Keeping cool

There are three important regulations that require the urgent attention of operators of refrigeration and air-conditioning systems.
These are:

  • Ozone Depleting Substances Regulation
  • F gas Regulation
  • Energy Performance of Buildings Regulation (EPBR)    

These separate pieces of legislation each address different environmental impacts and all impose obligations on the operators of these systems.
Typical hospitals and other health facilities operate systems that need to comply with these Regulations. Examples of such systems are:

  • Large central air-conditioning systems, probably served by one or more packaged chillers (with a chilled water distribution system)
  • Small split comfort-cooling systems (each serving one or two offices with wall or ceiling-mounted cooling units)
  • Similar split systems providing cooling for server or computer rooms
  • Some large items of specialist machinery (e.g. scanners) may also have their own cooling systems
  • Other refrigeration systems such as mortuary systems, low temperature cabinets for drugs or samples and cold stores for catering facilities

ODS Regulation
The Ozone Depleting Substances (ODS) Regulation was drawn up to enable Europe to meet its obligations under the Montreal Protocol, the international agreement designed to halt the damage to the ozone layer. It comprises of:

  • A ban on the most harmful ozone-depleting substances (e.g. CFCs like R12), in force since the 1990s.
  • A ban on new equipment using less harmful “transitional” refrigerants (HCFCs like R22) – since 2001 (or 2004 for small air-conditioning systems).
  • The imminent ban on the use of virgin HCFCs for servicing the stock of existing HCFC systems, which comes into force from the end of 2009. After this, only recycled HCFC will be allowed, until the end of 2014 when these too will be banned.

Given that most refrigeration systems leak to a certain degree, all users of HCFC systems must plan to manage their operations without virgin refrigerant after December 2009. Doing nothing is not a sustainable option. The potential consequences if a mission-critical system fails, without sufficient refrigerant on-hand to enable an effective repair, are very serious. To meet this challenge, facility managers should follow a strategic approach.

A HCFC Phase-out strategy
A model for a successful HCFC phase-out strategy would look like the following:

  • Assess the Risk – Identify all HCFC systems and estimate their business risk.
  • Prioritise – Identify the most business-critical systems and address these first, but without neglecting the other less critical systems.
  • Determine the Phase-Out Solution – After identifying all systems using HCFC refrigerants, assess each one against decision criteria (see Box A) and assign a Phase-Out Solution. These are likely to fall within one of three main options:

1.Replace – some systems should be replaced with new systems using non-ODS refrigerants. Replacement is, however, likely to be the most expensive option in up-front cost terms (around ten times more than a simple “retrofill” conversion).
2.Convert to a new refrigerant – this may be a simple “retrofill” (using a compatible non-ODS refrigerant) or a more significant conversion (requiring new heat exchangers and/or compressors).
3.Leave As-Is – this is not a “do nothing” option. It is only applicable if (a) a guaranteed stock of recycled HCFC is assured or (b) the system represents no mission-critical risk.

  • Planning and Budgeting – Develop a Phase-Out Plan. Depending on the size of your operation, it is unlikely to be possible or desirable to carry out all the actions at once. This should be done in association with your air-conditioning contractor, to ensure their availability and commitment.
  • Implementation – Carry out the plan, with monitoring and regular review.
  • Recycled R22 Stocks – Due to the likely shortage of recycled HCFCs (see Box B), it will be imperative to manage your stocks of recovered HCFCs. When systems are either replaced or converted, the recovered gas will be needed to service those systems still using HCFCs.

F Gas Regulation
The F gas Regulation aims to reduce the emission of fluorinated gases into the atmosphere, where they contribute significantly towards global warming. These F gases include HFC refrigerants, some of which have a global warming potential (GWP) over a thousand times that of carbon dioxide.
The regulation, which came into force in July 2007, places important obligations on the operator of certain equipment containing HFC refrigerants. These are summarised below:
F gas Regulation – Obligations for the Operator of refrigeration or air-conditioning systems

  • General Obligation to Prevent Leakage – Using all measures that are “technically feasible and do not entail disproportionate cost”, operators must (a) prevent leakage of HFC gases and (b) repair any detected leakage as soon as possible.
  • Regular leak testing – Certified personnel must check systems for leakage by certified personnel on a regular basis. The frequency of testing depends on refrigerant volume, as shown below:

Refrigerant Charge Leak Test Frequency
3 to 30 kg: Every 12 months
30 to 300 kg: 6 months
Over 300 kg: 3 months

  • Automatic Leak Detection Systems – Plants with 300 kg or more of F gas must be fitted with automatic leak detection. For any plant fitted with such a system, the frequency of manual leak checking can be halved, to a minimum frequency of once every 12 months.
  • Record Keeping – Records must be kept about any system with 3 kg or more of HFC refrigerant.  These must include:
  • The quantity and type of refrigerant
  • The quantity of any refrigerant added or recovered
  • Details of leak tests
  • Details of any repairs, including identification of the company and technician who carried out the work.
  • Gas Recovery – HFC refrigerants must always be properly recovered from plants requiring maintenance or at end of life. This may only be carried out by certified personnel and the recovered refrigerant must be recycled or sent for reclamation or destruction. NB: Recovered gas is a hazardous waste and must be treated accordingly.
  • Qualified Personnel – Personnel carrying out refrigerant handling, leak testing or gas recovery must have the necessary qualifications. New qualifications are being phased in by 2011. For further details, see

Time to comply
If you use HFC refrigerants in your air-conditioning or refrigeration systems, you need to be complying with these regulations now. It is over 12 months since the regulations came into force, so all systems containing 3 kg or more should have been leak tested. All systems over 300 kg should have an automatic leak detection system fitted. A system of record keeping should be in place for all these systems.
A comprehensive compliance strategy should include the following steps:

  • Identify all refrigeration and air-conditioning systems containing F gases, and record their refrigerant type and charge (kg).
  • Determine who is the “Operator” – this is an important distinction since it may be the landlord, tenant or (less likely) a third-party FM contractor. In future, it is important that the “operator” is clearly identified in any tenancy or FM contract.
  • Keep the necessary records.
  • Carry out leak tests at the required frequency.
  • Install automatic leak detection systems for plants containing 300 kg or more of HFCs.
  • Obtain assurance that maintenance personnel have the necessary qualifications.
  • Ensure that refrigerant recovery is carried out effectively.

Energy Performance of Buildings
New legislation to implement the Energy Performance of Building Directive (EPBD) was published in July 2008 by the DCLG. This includes requirements for inspections of air-conditioning plants, designed to improve energy efficiency and reduce carbon emissions.
The Regulation imposes an inspection regime, which must be carried out by an accredited Energy Assessor, on all air-conditioning systems of over 12 kW rated cooling capacity. Inspections must be carried out at least every five years. The first inspections must be carried out by the following deadlines (see table):

Box A – Decision Criteria
The decision to Replace, Convert or Leave an HCFC plant should be based on a number of criteria, which may include:
1)System Type – does the system use “direct expansion” or a “flooded” evaporator? This is an important distinction and requires the assessment of an experienced refrigeration or air conditioning engineer.
4)Satisfying Current Requirements – this is an opportunity to replace the system (or alter it) to meet the current and forecast cooling requirements.
5)Energy Efficiency – the benefits of a new energy-efficient system should be assessed. This is an opportunity to consider additional cost saving options, such as free-cooling.

Box B – Managing Stocks of HCFCs
The availability and price of recycled HCFC gases after the end of December 2009 are very uncertain.  
The ODS Regulations are currently under review and the proposed amendments suggest clearer definitions of recycled and reclaimed HCFC. If these amendments are agreed, it is likely they will further tighten the availability of recycled R22 on the open market.

  • “Recycled” HCFC (recovered HCFC that has been passed through a filter) may only be used again by the same owners in their own systems.
  • “Reclaimed” HCFC gases (which have been reprocessed to a condition indistinguishable from virgin gas) may be transferred to another owner for use elsewhere. 

Any organisation planning to use recycled HCFCs in systems after the end of 2009 should contact their air-conditioning contractor to discuss how to meet their anticipated demand.

For more information
For more information on the requirements of the EPBR Air Conditioning Inspections, go to the Communities and Local Government website at:
For advice on compliance with the F gas and ODS Regulations, contact “F-Gas Support”, a DEFRA funded body set up to assist users to meet their obligations. Website:
Telephone Helpline:  0161 874 3663