.
A simple rule is if the company you’re using to service your F-gas system doesn’t have an F-Gas certificate or trained personnel they shouldn’t be touching a fire protection system containing an F-Gas!